PFAS Contamination Risks at Base31: Long-Term Implications for Residents and Municipal Liability

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Disclaimer: This post is based on public information. It does not claim PFAS contamination exists at Base31 — only that no test results have been disclosed to the public.

Summary

Base31 is moving ahead as a major redevelopment project, but one critical question remains unanswered: has the site ever been tested for PFAS (“forever chemicals”)?

PFAS were widely used at military bases and airports through firefighting foams, and they are now linked to serious long-term health risks. Yet, despite extensive environmental studies on petroleum hydrocarbons and lead, no PFAS testing report has been made public for Base31.

This doesn’t mean PFAS are present — but it does mean residents have no assurance either way. Transparency matters. The Developer, MECP, and County should release a clear public statement confirming whether PFAS sampling has been done and, if not, commit to independent testing before more approvals move forward.

Important to note: According to reliable sources, wells around Trenton/Mountain View Airport (TC LID: CPZ3) are currently tested every month for PFAS.

Introduction

Base31, the redevelopment of the former Camp Picton air base in Prince Edward County, is slated for thousands of new homes and mixed-use community growth. While petroleum hydrocarbons and lead contamination have been documented and partly remediated, one glaring omission stands out: no PFAS testing report is publically available.

This post is based on publicly available information. It does not claim that PFAS contamination is present at Base 31, only that no public testing results have been disclosed to date.

Per- and polyfluoroalkyl substances (PFAS), commonly known as “forever chemicals,” were widely used in firefighting foams (AFFF) at military bases and airports from the 1950s onward. Given Base31’s history as a military airfield with fire training and aircraft fueling operations, the likelihood of PFAS contamination in soil and groundwater is significant, however not certain.

It appears that testing for PFAS is voluntary which in itself is of concern. In other words, if there is no public outcry or push from the council to have this testing done, it probably won’t be done. A public statement confirming that PFAS are NOT present at Base 31 should be released by the Developer, MECP and County to reassure residents.

No credible evidence in public records confirms that PFAS (per- and polyfluoroalkyl substances) have been tested or reported at Base31 / Camp Picton. None of the disclosed Environmental Site Assessments, remediation reports, or planning documents appear to reference PFAS sampling or results, nor do they explicitly guarantee that PFAS are not present. An extensive search of municipal websites, environmental databases, regulatory filings, and public studies found no indication of PFAS testing having been conducted or published. However, the possibility of undisclosed or private investigations cannot be ruled out.

Source: https://newsinteractives.cbc.ca/features/2025/pfas-canada-map/

What the Public Record Does Show

Soil and groundwater contamination investigations at Base31 have focused on petroleum hydrocarbons (PHCs), BTEX, PAHs, and lead in soil (e.g. from a former firing range, and a 2024 lead patch near Building 3)¹.
The public lead-soil incident near the Sensory Garden is documented; it was traced to deteriorating lead paint on Building 3, not PFAS².
Planning materials for Base31’s redevelopment (e.g. OPA-04-23) list many supporting technical reports (heritage, servicing, traffic, natural heritage, archaeological) but do not include an environmental report explicitly addressing PFAS³.
To the best of knowledge, no public notice, media article, MOE/MECP files, or consultant reports found name PFAS sampling or testing at the Base31 site.

What the Search Turned Up

The official OPA-04-23 Base31 planning pages list a wide array of technical studies submitted (e.g. servicing plans, natural heritage, traffic, heritage) but no environmental report explicitly referencing PFAS sampling or results. Prince Edward County Municipal Services
The public comment file on ERO (Ontario’s environmental registry) contains a CSV of comments; one of the comments mentions PFAS as a concern (“PFAS being present … both Airports and Military bases have shown individually to contain PFAS”), but that is a concern raised by a commenter, not reference to a validated test result. Environmental Registry of Ontario
More broadly, national and provincial PFAS reports (e.g. Canada’s “State of PFAS” draft) discuss PFAS sources, behavior, and general monitoring across Canada—but do not mention Base31 or its redevelopment specifically. Government of Canada
Ontario’s drinking water reports discuss PFAS guidelines and background presence, but again no indication of Base31 being tested. Ontario
A notable map from CELA (Canadian Environmental Law Association) shows known or suspected PFAS contamination sites at military bases and airports across Canada—Base31 is not explicitly listed on that map. Canadian Environmental Law Association

Contamination at Base31_ Historical Use and Evidence – A report Download

Failure to address this risk poses potential long-term health impacts for residents and substantial liability exposure for both the Municipality of Prince Edward County and the Ontario Ministry of the Environment, Conservation and Parks (MECP).

Why PFAS Matter

Persistence: PFAS do not break down in the environment; once present, they accumulate in soil and water for decades or longer.
Mobility: PFAS readily migrate through groundwater, meaning a small release at a fire-training pad can impact aquifers far beyond the immediate site.
Bioaccumulation: PFAS build up in human and animal tissues, leading to long-term exposure even at low concentrations.
Health Risks: Studies link PFAS exposure to thyroid disease, immune system suppression, liver damage, developmental effects in children, and increased risk of cancers (e.g., kidney and testicular).
Regulatory Thresholds: Health Canada’s new (2024) drinking water objective is 30 ng/L for the sum of 25 PFAS compounds. Some U.S. states have set even stricter standards.

Likely Exposure Pathways at Base31

Groundwater Contamination – If PFAS are present in aquifers beneath Base31, there is potential for plume migration beyond the property. While new homes are expected to use municipal water, surrounding rural properties on private wells could be impacted.
Soil and Dust Contact – PFAS residues in soils, especially near old fire-training areas, can be disturbed during construction, generating dust inhaled or ingested by workers and residents.
Surface Water Runoff – Stormwater management ponds could become PFAS reservoirs if construction mobilizes contaminated soils, leading to ecological exposure downstream.
Long-Term Unknowns – PFAS contamination can remain undetected for decades, only surfacing once residents experience unexplained health issues or wells test above guidelines.

Why MECP and Council Should Be Concerned

Regulatory Oversight: MECP has a duty to ensure redevelopment of contaminated sites meets environmental standards before land-use changes to residential. Allowing approvals without PFAS testing undermines the credibility of Ontario’s brownfield remediation system.
Liability for Residents: If PFAS are later detected above safe thresholds, homeowners could face health risks and diminished property values. Without upfront disclosure and testing, lawsuits against the developer, County, and Province are almost inevitable.
Financial Costs: PFAS remediation is extremely costly. Pump-and-treat systems with granular activated carbon or ion-exchange resins can cost millions annually. Municipalities that inherit contaminated lands (through public infrastructure, storm ponds, or water systems) face massive financial exposure.
Precedent Cases: Communities near former military bases in the U.S. and Canada have already faced multi-million-dollar lawsuits and health claims linked to PFAS. The County risks being added to this list if it proceeds without due diligence.

Recommended Actions Before Approval

Comprehensive PFAS Testing
- Conduct Phase II Environmental Site Assessment focused on PFAS at all potential source areas (firefighting training zones, fuel storage, hangars, drainage).
- Analyze groundwater, soil, and surface water samples against Health Canada’s new objective.

Independent Oversight
- Require testing to be carried out or peer-reviewed by an independent third-party environmental consultant, not solely the developer’s team.
Public Transparency
- Results must be disclosed to the public in plain language, with clear maps showing any areas of concern and migration risks.
Risk Assessment and Remediation Plan
- If PFAS are detected, MECP must mandate a site-specific risk assessment and remediation plan before residential construction proceeds.
- Institutional controls (e.g., no groundwater use) must be formally registered on title.
Liability Clarity
- The County should require legal agreements that place the responsibility for PFAS discovery, remediation, and costs squarely on the developer.
- MECP should confirm that if contamination is found later, the Province—not municipal taxpayers—will fund remediation.

Conclusion

Redeveloping Base31 without PFAS testing is an invitation to long-term environmental, health, and financial disaster. The science is clear: military airfields are high-risk PFAS sites. The regulatory framework is clear: redevelopment requires comprehensive environmental assessment. The risks of liability are undeniable: residents’ health, property values, and municipal finances are all at stake. For Prince Edward County Council and MECP, the path forward is simple: pause approvals until independent PFAS testing and review are completed. Anything less is negligence that could haunt this community for generations.

Disclaimer and Legal Waiver

This report has been prepared for informational and advocacy purposes only. It summarizes publicly available information, general scientific knowledge, and reasonable concerns related to potential PFAS (per- and polyfluoroalkyl substances) contamination at Base31 in Prince Edward County. The authors are not providing legal, environmental engineering, or health advice. Readers should not rely solely on this report for decision-making. Instead, they should seek independent professional advice from qualified environmental consultants, legal counsel, and public health authorities before taking any action or making investment or policy decisions. While every effort has been made to ensure the accuracy of the information presented, the authors make no representation or warranty, express or implied, regarding the completeness, accuracy, reliability, or suitability of the information contained in this report. The information is subject to change as new studies, data, or regulatory standards become available. By reviewing this report, the reader agrees that the authors, contributors, and publishers shall not be liable for any direct, indirect, incidental, or consequential damages arising from the use of, or reliance upon, the information contained herein. Any references to environmental or health risks are general in nature and do not constitute a site-specific risk assessment. Only a licensed environmental professional can determine site conditions through recognized investigative procedures. The opinions expressed are those of the authors in the context of civic dialogue. Readers are encouraged to consult the Ministry of the Environment, Conservation and Parks (MECP), the Municipality of Prince Edward County, and qualified experts for authoritative information and regulatory guidance.

(1) https://pictongazette.ca/post/elevated-lead-levels-found-in-soil-sample-at-base31 (2) https://pictongazette.ca/post/elevated-lead-levels-found-in-soil-sample-at-base31 (3) https://www.thecounty.ca/opa-04-23-base-31/