SPECIFIC COMMENTS & RESPONSES FROM TAG AND STANTEC

 As suggested yesterday I will include some of the statements made by TAG and Stantec regarding the Draft Risk Assessment (Ecological & Human Health) for the Canagagigue Creek. These comments are not all encompassing as there are other issues affecting the credibility of this Risk Assessment including very high Method Detection Limits, locational biases, improper sediment sampling procedures (shovel vs. core samplers) etc.                                                                                                                                     .........................................................................                                                                                             "For example, at Station 21 in Reach 3, near the first bridge at New Jerusalem Rd. and near 3 farmhouses, one sediment sample (21BS1) had concentrations of total TEQ for dioxins as 868 and 1090 pg/g. The ISQG standard is.85 pg/g.  The sediment exceedance of the larger number is over 1000 times the standard. As there are only a few additional locations like this one, TAG requests that the hotspots be included in the targeted remediation for reasons outlined in more detail below. "                                   ..............................................................................................                                                                         Stantec's response on behalf of Lanxess is "While targeted remediation could remove these "hotspots" from the Creek, possible detrimental consequences to the aquatic floral and faunal communities within the area could also occur as a result". I view this response as weak and simply cost saving.                       ...................................................................................................                                                                   TAG states "...the assumption that land use will not change in the next 25 to 50 years is doubtful. Waterloo Region is one of the fastest growing and changing places in Canada. It is reasonable to assume that land uses will change from agricultural along portions of the creek. The pressure for increased recreational human activity along the creeks such as parks, trails. fishing etc. has the potential to increase human contact to these persistent toxins before the persistent toxins including DDT and dioxins have broken down."                                                                                                                           ................................................................                                                                                                       Stantec's response "Even if surrounding land use changed from agricultural to, for example, residential, the human receptors used in the HHRA and ecological receptors used in the ERA and exposure parameters would remain the same. Additional text will be added to the revised HHERA accordingly to address this comment." Well I fail to see how additional text in a Risk Assessment document either changes or fixes anything. I view this response as barely even lip service.                                                   ....................................................................................                                                                                    TAG writes "Furthermore, flooding is identified as one of the biggest climate challenge impacts in the Region going forward." "Any washout of the hotspots will end up in the Grand River, a source of drinking water for many."                                                                                                                               ..................................................................                                                                                                     Clearly TAG are again suggesting that more remediation (removal) of hotspots are required. Instead Stantec suggests "We agree that flooding could remove surface layers of soil and sediment, thereby bringing chemicals to the surface that were previously found at depth. That is why in the HHERA, all of the data, regardless of depth, were used in the characterization of risk. Therefore, should flooding events cause movement of soil and sediment, it is unlikely that the results of the HHERA would change since deeper samples were already included in the overall evaluation of risk. "   Good Lord are Stantec so hung up on the goodness and quality of their document (Risk Assessment) that they are intentionally deflecting the argument of deeper toxins being mobilized and spread further downriver? TAG's comments were for greater cleanup not to fix some stupid, riddled with assumptions, document allegedly providing insight when in reality it is simply greenwashing and reducing Lanxess's cleanup costs on the back of local residents and others.                                                                                 .............................................................................                                                                                         This is but a sample of this June 6/22 document sent to TAG Chair Tiffany Svensson by Stantec on behalf of their client, Lanxess Canada. This is how Qualified Persons (QP), intellectual prostitutes and others sell their services to well heeled clients. Truth is the first casualty of war and they are at war with both human health and the environment.  

TAG STRONGLY CRITICIZE STANTEC/LANXESS DRAFT RISK ASSESSMENT

 Stantec have included many of TAG's (Technical Advisory Group) comments in their June 6/22 responses to TAG's written comments sent to the Remediation Advisory Committee (RAC). Now do keep in mind that RAC are a fundamentally flawed body in a position of gross conflict of interest. First of all most of them don't have a clue technically. Secondly this group of bureaucrats, agencies and politicians are fundamentally just a bunch of appointees from regional council and Woolwich Council. They are not remotely independent either individually or as a group. If they were they would never have been appointed to  the GRCA or any other environmental or watchdog group by our elected politicians who jealously guard their turf. The last thing an elected official will ever do is appoint honest and independent persons to positions giving their appointees a platform unless the politicians are fully confident that their appointees will toe the line.                                                                                                                                                 ................................................................                                                                                                           I am pleased that much of the critical (of the Draft Risk Assessment) discussion at TAG appears to have actually made it into written comments and been presented to RAC. That is worthy of praise for Tiffany Svensson (TAG Chair)  who has appropriately not received much of that from me in the last two or three years. That said for me the proof is in the pudding. Will most TAG members rest on their laurels and be satisfied with simply verbal and written objections to what I view as an inherently flawed process (Risk Assessment) that is totally under the control of the polluter and his bought and paid for help (consultants and other fellow travellors maybe including some politicians )?                                                                    .......................................................................................                                                                                    I may elaborate on specific TAG and Stantec comments & responses tomorrow.   

ARE WOOLWICH TWN. PLANNING YET ANOTHER FAST ONE?

 Tonite's Woolwich Council meeting discusses various and assorted land use changes in and around Breslau, St. Jacobs and Elmira. There is some confusion for me regarding a couple of Figures namely pgs. 39 (Land Options: Elmira) and pg. 45 (Proposed Community and Employment Lands: Elmira). These figures and text can be found on the Township's website under Council Meetings/Agenda.                          .................................................................................................                                                                          Page 35 also is a Table showing various numbers on the left corresponding to locations on page 39.  Number 16 is in the south-east corner of Elmira and number 17 is the Stroh and Martin farms. Is the map on page 39 however showing an additional expansion of the countryside line to include ALL of the Stroh farm or not? Is this some surreptitious expansion or not?                                                                                ...............................................................                                                                                                            This is relevant as both the Stroh and Martin farm are proven to be contaminated (DDT, dioxins) and likely more by sediment samples provided by GHD and two soil samples provided by me DESPITE Lanxess and GHD nonsense, silliness and outright bull manure. The truth has never been anything more than a suggestion from which they can manipulate their own conclusions and "facts".  

CONGRATULATIONS TO ANGIE RIVERS & A FEW OF HER FEMALE COLLEAGUES

 News Flash:  1) Waterloo Regional Police Force male members:  the powers to be most likely did not decades ago introduce female police officers for either your sexual gratification or for your sexual fantasies                                                                                                                                                              .................................................                                                                                                                          2)  There are both publicly accepted rules and norms of behaviour AS WELL AS laws clearly defining various forms of harassment including sexual harassment.                                                                              ...........................................................................................................                                                                3) Neither Police Forces nor other employers are exempt from those laws and rules even when the majority of employees are male and some of them are fundamentally stupid.                                                  ................................................................................................................                                                            Officer Angie Rivers is being congratulated for her persistence, insistence and determination to insist upon her right and others to work in an already difficult and sometimes unsafe environment without fear of discrimination, harassment and or assault by her own colleagues and co-workers. Today's Waterloo Region Record carries a story written by Terry Pender titled "Sergeant docked 39 hours' pay for harassment".  The now seven year process of getting justice and fair treatment by the Waterloo Region Police Force continues on with an arbitration hearing currently underway. The entire lengthy, disjointed and cumbersome process has included Police Service investigations, Notices of Discipline, court proceedings for an attempted class action lawsuit as well as the current ongoing grievance procedure arbitration hearing.                                                                                                                                                              ..........................................                                                                                                                                  Based upon my own life experiences it is clear to me that the description of the entire police internal investigation and discipline process indicates it has been long perverted by privilege, bias, discrimination and ignorance. No honest investigation of  behaviours and facts within an organization needs to take seven years and counting. The entire purpose of dragging something like this out is to both discourage and defeat the complainant as well as to discourage other complainants from coming forward. It is essentially step one in the playbook for self-serving, dishonest and untruthful employers. Whether Angie Rivers wins or loses her arbitration case she has exposed Chief Larkin, senior police administrators, the Police Services Board and quite frankly Waterloo Regional Council (barely at arms length away) as being complicit cowards unwilling and unable to do the obvious right thing for fear of offending those in the wrong. Shame on the pack of them. Will every citizen in Waterloo Region commend her? No only those who are honest, thoughtful and pay close attention to both current events and to life around them.                  

MORE LOCAL OPPOSITION TO PROPOSED TRUCK & TRAILER PARKING LOT ON TOP OF BOLENDER PARK LANDFILL

 Today's Woolwich Observer carries a Letter To The Editor from Dr. Dan Holt regarding the strange development proposal by 39A Holdings for a tractor and trailer parking lot to be built on the immediate north side of Bolender Park and the Splash Pad. Mr. Holt lists ten serious issues that will result if the development proceeds all of which I agree with. They range from increased truck traffic in the downtown, increased diesel fumes and noise, removal of over 300 trees to potential worsening of methane gas issues on the property.                                                                                                                                                  ..........................................................................                                                                                                  None of the ten problems to be are minor and several are problems already from truck traffic that only will be worsened. Mr. Holt's comments about volunteers planting trees along the Kissing Bridge Trail beside the northern edge of this proposed development as well as about a recent urban design survey are both right on the mark. Why would we as citizens and residents of Elmira want to to encourage  activities that harm our environment and quality of life? There are better locations for these trucks and trailers than downtown Elmira.  

DOW & OTHERS: BETTER PROFITS WITH CHEMISTRY

Today's K-W Record carries the following story  titled "Pressure growing to remove PFAS from fast-food wrappers". What is PFAS you say? From memory I believe that it stands for Poly Fluoral Alkyl Substances although I'm not 100% certain. In a nutshell these are a type of water proofing material containing fluorine. I believe that Scotchguard might be one of the brand names. These substances can be used on clothing, food wrappers and dozens of other consumer goods.                                                           ................................................................................                                                                                           In the U.S. a movie was made about a lawyer who took on Dow Chemical and their dumping of PFAS substances in a landfill which horribly damaged a local farmers' cattle. Possibly the actor in the movie's lead role was Mark Ruffalo. There has not been nearly enough media about these toxic substances which can also enter water supplies and have done so. According to the newspaper article the EPA have set a VOLUNTARY health advisory level of 70 parts per trillion (ppt) for two PFAS chemicals in drinking water. Wow that sure seems like an inadequate response to these toxic chemicals. 

TAG PAST & FUTURE

 O.K. the "future" TAG is merely referencing the next upcoming meeting which is Thursday June 23 most likely at 6 pm. Unfortunately it too will be virtual unless changed within the next couple of weeks. My recollection from the last meeting was that no date was set for any upcoming RAC meetings.                      ......................................................................................                                                                                      The last TAG meeting was May 12/22 and one point of discussion was in regards to whether or not the Draft Risk Assessment (RA) to date is including the Stroh Drain. The concensus seemed to be that indeed it did. I've reread part of  the latest Draft RA and while obviously the Creek from Lanxess to the Grand River is part and parcel, the various sampled tributaries are less clear. Fortunately the Stroh Drain which they refer to as 6770 Line #86 is clearly included. The tributaries (Larch's, Shirt Factory Creek, Bolender Creek & Landfill Creek) which were all sampled  for soils and sediment contamination by DDT and dioxins are however all mentioned in the Draft Risk Assessment.                                                                    ........................................................................                                                                                                    I am a little concerned for the Uniroyal toxic contaminants on the Martin farm however. That farm is immediately south of the Stroh farm and includes the southern half of the Stroh Drain and it's discharge into the Canagagigiue Creek. While the Stroh Drain is included it is referred to as the drainage area at 6770 Line #86 which might be interpreted by a self-serving, ethically challenged owner of polluted land as suddenly stopping at the Martin property line which of course it does not do. Also keep in mind that the sediment samples from the Stroh Drain, Ditch & Berm (SDDB) were both taken on the Stroh property AND on the Martin property. In fact the dioxin concentration in sediments taken on the Martin property was 30 times  higher than the federal sediment criteria for dioxins: i.e. 24.4  ppt TEQ versus .85 ppt TEQ.  ..............................................................................................                                                                              Rest assured however that might is right here in Woolwich Township (Elmira) and polluters and their friends are experts at interpreting data to their financial advantage and nobody officially appointed to be their watchdogs are going to do anything serious about it.