07/11/2025
To: Mr. Phil Ouellette
Subject: Omission of Critical Information in the Crane Mountain Height Augmentation Deliberations
Dear Mr. Ouellette,
I am writing regarding an issue of substantive concern arising from the discussions surrounding the Crane Mountain Height Augmentation Environmental Impact Assessment (EIA).
In your complaint of November 8, 2024, you cited my statement made during the open agenda item on the staff recommendation for the business case for the height augmentation, in which I noted that:
“There is no question that this leachate will leak. Maybe not this year, maybe not next year, but it will leak, and it will contaminate over a thousand wells downstream.”
You described this statement as “falling outside of those provided to the FRSC Board of Directors through FRSC professional employees as well as the third-party consultant hired to advise the FRSC on the height augmentation,” and that it was “not aligned with the guidance the FRSC Board of Directors received from FRSC professional staff or the third-party consultant firm.”
My concern is not the existence of your complaint, but the reason the information I referenced — that all landfill liners eventually leak — was never presented to the FRSC Board by professional staff or consultants.
This principle is not a speculative opinion; it is well documented and widely accepted by leading authorities. The United States Environmental Protection Agency (EPA) has publicly stated that all landfill liners are expected to fail over time. This position has been reaffirmed in numerous technical publications. I also provided you with a report citing that reference.
At the same meeting, the Crane Mountain Enhancement Inc. (CMEI) group presented similar information, quoting directly from Professor R. Kerry Rowe, BSc, BE, PhD, DEng, DSc(hc), FRS, NAE, FREng, FRSC, FCAE, Dist.M.ASCE, FEIC, FIE(Aust), FCSCE, P.Eng., CP.Eng., a recognized global authority in landfill engineering, who has repeatedly concluded that all liners leak.
All FRSC Directors, CMEI engineers, and FRSC’s own engineers and staff were present for that discussion. At no time did any FRSC professional engineer or consultant challenge or correct that statement.
I subsequently asked that FRSC professional engineers be consulted to confirm whether they agree with this well-established fact. To date, I have received no response.
Given the significance of this issue to public health and environmental protection, I respectfully request clarification on the following points:
Why was the established scientific consensus that all landfill liners eventually leak not presented to the FRSC Board of Directors by FRSC professional staff or by the third-party consultants advising the Board?
On what basis was this information deemed to “fall outside” the scope of the materials provided to the Board?
Do FRSC’s professional engineers and consultants agree or disagree with the position of the USEPA and Professor Rowe?
If they disagree, what evidence or analysis supports their position and why was that not presented to the directors??
Who is responsible for ensuring that the FRSC Board is provided with all relevant and material information necessary for informed and responsible decision-making?
This omission goes to the heart of the Board’s ability to make evidence-based decisions and to maintain public trust in the environmental management of the Crane Mountain facility. It is essential that the Board receive a complete and transparent account of all relevant information, particularly where the consequences of omission have potential implications for public health and the environment.
It is also of great importance that directors are free to express statements of fact in board meetings or opinions based on factual research . That these facts are not aligned to your vision or that fall outside of information provided to you is no reason to disregard their importance and resort to a complaint procedure to suppress or stifle the freedom to pass on that information.
I would appreciate a formal written response to these questions at your earliest opportunity
Respectfully
Ray Riddell
