HOW MUCH DID WOOLWICH COUNCIL & FRIENDS LEARN THROUGH 2015 and 2016?

 

Well they certainly learned that they are not bulletproof. They learned that their disgusting and unethical and even illegal behaviours have consequences. They were investigated by the Ombudsman, the Integrity Commissioner, MECAC, provincial and Superior Courts in Kitchener and the media. Likely the media hurt the worst. Notice that councillors Scot Hahn and Mark Bauman never ran again for council and Mr. Hahn even resigned in mid term.  Mayor Sandy Shantz generally skated through all the investigations of bad behaviour and poor decision making although enough of you know what stuck to her during the process. As it should. Her hands were dirty.

From improperly held in camera council meetings to attempts to deny citizens their right to speak to Council and right on up to ridiculously stupid and lazy attempts to bypass the Municipal Elections Act regarding campaign expenses; councillors behaved like third world, bush league little despots. And got caught! Over and over again.

Woolwich Council back then were way too big for their britches. They through manipulation and lying along with Chemtura and the Ministry of Environment got rid of the best CPAC (Chemtura Public Advisory Committee) there ever was.  They did this to protect and enable Chemtura's (later Lanxess's) cleanup failures in Elmira. CPAC on a monthly basis was roasting the the Ministry (MOE) and Chemtura for their lying, deceit and manipulation in avoiding proper ground and surface water cleanup. The Woolwich Observer as well as the K-W Record not to mention CKCO-TV plus radio stations may have been light on pollution coverage but they just ripped dogpatch (Woolwich Twn.) over and over again for their myriad of political and ethical failures as mentioned above.

LANXESS, MECP & WOOLWICH DEFRAUDED THE PUBLIC?

 Hmm is defrauded above  the proper term? Certainly they have lied, deceived and generally treated the public with contempt. Does any of that pass whatever legal test is required to make such a claim? How would I know, I'm neither a lawyer nor a flakking politician appointed judge. 

Back in 2014 CPAC asked me what single issue was so serious and blatant that they should focus upon it. After careful consideration I told them that there were two issues of huge but significantly different importance and in my opinion either one was worthy of CPAC's focus. The two issues were DNAPLS still on site (& off) as well as the entire east side properties namely the Stroh and Martin farms. We ended up pursuing the east side contaminated properties which both infuriated and terrorized Chemtura/Lanxess, the MECP  and Woolwich Township big shots. 

To this day there has NOT been anything even vaguely resembling a serious investigation of the levels of contamination on those two properties courtesy of Uniroyal Chemical. The pathways are there, are obvious and clear. Dioxins, DDT, NDMA and likely the whole suite of Uniroyal toxic liquid wastes flowed both above and below ground surface onto the Stroh and Martin properties. I expect that the Stroh property is the worst of the two.

Not to worry though. Don't you know that all technical problems merely require political efforts to be resolved? This resolution of course favours the well connected, the well off and their friends. It does nothing for the environment, the majority of local citizens or the wildlife. As usual they are sacrificed for the benefit of the few.  The Elmira By-Pass will go up the east side combined with commercial development. The whole idea is to bury as much as possible and hope that erosion, flooding and natural contaminant migration will be limited. Afterall our authorities, with greed and malice aforethought, have been doing that for decades without a care in the world.  So far no one has gone to jail and as long as developers, politicians, their polluter friends and other assorted riff raff play by their personal rules versus the law, all will continue unbothered by the damage and harms they inflict upon the rest of us.   

TWO UPCOMING TRAC DATES ALTHOUGH THE FIRST MAY BE CANCELLED

 The two original dates were October 10 and November 14 of this year. Now I do recall some discussion of October 10 being too early and the alleged public consultation body are awaiting  on (as always) some report from the MECP. So please pay attention say in next week's Woolwich Observer and if there isn't a Notice for the Thursday October 10/24 meeting then likely it's been cancelled.

The primary Agenda items these days are Lanxess and the Ontario MECP putting lipstick on their pig. Their pig is of course the utter and complete failure of RAC, TAG and belatedly TRAC to achieve drinking water standards by 2028 in the Elmira Aquifers. Obviously the prime responsibility rests with Lanxess and the MECP but Sandy Shantz is the major architect of the removal of the best CPAC there ever was back in September 2015. Hence the last nine years have been a total waste of time as RAC, TAG and now TRAC continue to express their love and devotion for corporate polluters, and corrupt regulators with only occasional mews of concern combined with Sebastian's recent couple of body blows to these three groups. Calling them deferential and Lanxess's consultants the equivalent of client driven as Sebastian did should happen at each and every meeting thus letting the public know that the rosy propaganda is not shared by all. 

Further lipstick on a pig includes a new Control Order from the MECP which heaven forbid likely will be no more enforceable or serious than the last ones. Control Orders are introduced with fanfare and then watered down to the polluter's convenience when their is less public outrage and supervision ongoing.

Further lipstick will include definitions of what drinking water standards in the Municipal Upper and Municipal Lower Aquifers actually will mean.  Maybe they will even allow allegedly "treated" water to be reinjected back into the aquifers.  Perhaps select wells in the Elmira North and South Wellfields will be put back into operation and as the Region of Waterloo do in Cambridge they can play musical wells by shutting down those nearest contaminant plumes and pump water for use from others. As the plume slowly shifts towards the pumping wells then they can be shut down and others started up.

I have reason to believe that new remediation is at the least being discussed. While I have no reason to doubt that proper groundwater remediation exists I have strong doubts that Lanxess or the MECP have any serious will to actually spend money and do the required work.

This is typical cosmetic nonsense of the last three and a half decades. It's all about managing the media, the citizen opposition and the truth. Propaganda is lying to the public and our authorities have had decades of practice.

THREE SPEAKING ENGAGEMENTS ABOUT ELMIRA'S NON-CLEANUP THIS YEAR

 I view this as a very positive sign that the message is getting out there despite the best (perverted) efforts of Lanxess, the MECP and their fellow travellors.  Last spring of course we had the public meeting held here in Elmira that was attended by 70 people.  Rich Clausi was our Master of Ceremonies and Sadi did all the work around organizing both the venue (Rural Roots) and bringing out Elmira citizens. There were two guest speakers of which I was one. Then this summer I spoke to the retired wing (Kit.) of the OSSTF (Ont. Secondary School Teachers Federation.). That also went very well . Finally my third speaking engagement is about a month away and it too is quite local.

I have been pleasantly amazed at how understanding and unfortunately resigned citizens are in regards to governmental corruption. Citizens know that they are being lied to on a myriad of topics every day of the week by our politicians at every level. Convincing them has not been a problem as they've already come to this conclusion on their own. 

CREATING YOUR OWN REALITY

 One perfect, well known example is that of Donald Trump. He and the Republican Party haven't just created a hero, a bigger than life, fictional politician who admires Mussolini, Putin, Orban, Erdogan and other world leaders (?)  o.k. world despots but an actual myth around Mr. Trump. He allegedly is the only one who can unite America and make it great again. Or some such bull#@*%. 

Uniroyal/Crompton/Chemtura and now Lanxess have created a similar myth. Their myth is that the cleanup of Elmira's air, waters and soils are and always have been  in good hands and under control. This false myth is obvious when 35 years after the November 1989 Elmira Water Crisis our contaminated aquifers aren't even close to being drinkable  (NDMA  MU  .091 ug/l     ML  1.61 ug/l) average concentrations and chlorobenzene average concentrations are    MU  123 ug/l   and ML   173 ug/l . Now keep in mind these are all in ug/l which equals parts per billion (ppb)  and the drinking water standards are .009 ppb for NDMA and 80 ppb for chlorobenzene.   (MU = Municipal Upper   ML = Municipal Lower.)

Hence NDMA's currently on average concentration is between TEN and  SIXTEEN HUNDRED times greater than the Ontario Drinking Water Standards depending on which drinking aquifer is examined.

Chlorobenzene's currently on average concentration is between ONE & A HALF and TWICE times greater than the Ontario Drinking Water Standards depending on which drinking aquifer is examined. 

Of course the professional liars haven't mentioned the other hundred or more toxic chemicals also in our drinking water aquifers. Not to worry they say, those too will eventually be removed.  Sure they will along with NDMA and chlorobenzene in another 30 to 60years depending on the quality of the lying between now and then.

BAD ADVICE?

Recently it's been suggested to me that I focus my attention and wit more upon the Ontario Ministry of Environment (MECP) and less upon Woolwich Township. Basically the answer is no. The MECP certainly are corrupt by various definitions of that word. They are also cowardly and have no backbone for a fight with any multi-national corporations who are big enough to hit back, hard. They trounced Varnicolor Chemical in Elmira only after they realized that myself, Rich Clausi, Susan Rupert and Ted Oldfield were taking no prisoners. We kicked Varnicolor's butt as well as the then Ministry of Environment (MOE)  publicly and regularly. We humiliated the MOE over and over again and with the media's help had some calling for a Public Inquiry into the Ontario MOE.

I believe that I focused on Uniroyal/Crompton/Chemtura and the MOE for almost twenty years. Only later on did I actually realize how corrupt and back stabbing the Township was. They were aiding and abetting the polluter throughout including elevating co-opted individuals and undermining those (moi) who opposed the polluter and the MOE. I recall a private meeting with Woolwich Council in the spring of 2008 when I asked councillor Sandy Shantz, who attended CPAC meetings, straight up in front of her colleagues if she had EVER seen or heard me criticize a fellow CPAC member ?  The liar hummed and hawed until she finally mumbled something to the effect of gosh she wasn't sure. I knew then that the fix was in. I had sat beside Sandy at CPAC and yes I was hell on wheels with Chemtura and MOE liars and deceivers but I had NEVER publicly at CPAC criticized or insulted a fellow CPAC member. 

After that Sandy and other corrupt councillors were fair game and still are. They have long enabled the lies and deception fed to the public by the polluter and their fellow travellors. 

 

THE LACK OF MORALS AND ETHICS INVOLVED WITH CORPORATE GAMESMANSHIP

 Uniroyal, Crompton, Chemtura and Lanxess are the corporate names of the immoral corporations polluting Elmira, Ontario.  Is there actually a morally good corporation out there that puts the public interest before their own? If so their CEO and staff would soon be out of a job. Shareholder profits, long or short term are their motivation, not moral goodness.

Gamesmanship isn't so much about playing with the rules or by the rules. It's about manipulating people. It's about carefully determining who potential friends are who can be enticed in your direction and also who the serious opposition will be. It's all about uplifting "friends" and cutting down those who oppose your contrary to the public interest, behaviour. Uniroyal knew that once Susant Rupert had left Elmira that they might be able to make some quiet inroads into APT Environment . Boy that has saved them hundreds of millions of dollars in cleanup costs. 

They have continued co-opting politicians and others. They have consolidated since September 2015 their control of the hilariously designated public consultation bodies from RAC/TAG to TRAC. They have attempted to infiltrate persons past and present into the real opposition. Their gamesmanship is disgusting. But then so is their pollution and their lies around it. 

THE DEFINITION OF INSANITY IS DOING THE SAME THING OVER AND OVER AGAIN AND EXPECTING A DIFFERENT RESULT

 Now with normal, regular, honest science there is a rule, if you will, that experiments must be reproducible. In other words if you get a surprise result from a scientific experiment you don't immediately rush out to write it up and then publish it in a scientific journal for your peers to read. Instead you carefully redo the experiment over again, maybe even several times, to see if the surprise result was an anomaly, a fluke or the result of a mistake somewhere throughout the process.  If however you get the same results from the exact same experiment, components and procedures then you may well be on to some new information.

On the other hand CRA/GHD are masters of junk science, psuedo science and just plain nonsense science. Their client, Uniroyal/Lanxess, have also been big time players when it comes to gamesmanship.  That gamesmanship includes help from their fellow travellors recruiting/enticing citizens to their cause, both declared and undeclared. It includes poaching from citizen groups again declared and undeclared. Susan Bryant is their biggest success although they have tried others. These fellow travellors include the GRCA, the MECP and Woolwich Township. Awards and certificates for example can be bestowed whether for merit or for different, less honourable reasons. 

 Their recent "investigation" of industries in Elmira using or having used chlorobenzene didn;t tell the public a single thing about that. Not one company was straight up named as using chlorobenzene. It sounded like maybe Nutrite/Yara but definitely not Varnicolor.  Borg Textiles was not named or investigated yet they are very high on the list of potential bad actors who used chlorobenzene in their textile manufacturing whether through their dye shop or otherwise.

So what is happening that requires another massive dose of insanity by the public? It is Uniroyal/Lanxess claiming to be hot on the path of the latest and greatest remediation that will do more in five years than their blessed pump & treat has done in thirty years. Promises are wind for Uniroyal and its' successors and always have been. New faces, new approaches, new words mean nothing when we have a thirty-five year history of bulls%*# from both this company and their tarnished/corrupt regulators, the Ontario Ministry of Environment. Yes I believe that proper remediation including Source Removal done honestly and professionally could have had our aquifers cleaned up over a decade ago.  They could also be much further along with on-site cleanup by now if they had gotten to it thirty years ago. Why however would I believe that their promises today are one bit more honest and truthful than all their broken promises since 1989?  One would either have to be naive/ignorant of the corporate beast or frankly insane to believe their verbal or written comments.  

NOPE YOU CAN'T LET WOOLWICH OFF THE HOOK! THEY ARE BOTH RESPONSIBLE AND CULPABLE

 There is a moral, ethical and probably even legal onus on Woolwich councillors to do the right thing . By right thing I would suggest that that means that whatever issues are municipal from taxes, various by-laws, local development, roads, sewers and water, noise problems, odour problems  etc. must always be decided with the public interest in mind. Both short term and long term public interests need to be considered. Hence a short term road closure may not be in the public's immediate best interests but surely in the long term a closure for repairs will be. 

So does that give the municipality free rein to lie to their citizens? Especially long term lying just because the councillors think that they know better than their citizens? I think not.  If councillors and mayor believe that a dirty polluter's value to the community is greater than it's harm to the community do they have the right to lie and gild the lily? They do not! If the Council wish to educate their citizens , fine. If they wish to hold public meetings and TRUTHFULLY broadcast all the wonderful advantages to the community by the presence of the dirty polluter, again fine. But when it gets to the point that the only way that Councils can sell the continued presence in town of a dirty, dishonest polluter is by lying through their teeth to the public then it's time for the liars, politicians and truth challenged individuals to get the hell out of town.

What about moments of huge crisis? Have any of Woolwich Township's elected councillors/mayors exhibited intellects so far advanced from the rest of us that we would assign them dictatorial powers? Good Lord no. Generally to get elected they either have Mennonite last names, look good or have catapulted from a smaller community size issue into public office. Yes there have been some smart, intelligent councillors but for each of those there have been some real putzes i.e. dumb, uninformed, lazy. I don't need to name them. If you've been paying any attention you know who they are.  

Maybe the day will happen when blatant lying and coverups will be punishable by law. Maybe we will eventually see dishonest politicians who are in it for their interests only, running for the hills. You can start with Woolwich any time at all. Going along to get along is not O.K.. 

 

THE DNAPL COVERUP CONTINUES TO THIS DAY - THANK YOU ALLAN DEAL (GHD) & LANXESS

 

Who can remember all the lies and carefully maintain them over decades? Certainly Allan Deal is having difficulties. He was stumbling, misstating and confusing truth and lies during his alleged "Chlorobenzene Source Evaluation".  He repeatedly conflated the word "chlorobenzene" with chlorinated solvents. Granted even some of his text up on the screen also seemed to be having troubles using the two words consistently or appropriately. Very strange. At 1:01:49 of the Township's on-line video of last week's TRAC meeting chlorobenzene is conflated with chlorinated solvents both verbally and in writing up on the screen. Also this was supposed to be a "Chlorobenzene Source Evaluation" not a chlorinated solvents source evaluation. Two DIFFERENT things. 

Mr. Deal predicted that chlorobenzene in our aquifers would be mostly O.K. by 2028. More bull as his "asymptotic" nonsense presentation told us that chlorobenzene in the Municipal Upper aquifer was at an average concentration of 123 ppb. and in the Municipal Lower aquifer at 173 ppb. The standard or criteria is 80 ppb. Three and a half years won't make much difference.

Mr. Deal stated in response to a question about off-site DNAPLS that there were none in the off-site MU (Municipal Upper).  Nice deflection as they likely started in the shallow Upper Aquifer and likely have migrated downwards. Well W8 on the Yara property is likely affected by DNAPL chlorobenzene. W4 near the Howard St. water tower was affected by DNAPLS for years  and Mr. Deal nearly blew it when he stated that after that pumping well was turned off it didn't have it's concentrations rebound at all. He made it sound as if either he was expecting rebound or that he was surprised that it hadn't. That is true because he knows that pumping well W4 was located right there exactly to pump out the dissolved from DNAPL chlorobenzene earlier found in well OW57-32  

Finally Allan Deal fudged again . The e-mail sent out with the Revised Agenda had page 30 marked as THANK YOU and page 31 marked as "Isotope Sample Analysis". The Figure presented shows five different wells all screened in the deeper aquifers (MU, ML) and sampled for MCB - monochlorobenzene  the same thing as chlorobenzene. The funny thing is that well OW-41  from the Varnicolor Chemical site allegedly has 580 ppb chlorobenzene in it!  The point this page and Figure are making is that Isotope Analysis isn't clear enough to prove or disprove other sources of chlorobenzene.

Here however is the point . This page (31) was not presented to TRAC eight days ago. It was left off. No wonder! Mr. Deal was attempting to blame all the hydrocarbons and solvents in Varnicolor's deep aquifers (MU) on them by falsely saying upgradient Uniroyal Chemical didn't handle any of them. That has since been disproven. So by Mr. Deal's logic MW-41 on the Varnicolor site having chlorobenzene in it must have come from Varnicolor just like the other listed chlorinated solvents on their site.

So which is it folks? Did Varnicolor dump chlorobenzene on their site along with the rest of their massive dumping or did the chlorobenzene come from Uniroyal ?  Did Mr. Deal attempt a misdirection by avoiding page 31 that he sent out initially after he saw that it undermined his and the MECP's theory of  no chlorobenzene at Varnicolor AND it also undermined his theory that the chlorinated solvents in the MU below Varnicolor came from Varnicolor not the upgradient Uniroyal/Lanxess?  How about the possibility that the free phase DNAPL by the Howard St. water tower gravity flowed from  the former Borg Textiles.? Yes that's the same Borg Textiles that Allan Deal couldn't find chlorobenzene, chlorinated solvents or anything else at despite their former on-site dye shop . All in all yet another confused and confusing presentation riddled with errors and inconsistencies. 

THE DNAPL COVERUP ISN'T THE ONLY REASON THEIR "CLEANUP" HAS FAILED BUT IT'S A BIG ONE

     CLICK TO ENLARGE THE TABLE BELOW!

 So what is this Table above? It is the next page of Jaimie Connolly's (M.O.E. hydrogeologist) May 2, 2008 DNAPL report . Yesterday I showed the seventh page with a number of groundwater contaminants from monitoring well OW86. This is the eighth page with the rest of the contaminants found in the groundwater.  Particularly note chlorobenzene and it's Aqueous or pure phase solubility of 444 mg/l versus it's Effective Solubility of only 1 mg/l  when it is in groundwater mixed with fifteen or sixteen known other contaminants and who knows how many unknown ones. Basically at this monitoring well the concentration  of chlorobenzene of .033 mg/l  or 33 parts per billion (ppb) is a strong indication of chlorobenzene as a free phase DNAPL nearby as 1% of the Effective Solubility is 1% of 1 mg/l (i.e. 1,000 ppb.) which equals 1% x 1,000 = ten (10)  parts per billion.

It is likely that Lanxess "forgot" to be honest with Dr. Neil Thompson (U. of Waterloo) about the presence of DNAPLS on their site. Hence his calculations of how much chlorobenzene should be present may have been way off and in fact could only be explained by his determination that there was an excess 1300 - 1900 kg. of chlorobenzene from an unknown source.  This left the MOE/MECP and Lanxess in a pickle as their sweetheart deal is predicated on Uniroyal/Lanxess being the sole source of Elmira's groundwater contaminants. Now that is buggered with Nutrite/Yara as well as with Varnicolor not to mention one further north and possibly either Borg or Varnicolor up to bat for the "excess" chlorobanzene. This is the confusion that professional liars sow. When they lie about almost everything you no longer know where the lies stop and if and when they are speaking the truth.

Allan Deal's chlorobenzene report a week ago at TRAC was pitiful. Good reason for the TRAC Chair to delay or deny questions from apparently the only honestly informed person present, yours truly. Good Job Nathan. Sandy, Lanxess and the MECP all love you. 

EFFECTIVE SOLUBILITIES CALCULATED BY THE ONTARIO MINISTRY OF ENVIRONMENT

 

Below is a Table from Jaimie Connolly (MOE hydrogeologist) dated May 2, 2008 presented to the MOE, Chemtura and CPAC.  It shows how extremely reduced the Aqueous or Pure Phase Solubilities of various contaminants are in groundwater that has multiple different liquid contaminants dissolved in it

Click on Image (Table) to make it larger!

Click on Image to make it larger !

SO WHAT EXACTLY AM I TRYING TO DO ?

 O.K. a week ago I gave a little explanation as to my strategy. Today will be a little more. Politicians and other assorted riff raff are big on plausible deniability. Their attitudes are if you have a problem for gosh sakes don't aggressively go out and investigate it. If you can smell smoke there may well be a raging fire nearby and the less we know about that the more we can pretend it doesn't exist. So by my sending municipal and regional councils detailed and specific facts regarding the east side of Lanxess i.e. the Stroh and Martin farms , the harder it is for them down the road to plead ignorance.

It's the same thing with DNAPLS (dense non aqueous phase liquids). The more information and facts they have the harder it is for them to pretend that it is a complex problem beyond their reach. Or even more so that it is a complex problem that must be left to the credentialed experts i.e. Qualified Persons  Coincidentally all the QPs are bought and paid for...oops I mean hired by the polluter and his fellow travellors. Names are not always necessary as they likely have mothers, families, children etc. and what some of them are doing is not illegal although it should be.

So I've been sending detailed facts and data to Woolwich Council, Waterloo Regional Council, Lanxess some, Ontario MECP some, TRAC some, and the media. Have you noticed how little interest the media have in Elmira these days? Are they waiting for another explosion and fire or something more dramatic like half of Elmira not waking up some morning?

By the way short of them surreptitiously adding the multi page report on chlorobenzene to last week's TRAC Agenda at the last possible moment, along with a brief description of the both short and long term groundwater pumping failures; there has been an awesome silence from our authorities in response to the facts being sent to them. Zero from the two councils, zero from TRAC, the media and the MECP. It is their non responses to an informed citizen's critiques and  clarifications of their errors and misunderstandings that is the most damning of their actions and inactions. Clearly they know that my facts and claims are accurate and the very last thing in the world they ever want to do is to publicly discuss any of it.  They are fearful, even terrified, as well they should be. Their day of reckoning is approaching and they know it.

Informed opposition to their "remediation" coverup continues. Informed opposition to their plethora of lies and deceptions involving groundwater, the former Uniroyal site, the Canagagigue Creek, other industrial sources of contamination in Elmira, the knowing and willful poisoning of Elmira residents for years will not end. Eventually they will be confronted en masse and what they do and don't do now will determine their eventual fates.

   

EPA & USGS DEFINITIONS OF EFFECTIVE SOLUBILITY

    EPA - U.S. Environmental Protection Agency

USGS - United States Geological Survey

         SOURCES:

  "Effective Solubility Assessment for Organic Analytes in Liquid Samples, BKK Class 1  Landfill, West Covina California 2014-2016  USGS Open-File Report 2019- -1080"

    "EPA  Ground Water Issue  Dense Nonaqueous Phase Liquids  March 1991" 

Page 8  EPA      

                         "Organic compounds are only rarely found in ground water at concentrations approaching their solubility limits, even when organic liquid phases are known or suspected to be present. The observed concentrations are usually more than a factor of 10 lower than the solubility presumably due to diffusional limitations of dissolution and the dilution of the dissolved organic contaminants by dispersion. This has also been attributed to:  reduced solubility due to the presence of other soluble compounds, the heterogeneous distribution of DNAPL in the subsurface, and dilution from monitoring wells with long intake lengths."

Page 2  USGS

                           "...the presence of DNAPL or mixed DNAPLs was considered unlikely based upon measured concentrations below the aqueous solubility threshold of 1 percent that is commonly used as a "rule of thumb" to screen for the presence of DNAPL, as described in the Draft Leachate Investigation Report ..."

"However, the 1- percent threshold for considering groundwater concentrations indicative of NAPL presence refers to effective solubilities rather than aqueous solubilities, when the NAPL may contain more than one compound ."

    Personally I have been aware of the difference between Aqueous or Lab Solubilities and Effective Solubilities for at least the last twenty-five years. So have Conestoga Rovers and GHD and any other "experts" in the field. Oddly none of them spoke up at last Thursday's TRAC meeting as Allan Deal (GHD) verbally misrepresented the 1 % rule of thumb by suggesting that concentrations at or above 4,900 ppb (ug/l) were required to indicate DNAPL presence. 

I think Sandy that either your "experts" are no such thing OR they find it beneficial not to criticize or dispute Lanxess and their client driven consultants. Keep on appointing polite, deferential people who will never say BULLSHI*  even when they're up to their necks in it.

Alan Marshall  EH-TEAM & more

REGARDING LIQUID CONTAMINANTS, EFFECTIVE SOLUBILITIES ARE LOWER THAN LAB SOLUBILITIES

 The title above refers to yesterday's second last paragraph here where I discussed Mr. Deal's misleading of TRAC and the public by stating that the 1% rule indicated that chlorobenzene concentrations had to equal or exceed 4,900 ug/l (ppb.) to indicate possible DNAPL upgradient. That is nonsense based upon the multitude of dissolved chemical contaminants in Uniroyal/Lanxess's groundwater. Much lower concentrations based upon the EFFECTIVE Solubility would indicate DNAPL nearby. 

Five minute wonder Hadley (Lanxess) advised TRAC that Lanxess are now thinking of recirculating treated groundwater into the Elmira Aquifers. This sounds the same as suggestions decades ago to "reinject" allegedly clean groundwater back into the aquifers. I'm skeptical and for good reason.

TRAC were advised that the MECP are not ready to finalize the Risk Assessment after all these years (of deception, delay and obfuscation-my comments).  My guess is that they too are wondering if the public will be able to swallow the "no unacceptable risks" bulls**t  Lanxess (Stantec) are selling. 

Sebastian actually advised at Thursday evening's TRAC meeting that the pumping at on-site well PW4 was "woeful". He is correct yet for him to criticize Lanxess so harshly is music to my ears. That well is the MAIN well preventing the grossly contaminated on-site Municipal Upper (MU) from flowing off-site and recontaminating the Elmira Aquifers all over again. These excuses by Lanxess do not bode well for the promised pumping forever (in perpetuity) on the Uniroyal/Lanxess site. 

One more of these excuses was presented by Allan Deal advising that an "engineering buffer" is built into the Target pumping rates. This is to suggest that the Target Rate is flexible and can be readily under achieved without consequences. One that is not what we were told decades ago and to this day the following sentence is written in the footnotes (1) below each month's (Progress Report )Table of Average Daily Pumping Rates : " GHD recommends that Lanxess maintain the target pumping rates greater than or equal to these rates."  So quit making excuses and get your G.D. pumping rates back where they belong which is the long ago approved TARGET PUMPING RATES!!!

Apparently the Ontario MECP are writing some kind of tech report about the Risk Assessment. Whoopdy Do !!! Now it sounds as if Lanxess may share that report with the downstream farming families (Old Order Mennonites) first and then later with TRAC. Well the good news for Lanxess is that they will not get much if any opposition from either group. 

Again Lanxess are terrified about both on and off site DNAPLS hence repeated attempts to either manufacture or enhance "evidence" that might suggest they don't exist and never did.  Comparing chlorobenzene concentrations in wells PW4 (on-site) and W4 off-site is one example. Allegedly the chlorobenzene concentrations have been dropping in W4 and not so much in PW4. If this proves anything it is that the free phase DNAPL beside PW4 on-site at well OW88 is greater in mass and volume than the DNAPL found beside the Howard St. water tower in well OW57-32  which instigated W4 being located right there. 

Thank you Mr. Deal for using Varrnicolor Chemical as a distraction to TRAC members. At the same time you have emphasized how Varnicolor were/are a source of contamination to the Municipal Aquifers in Elmira albeit allegedly only of six solvents including very toxic Vinyl Chloride, DCE and others. Also we are advised that after 35 years Varnicolor still is not fully remediated either, as the owner who tried to get a clean bill of health in 2016 from the MECP has given up on it.  

I would characterize Thursday's TRAC meeting as an exercise in Dishonest Sincerity by GHD. Woolwich Township should be ashamed of their enabling this manipulation and deception of their citizens.

UNIROYAL/LANXESS CONSULTANTS CONTINUE TO LEAD WOOLWICH TOWNSHIP BY THEIR NOSES

 This is certainly accurate for the newer, younger Township councillors. They haven't got a clue albeit how could they? The CAO, mayor and former TAG Chair Tiffany Svensson are totally different. Unless all three are far stupider than I give them credit for, then they know full well what's going on and are a part of it. Last night's TRAC meeting was yet another case of the same two twits, Luis Almeida and Allan Deal strolling down the garden path with untrained amateurs  in tow.  Now the likes of Eric Hodgins (RMOW) and maybe one or two other professionally trained  persons not so much. I suspect that this is the reason honest persons such as Katherina Richter and Dustin Martin walked away from TAG. The stench of complacency and bulls**t was too overpowering. Only one TRAC member last evening showed the slightest amount of common sense and outrage and that was Sebastian Seibel-Achenbach. He pushed hard against both Luis and Allan Deal's plethora of excuses and lies regarding Lanxess's major pumping reductions and failures especially on-site albeit off-site as well.

Agenda Item 5.1.2.3 discussed pumping rates. and as indicated above it was yet again excuse after excuse as to why over the last three to four years both on and off-site pumping has been decreasing. Decreasing by ridiculous amounts especially when we are told that they aren't going to achieve drinking water standards by 2028. Does an Olympic athlete after being told that he is shy of the Olympic standard, slow down? Does he coast when his coach tells him it's time to get to work ? That is exactly what Lanxess have been doing while making up excuse after excuse rather than getting to it and pumping MORE as they have promised to do in the past.

Then we get to what passes for an "investigation" by these clowns. CRA have been caught over the years fudging and pretending that they are doing scientific inquiry and studies. Dr. Richard Jackson (former TAG Chair) literally laughed at their so called "pilot testing" of ISCO (In Situ Chemical Oxidation).  Both Morrison-Beatty's and CRA's DNAPL "investigations" were a farce intended to disprove the obvious which had even been admitted privately by Frank Rovers (CRA) that the site was filled with DNAPLS whether free phase or residual. Honest interpretations of the data showed the same thing.

Last night's "Chlorobenzene Source Evaluation " at TRAC was more of the same. Essentially Allan Deal (GHD) set out to "prove" that Dr. Neil Thompson of the University of Waterloo was wrong when he reported several years ago that there was an excess 1300-1900 kg. of chlorobenzene in the Elmira Aquifers. That "excess" was based upon Uniroyal Chemical records showing exactly how much chlorobenzene was used in production over the decades and how much chlorobenzene was discharged into the wastewaters dumped on site. Lanxess later reported that isotopic analysis proved that it was different chlorobenzene in parts of the Elmira Aquifers than what was discharged on the Uniroyal site. 

Mr. Deal's "investigation" had four components to it of which he failed to share the results of the alleged "review of historic chlorobenzene users"; he installed one whole new monitoring well somewhere with a blurry map  of where; he collected samples and analyzed them for VOCs and finally he collected samples for isotope analysis. Not a mention by Mr. Deal of Borg Textiles as a historic chlorobenzene user. What relevance was there for the new monitoring well? What did it prove or disprove? His analysis of samples for VOCs was irrelevant in that the samples were from Varnicolor Chemical and "are not COCs at the Lanxess site" which is a whole lot different than saying they are not on the Uniroyal/Lanxess site. COCs are Contaminants of Concern and chosen by Lanxess. Finally the isotopic analysis. What a pile of pus . Where were the samples whether shallow soils or groundwater from the other "historic chlorobenzene users" such as Borg.? No evidence was shared with the public five years ago from Dr. Neil Thompson (likely shared with Lanxess) and the repudiation of it by Allan Deal was presented with equally vague and weak evidence as far as laypersons and the public are concerned. Basically Mr. Deal proved nothing. 

On page 16 of Mr. Deal's "Chlorobenzene Source Evaluation" he discussed solubility and the 1% rule.  His written quote from the Environment Agency seemed accurate but then he verbally fudged it's interpretation by suggesting that 4,900 ug/l (ppb) was the concentration criteria suggesting DNAPL upgradient was possible. That is false as the lab solubility of chlorobenzene in water is 490,000 ug/l in pure water NOT NOT NOT in the grossly contaminated groundwater on the Uniroyal site.  The real on site solubility is referred to as the EFFECTIVE solubility exactly as the quote indicates. Mr. Deal verbally misled TRAC and the public. Feel free to alter the recording to protect the entire, long term DNAPL coverup. 

This is the third TRAC meeting and all three have been propaganda sessions. I left last night's meeting at the end of the alleged DNAPL/Chlorobenzene investigation. It's been decades of professional liars spewing junk science to generally spineless but sociable wimps. I'll catch up on the new Control Order and likely pretend, new remediation when the meeting is up on the Township's website. TRAC is also carrying on their anti-public behaviour in either denying them the right to ask questions or delaying it unnecessarily.

THE TAIL WAGGING THE DOG IN ELMIRA HAS ALWAYS BEEN THE CORPORATE POLLUTER

 The tail is Lanxess and the dog is the cleanup. This perversion tells the tale of who is really in charge in Canada. It is corporations who are above the law. Why wouldn't they be? They lobby governments for laws, rules and regulations that are corporate friendly. They make all the major decisions behind the scenes. If political parties want major corporate donations whether above or below the table then they do what they are told. Or quoting Sebastian Seibel-Achenbach and others "He who pays the piper calls the tune."

The MIckey Mouse cleanup in Elmira since 1989 has been 100% under the control of Uniroyal Chemical, Crompton & Knowles, Chemtura and now Lanxess. Lanxess have given us significant groundwater pumping reductions both on their site and off-site throughout Elmira. They have given us a pathetic, biased  Risk Assessment  (R.A.) stating that there are no unacceptable risks in the downstream Canagagigue Creek from Uniroyal/Lanxess. Well of course they aren't unacceptable to Lanxess and their fellow travellors . Stantec who did the R.A. did so accepting the data from Lanxess/GHD at face value. It was biased data throughout the length of the Creek based upon improper sampling methods (shovels v. core samplers) and inflated laboratory Method Detection Limits (MDL) above government health criteria thus eliminating valuable data and health exceedances. 

Who are Uniroyal/Lanxess's fellow travellors? First and foremost are the Ontario Ministry of Environment (MECP).  Call them a captured regulator or whatever you will the government of the day has never given them the financial backing to successfully take on corporate giants in our courtrooms.  Speaking of our courtrooms they are the playground of the rich and that too is no accident. The wealthy feel that they have a divine right to rule this country and have made certain that they and their friends are given status and respect within the judicial system which again political parties have molded to suit them and their friends needs, not yours or mine.

Further fellow travellors include municipal councils, regional councils, GRCA, and many more. All well off groups financially who have vested interests in maintaining the status quo.  All of these groups will grudgingly follow mass citizen movements but they will never lead them or help them initially. Whether modest change or revolution none of these groups want change.  Hence the inertia and lethargy by our authorities to step up and honestly address public problems, especially those that have been contributed to by our complacent governments and various authorities.  

1989 - 2024 LOTS OF TALK & STUDIES BUT SO VERY LITTLE ACTUAL CLEANUP IN ELMIRA

 

Some pits and ponds were emptied and backfilled in the 1980s BEFORE the announcement of NDMA in Elmira's drinking wells. I believe that our authorities were not at all taken by surprise but were fully cognizant that they had contaminated Elmira's drinking wells long before November 1989. In fact I fully expect that the lying sh**s knew that they had contaminated both the north wellfield (E2, E5, E8 etc.) as well as the south wellfield (E7, E9) probably no later than 1979.

On-site cleanup since the start of the Elmira Water Crisis in November 1989 has not been zero. In  late1993 a few DNAPLS were removed from TPW-2 and RPW-5 and put  into the Mausoleum or Envirodome along with the contents of RPE4 & 5. Then in 1999 the Mausoleum was emptied and the contents trucked to Corunna near Sarnia for burial in an alleged, secure hazardous waste site. Later on a few more DNAPLS were inadvertently found near RPE-3 and removed. There was also some excavations of creekbanks and part of an island in Canagagigue Creek in the early 2000s. I believe that there may have been some relatively minor further creekbank excavations on the north-west side of the Creek as well . 

The problem with both the excavations in the 1980s as well as the 1993 excavations is that only visible surface wastes were removed. Jeff Merriman, a Uniroyal Chemical engineer, bragged to UPAC & CPAC that excavations stopped when they could no longer see or smell the contamination. Not exactly a serious scientific analysis especially considering the known leakage through the bottom of the pits  (3,400 litres per day on the west side alone) according to CH2M HILL , consultants to the Region of Waterloo.

Now today in September 2024 Lanxess want us to believe that they are serious about doing remediation that could have and should have been done 25 or 35 years ago.  They will also likely claim that the remediation today is so much better than it used to be. Really?  Dr. Richard Jackson (TAG Chair) advised TAG and the public in late 2016 that there were no "magic bullets" i.e. new cleanup methods.  Perhaps some of the numerous remediation methods have been fine tuned, chemical amendments added etc. . That in itself would be great but are we going to trust the professional liars (Lanxess & the MECP) to be in charge of that cleanup after the mess they have made together for the past 35 years? Secondly will they only cleanup the off-site Elmira Aquifers or will they actually clean up as well the former Uniroyal site itself to ensure that down the road negligence doesn't re-contaminate the Elmira Aquifers?

Or perhaps Lanxess and the Ministry (MECP) just want to talk about new remediation methods for the next 35 years. Talk alone is cheaper especially if you ignore the value of the environment and the lives of human beings and wildlife.  

WOOLWICH FINALLY RESPOND (SORT OF) TO MY MULTIPLE E-MAILS TO THEM, THE REGION & THE MEDIA ABOUT CLEANUP FAILURES

 

A little over a month ago I sent about seven detailed critiques to all three groups above.  My critiques over the last couple of years have also listed two items namely decreasing groundwater pumping rates both shallow and deep and both on and off the Uniroyal/Lanxess property as well as references to chlorobenzene as free phase DNAPL found 100 feet below ground surface in monitoring well OW57-32 (R) beside the Howard St. water tower in approximately 2007. Perhaps according to this week's  (Thurs. 6 pm.) TRAC Agenda Lanxess are finally going to address those two items. The rest are still being ignored as the professional liars in town are wont to do. 

The seven detailed critiques focused on the Stroh and Martin farms to the east and slightly south of Uniroyal/Lanxess. They included items such as elevated east side pits (RPE 1-5), Interceptor Trenches, phony location of GP-1,  putting Uniroyal contaminants through the Martin swimming pond, lack of buffer zones with the two farms, the "sink" of dioxins and DDT on the Stroh farm and where it is located etc. All of these are huge issues which only first class scum and their fellow travellors would or could ignore. The fact that the downstream Creek ("Gig") is still so highly contaminated is a clear indication that toxic chemicals have never stopped leaching, flowing and migrating off the Uniroyal site and likely won't until much, much more than on-site hydraulic containment (pump & treat)  is the solution. 

One of the recipients of the three groups above is councillor Nathan Cadeau. Yes he is woefully unqualified, ignorant and full of false piss and vinegar. Nevertheless he is the Chair of TRAC and should have been passing along my critiques and more to TRAC members AND to Lanxess/MECP. Has he? I would say 50/50 whether he has or not. I don't believe that he is honest and straightforward but I KNOW that he is grossly ignorant of the Elmira Water Crisis which puts him in with most of  Woolwich citizens.

HOW DESPERATE & STUPID ARE THEY AND IS THE SUDDEN RELEASE (this Thursday) OF THE NAME OF THE SECOND SOURCE OF CHLOROBENZENE RELATED?

 I've been trying to figure why Lanxess have suddenly decided to rat out one of their former corporate colleagues here in Elmira. While Varnicolor is long gone I believe that Glenoit is the newer name for Borg Textiles. Has a deal been done or are Lanxess simply too big to worry about legal issues by naming the second source? Another reason may be that if Lanxess/MECP are going to try and bullsh*t  the public into believing that they've suddenly decided to properly remediate the Elmira Aquifers then they have to show some good faith. Good faith as in admitting who the second (or third?) source is. Doing this not only improves their credibility but it paints them in a more sympathetic light as in they've taken all the chlorobenzene blame for the last thirty-five years. Strangely (?) at the last RAC meeting Jason Rice (MECP) disagreed that there was a second source of chlorobenzene. Maybe he hasn't received the memo that it's O.K. 35 years later to tell the public that there were multiple bad pollution actors in Elmira for decades and that many of them contributed to poisoning the wellfields. Yes Uniroyal Chemical was likely the biggest and baddest (?) but Nutrite, Varnicolor and the about to be named one this Thursday at TRAC also contributed. Plus others still unnamed.

How about a second source of NDMA? I would say that that is more than just a possibility. From Varnicolor using the precurser to NDMA namely dimethylamine as a raw material in their commercial can coating process to the fact that higher than expected concentrations of NDMA were found from observation well CH38 beside Sanyo on Industrial Dr. for decades as well as further south closer to the south wellfield. Even the location of pumping well W3 and W3R give us a clue as the pumping wells were often very close to various off-site source areas. W3 /W3R is actually between Sanyo and the former McKee Harvester. Coincidence maybe . Pumping well W6A/B was a much later addition and is located at the extreme south end of the former Borg Textiles.

One thing all the guilty parties have shown themselves to be incapable of doing is being honest with Elmira/Woolwich citizens. As well they will never admit to the conspiracy between Uniroyal and the Ontario Ministry of Environment to minimize both parties negligence and incompetence in protecting our drinking water. 

CAN THE INGRAINED HABITS OF PROFESSIONAL LIARS BE OVERCOME?

 

Why not? Alcoholics can be weaned off of alcohol. Drug addicts have broken the cycle of addiction. Smokers have totally turned around their health and future by stopping in time. Human beings have an infinite capacity to change when they themselves so choose. We cannot do it for them. I have no illusions that my naming Uniroyal Chemical and corporate successors as "professional liars" has changed any of them. 

Speaking of "illusions" does anyone remember the excellent Documentary by Michael Heitman and Bonita Wagler titled "Grand Illusions".  If you don't it's because Lanxess Canada pulled the plug on it AFTER it was completed. My understanding is that the documentary was "balanced" in that the two originators had interviewed both community members as well as Chemtura employees. That said again my understanding is that Lanxess didn't like something their own employee had said on camera. My expectation would be that the employee was Jeff Merriman who led the Uniroyal etc. environmental charge for decades before retiring.

Has my condemnation of our corrupt Ministry of Environment changed their behaviour? I don't think so. They are as useless as teats on a bull with occasional exceptions from specific employees. Two days ago I posted here about whether or not Lanxess, the MECP and Woolwich Twn. seriously were interested in real remediation of the Elmira Aquifers.  Three days ago I posted a long but only partial list of lies that we the public have been told by our various "authorities" and their professional liars. 

Is professional lying an addiction? Should there be a psychiatric designation for it? Some people literally can't speak more than a few sentences without throwing in intentional lies and disinformation.  The very best politicians however have their lying under control. They can turn it on and off like a tap. Former mayor Todd Cowan had no such control and he's hardly alone. Self-aggrandizement is a part of the psychopathy of compulsive liars.  

It certainly is habit forming.  Normal citizens recognize that most politicians lie on occasion. Normal citizens would be shocked at how most politicians rely on it however as when in doubt lie your way out of it. Rarely do citizens applaud lying politicians who later apologize for their economy of truth. Hence there isn't much incentive to confess when it's just easier to repeat the original lie or make up a new one. They are generally difficult to prove one way or the other. 

Where does this all get us? Remember possibly President Reagan long ago when discussing arms agreements with Russia suggesting that the "U.S. will trust but verify.".  Well it's the same with polluters, their corrupt regulators and politicians from all levels suddenly at the last minute deciding that gosh more needs to be done to either clean up Elmira prior to the 2028 deadline or at least give the impression that that is what they want to do.  Their words and promises are wind, verification will be necessary and not verification from tame, lapdog committees appointed by the professional liars themselves.

 

DO WE CONDEMN LANXESS FOR SITTING ON THIS INFO FOR SEVEN YEARS OR DO WE PRAISE THEM FOR FINALLY COMING CLEAN ABOUT IT?

According to their Agenda for the upcoming TRAC meeting (Thurs. Sept 12/24) namely Item 5.1.4 they are going to blab about both DNAPLS (chlorobenzene) and about their Off Site Isotopic Analysis Study. Now some of this was shared with TAG and the public via Dr. Thompson (U. of Waterloo) several years ago around 2018. He claimed that there was an excess quantity of chlorobenzene, above and beyond Uniroyal Chemical's donations/dumping, in the off-site Elmira Aquifers. He also claimed that this excess chlorobenzene from a second source could be identified allegedly by isotopic analysis. It was obvious to me that there were but two very likely sources across the road from each other (Howard Ave.) who could be responsible, both of whom I have identified for years here in this Blog (Borg Textiles & Varnicolor Chemical).   

Now if it is Varnicolor there is going to be hell to pay as their groundwater allegedly showed NO chlorobenzene present via Ministry lab testing.  That would indicate gross corruption by the Ministry and while they avoided an Inquiry thirty some years ago this would be too much. It would be clear evidence of intentional government corruption. Now with both companies long gone from Elmira maybe some backroom deals have been done. One thing is for sure namely that both companies  either had a dye shop (for textiles) or paint and solvents as the major source of their business (Varnicolor).  Could both companies be responsible for the excess chlorobenzene?

Agenda Item 5.1.2.3 is titled "Investigating Well Extraction Pumping Rates". Now this again is interesting in that I've been sending e-mails to both Woolwich Council and TAG/TRAC for at least the last couple of years about this. Now do keep in mind that we the public are dealing with professional liars here  in Elmira. Maybe they are going to come clean and maybe they aren't. It could go either way just as their fatally flawed HHERA  (Human Health & Ecological Risk Assessment) claims that there are "no unacceptable risks" in the downstream Canagagigue Creek from Uniroyal's still present DDT, dioxins, lindane, PAHs, parathion etc.

I'll wait and see how clean the company comes AND if they want to share with the public why the public consultation body never felt the need to speak out publicly on these matters. Was TAG/TRAC kept in the dark or were they asked nicely as friends of Lanxess/MECP to keep their traps shut on these and other public matters. Either way is damning of all parties.

ARE LANXESS CANADA SINCERELY CONSIDERING ACTUALLY PRPOERLY REMEDIATING THE ELMIRA AQUIFERS?

 

Now come on! Quit laughing and quivering with mirth. Just because they and their corporate predecessors along with their regulator (MECP) have spent the last 35 years lying to the public about the Elmira Water Crisis is no reason to be skeptical. Maybe they're experiencing a Come To Jesus moment. Maybe they're on drugs. Hell maybe they've actually grown a conscience or something else bizarre has happened. Who knows?

Now of course there is still the problem of AFTER the Elmira Aquifers are clean to drinking water standards they are still directly connected to the upstream mess called Uniroyal/Lanxess Canada. Sure, sure there has been on-site hydraulic pump & treat since 1992 of the Municipal Aquifers and  since 1997 of the shallow Upper Aquifer. One of the serious problems is that while still lying  about it they have reduced their on-site pumping dramatically thus allowing off-site leakage despite their denials.  Imagine the day after Lanxess either goes belly up or retreats to the U.S. or Germany. Who's going to pay for the electricity to keep the pumps going? Who's going to maintain the motors, pumps and treatment facilities? The Elmira Aquifers will unfortunately end up right back where they were in the 70s, 80s and 90s.

Promises from the company are nothing but wind. Do the cleanup of both the aquifers and the Creek properly and then come talk to me.  After 35 years of irresponsible lying and deceit we the public do not owe you one inch of leeway or confidence.  

STORIES (LIES) MY FAVOURITE POLLUTER HAS TOLD ME

 

Impermeable clay aquitards

10% Solubility Rule

Tripling the amount of Off-Site pumping

30 years to remediate the Elmira Aquifers

Polluter Pays

independent public consultation

Uniroyal was the only source of contamination

"NDMA is not in our vocabulary"

nothing flowed eastwards from Uniroyal onto the Stroh property

nothing flowed southwards onto the Martin property

hydraulic containment in ALL aquifers

using shovels instead of core samplers is O.K.

there are no free phase DNAPLS on the Uniroyal site

there are no free phase DNAPLS off the Uniroyal site

all surface drainage on the east side went into GP1 & 2

there are no unacceptable risks downstream in the Canagagigue

risk assessments will be done properly and honestly

chemical odours are not necessarily health issues

professional consultants have a code of ethics or responsibility towards the public interest

The above took me about ten minutes to think of and write down. Over 35 years there have been lots of other truth efficiencies and economical truths. 

RAC & TAG + LIPSTICK = TRAC (TOTALLY ROTTEN & CORRUPT)

 

Hmm ! Is it hypocritical after a title like the one above to suggest that there are some decent human beings on TRAC? First of all I truly expect that there are some decent human beings on TRAC (a matter of percentages) albeit I would suggest that they aren't very smart. Educated yes, smart no. Most of the smart ones have abandoned that particular ship and TAG a along time ago. Even the Region of Waterloo had walked away for a while from UPAC, CPAC etc. when they had had enough. They did it low key but they gave warning that it was coming as it did.

Perhaps "Totally Rotten and Corrupt" could be replaced with a gentler moniker. How about "Too Reasonable About Corruption"?  Maybe better would be "Too Relaxed About Corruption". Ahh a rose by any other name would smell as sweet or in my jargon  ...corruption by any other name is just as putrid.

TRAC just like RAC & TAG was introduced by Sandy Shantz  both to mollify Chemtura/MECP as well as to deceive the public.  None of them were ever intended to actually promote proper remediation of the Elmira Aquifers, the Canagagigue Creek or heaven forbid the cesspool beneath the former Uniroyal Chemical.  They were intended to give the appearance of honest publlc consultation which they aren't and to give some credibility to the Ministry (MECP) and Lanxess's worse than Mickey Mouse pump & treat alleged remediation.

Remediation which can not help to fail (as they agree) although their excuses and blame runs the gamut from legitimate and accurate public criticism to "asymptotic behaviour" as well as "back diffusion".  The company (Uniroyal, Crompton, Chemtura & Lanxess) have been in full control of the cleanup since 1989 with only token criticism from the Ministry of Environment (MOE/MECP). Despite full control including mostly refusing Source Removal they have not cleaned up (or even close) the Elmira Aquifers nor have they removed even a shovel full of the downstream DDT and dioxins they are responsible for. Polluter Pays is nothing but a Ministry slogan. not a reality.