(Updated April 23rd 2014)
The Capital Regional District plans to construct land based sewage treatment plants to serve the core area municipalities (Victoria, Oak Bay, Esquimalt, Saanich, Langford, View Royal and Colwood). The decision to go ahead with the plan is supported by the political decisions of three levels of government – Municipal, Provincial and Federal. The credible judgement of Marine Scientists, Public Health officials and Engineers that the present discharge of the screened effluent into a unique marine receiving environment, through two deep sea outfalls, is highly effective in treating the effluent, have largely been ignored. See:
LIQUID WASTE MANAGEMENT PLAN
The CRD has a Liquid Waste Management plan (Amendment 8) approved by the BC Minister of Environment. This plan involves a treatment plant at McLouglin Point, an 18 kilometer double pipe to and from the Hartland land fill, a sludge treatment plant at the land fill and then as yet to be determined disposal of the sludge. The McLoughlin point plant will provide secondary treatment for 2x Average Dry Water Flow and primary treatment for up to 4x ADWF. This treatment plant increases the solids in the sewage from 0.1% to 2-3%. This means that the sewage is still 97% water which has to be disposed of through a new outfall planned to be at McLoughlin point after removal of the solids (sludge). There will be an additional 4 KM of pipeline from Clover Point to McLoughlin Point. An Amendment 9 of the LWMP was approved by the CRD Board and submitted to the Provincial Minister of Environment for approval in January 2014.
VIEWFIELD ROAD LAND PURCHASE
On March 20th 2013 the CRD announced that it had bought a parcel of land on Viewfield Road in Esquimalt as the potential location for a new sludge treatment plant. The CRD announced it had entered into an agreement to buy 1.7 hectares of land, in two parcels, for $17 million. The land is currently the site of Wilson Foods, next to the popular Wholesale Club warehouse, and backs onto the E&N rail line and a B.C. Hydro substation in an industrial part of the township.
On July 3rd 2013 the CRD Board decided to abandon the idea of a sludge treatment plant on Viewfield Road in Esquimalt. However there is still an agreement to purchase the land with a closing date of September 2014.
UNCERTAINTIES IN PRESENT PLAN
There were uncertainties in the approved plan (Ammendment 8) which staff informed the CRD’s core area liquid waste management committee (CALWMC) would need to be revised. Changes were included in Ammendment 9 that was submitted to the provincial Minister of the Environment in January 2014. The public has been informed that there will be Federal and Provincial contributions to the plan. There is a legal agreement in place for the Provincial Contribution (1/3 of Capital Costs on substantial completion of the project) but there is presently no legal agreement for the Federal cost sharing of 1/3 of the capital costs of the project.
It is expected that the current cost estimate of the plan of $783 Million capital costs and on going $14.5 Million operating costs, which were “Class C” estimates (which means +/- 25%) will be exceeded as is the norm for mega projects of this type. There was an assumption that there would be $5 Million in resource recovery revenue in the annual operating costs. This was hypothetical.
On March 27th 2013 the CRD Board gave second reading to a loan authorisation by-law (#3887) for the borrowing of $100 Million to cover approved budgeted costs for the immediate future. On April 10th 2013 the CRD had another by-law (#3888) that would enable temporary borrowing of the $100 Million since the Municipal Finance Authority funding was not available until the fall of 2013. Both Bylaw #3888 and #3887 were approved by the Board on April 10th 2013.
The CRD will incur an estimated $11.7 Million in temporary borrowing costs before the project is completed.
Until 2018 there will be an estimated $35 Million in operating and debt servicing costs. After this the operating costs are estimated at $14.5 Million per year.
Interest rates paid have been calculated at 1.75% for temporary borrowing and 5% for long term borrowing. The interest rate for the Private Public Partnerships part of the project - the sludge treatment facility and dual pipage from McLoughlin Point (It is also being called a Biosolids center or the “Energy Center”) will be higher because of the private financing.
The CRD has resolved to assess the local taxpayer, by requisition to the member municipalities, an extra $5 Million a year ahead of incurring all the costs on completion of the project. As was stated in a staff report “An orderly annual predictable increase will reduce the shock of this increased expenditure”. Without this measure there would be a significant increase incurred by the municipal taxpayers in 2018 but by doing this the CRD will be incurring the additional $11.7 Million in borrowing costs.
In the year 2013 the project management team and the Commission planned to spend $47,376,000. The CRD approved $23,376,000 in additional funding to be spent in 2013.
PROJECT OFFICE AND COMMISSION
The Project team has established an office at 510-1675 Douglas Street.
In 2013 the CRD formed the Core Area Wastewater Treatment Program Commission (CAWTPC) to manage the project. The budget for the compensation of Commission members was approved at $282,000 per year. (This includes a $750 per diem for members to attend meetings).
COMMISSION HIRED A NEW PROJECT DIRECTOR
On July 31st 3013 the Comission chairperson Brenda Eaton announced the hiring of Albert Sweetnam as the sewage treatment program Director on a five year contract with a salary of $290,000 per year plus benefits. The contract includes a bonus of $290,000 if the project director is able to ensure the completion of the project by 2018. He took over responsibilities from Jack Hull, the interim project director, on September 9th 2013. Mr Sweetnam is a civil engineer with experience in large mining and nuclear projects.
COMMISSION RENAMES PROJECT
On October 7th 2013 the Commission created a brand and renamed the project the Seaterra project.
An agreement has been drafted for the purchase of McLouglin Point for the treatment plant at that site. (Details of this purchase plan have not yet been made public.)
On July 12th 2013 the CRD Core Area Wastewater Treatment Program Commission released the request for proposals to design and construct the McLoughlin Point Wastewater Treatment Plant Project. Three companies Capital Clear; Harbour Resource Partners; and PCL Partnerships were invited to prepare and submit innovative, competitive proposals to design, construct, commission and partially finance the McLoughlin Point Wastewater Treatment Facility ; the Harbour Crossing Site and the Outfall and to provide Performance Management Services during a two year Performance Period.
Amazingly it was also stated that upon execution of the Project Agreement, the CRD will pay $250,000 inclusive of any taxes payable including GST to each unsuccessful proponent.
The McLoughlin Point required rezoning by the Municipality of Esqimalt. This rezoning hearing took place onn April 7th 2014 after a delay caused by public hearings that required more time than expected due to the number of speakers, almost all opposing the rezoning of the site.
The Municipality of Esquimalt Councillors unanimously rejected the rezoning request by the CRD on April 7th 2014. Councillors also supported a motion that would remove the possible designated use of the McLoughlin Point site for a sewage treatment plant in the future.
Prior to the rezoning hearing there was a proposed agreement submitted to the Municipality by the CRD for ameneties to be provided to Esquimalt and modification to the site to minimise the impact on the community. This agreement was subject to Esquimalt rezoning the site as requested by the CRD.
The Province of BC does have the authority to rezone the site without Municipal approval but to date has declined to exercise that power.
At the CRD’s Core Area Liquid Waste Management committee meeting on Wednesday 9th April, CRD directors voted to ask the provincial cabinet to intervene: either force through McLoughlin Point rezoning or provide other options.
Provincial intervention could prove more complex than anticipated. In response to a question from Oak Bay-Gordon Head MLA Andrew Weaver in the legislature, Environment Minister Mary Polak said the province has no plans to wade into the sewage debate.
"We've said from the beginning that this is an issue that the local governments need to grapple with, understanding that they're the ones who are obligated to begin treatment of their sewage. We have no plans to intervene," Polak said.
NEW OUTFALL AT McLOUGHLIN POINT
A study of the marine environment around the proposed new outfall at McLoughlin point has been completed. A report on the assessment was discussed on 11th of September 2013 by the Core Area Liquid Waste Management Committee. The staff report accompanying this report was misleading – it overstated the conclusion of the report summary. The staff report said that the McLoughlin point outfall will “significantly reduce the risk to human health and shellfish relative to the existing Macaulay/Clover system”. This was an unsupported overstatement of the conclusion of the report. The report actually said “The proposed discharge of secondary treated wastewater for a new McLoughlin Point marine outfall is not predicted to result in significant adverse effects to human health or the receiving environment”.
NO SIGNFICANT BENEFIT TO MARINE ENVIRONMENT
ARESST and RSTV have repeatedly reminded elected officials at the Federal, Provincial, Regional and Municipal level that Marine Scientists and Public Health Officials have given their best judgement that there will be no significant benefit to the marine environment for this vast expenditure of public funds. The magnitude of the expenditure is illustrated by the fact that the overall cost will be approximately the cost of ten Blue Bridges. (Victoria City is currently replacing the present Blue Bridge.)
There are still many uncertainties in this project. RSTV recommends that the following questions continue to be asked of the project.
WHY NOT AN EXEMPTION TO THE FEDERAL REGULATIONS?
Given Victoria’s unique marine receiving environment will the CRD apply for an exemption to the Federal Wastewater Systems Effluent Regulations? There are ongoing meetings between the Federal and Provincial Governments to develop an equivalency agreement for enforcement of regulations. An agreement has not yet been finalised therefore exactly what the enforcement will be has not been decided. The CRD has not given any indication that they are prepared to challenge the requirements of the Wastewater Systems Effluent Regulations based on the unique receiving environment off Victoria.
WHY NOT CONSIDER THE OVERALL ENVIRONMENTAL IMPACT COMPARED WITH THE PRESENT MARINE DISPOSAL AND NATURAL TREATMENT?
Which method of sewage treatment uses the greatest amount of scarce resources or produces the lowest volumes of greenhouse gases in construction, operation, maintenance and eventual de-commissioning and/or eventual replacement with more sustainable treatment system? The CRD has received "Triple Bottom Line" assessments in the past but the assessments never made a comparison with the existing effective natural marine treatment of the preliminary treated sewage.
WHY CREATE SLUDGE IN THE FIRST PLACE?
Sludge has to be disposed of, so is not sludge from a land based sewage treatment plant creating a bigger problem than the minimal effect on the marine environment that exists at present?
WHY NOT RECOVER HEAT ENERGY FROM EXISTING SEWERAGE SYSTEM?
If the focus is to be on energy recovery will energy (heat) be recovered from the existing sewerage system (before treatment plants) potentially saving the cost of a major capital expenditure?
WHAT SHOULD BE THE PRIORITY FOR PROTECTING VICTORIA'S MARINE ENVIRONMENT?
What should be the priorities for protecting Victoria’s the marine environment – in the inner harbour, at the shoreline or the ocean floor 60 Meters below the surface?
WHAT WILL BE THE BENEFIT TO THE MARINE ENVIRONMENT?
Will there be any benefit to the marine environment and therefore cost benefit from building land based sewage treatment plants?
WILL THERE BE A COST BENEFIT?
Given that the benefits to the marine environment will be insignificant, is building Land Based Sewage Treatment Plants a cost-effective way of protecting the marine environment? Is it possible to calculate a cost-benefit of this project?
IS NOT A RAINWATER/STORMWATER SOURCE CONTROL PROGRAM MORE IMPORTANT THAN LAND BASED SEWAGE TREATMENT IN PROTECTING THE MARINE ENVIRONEMENT?
What would a rainwater source control program prevent from entering the Marine environment- such as run-off from roads, industrial discharges etc ? To protect the marine environment should not the contamination of the shoreline have a greater priority than building land based sewage treatment plants for which there will be no significant measurable benefit ?
HOW EFFECTIVE ARE SEWAGE TREATMENT PLANTS IN TREATING CONTAMINANTS OF CONCERN?
What do we know about the effectiveness of secondary sewage treatment plants in treating contaminants of concern – such as metals, pharmaceuticals, other chemicals or even microplastics ? Each chemical or substance of concern needs to be studied separately. Which contaminants can be shown quantitatively (by measured quantity) to be of concern before and after treatment?
DO SEWAGE TREATMENT PLANTS INCREASE ANTIBIOTIC RESISTANT BACTERIA?
In most urban environments, antibiotics are rleased into municipal wastewater due to incomplete metabolism in humans, or due to disposal of unused antibiotics. This condition can cause the emergence of Antibiotic Resistant Bacteria which have been detected in both treated and untreated municipal wastewater. Data from other parts of the world has shown a higher proportion of antibiotic resistant bacteria contained in raw and treated wastewater relative to surface water. A recent study in China suggested that one genetic marker of Antibiotic Residtant Bacteria showed proliferation in one wastewater plant even though the final effluent was chorinated wastewater. (Letter to CRD from Dr Richard Stanwick and Tim Lambert Ph.D. Executive Director Health Protection Branch Ministry of Health).
HOW EFFECTIVE HAS THE SEWER SOURCE CONTROL PROGAM BEEN?
What has the source control program prevented from entering the Marine environment – such as fats and grease, mercury, pharmaceuticals? The sewer source control progam has been highly effective in diverting unused antibiotics and other medications from the sewer.
HOW WILL THE SLUDGE BE DISPOSED OF?
If the sludge is to be incinerated what amount of greenhouse gasses will be produced? In 2013 CRD decided not to reverse its policy that it will not allow the sludge to be spread on non-food producing agricultural land. This was after presentations by the Seaterra Commission which emphasised the safety of this method of disposal and that by not allowing it the overall cost of the project may increase by about $35 Million to enable an incinerator to be built at the Hartland site to burn the dried sludge.
WHAT IS THE FATE OF CHEMICALS IN THE SLUDGE?
If incineration of the sludge is the method chosen what chemicals will survive the incineration and be vented to the atmosphere? What chemicals and in what concentrations, will be in the sludge that has to be disposed of by whatever means?
WHAT ABOUT ENERGY USED TO TREAT AND DRY THE SLUDGE?
How much energy will be consumed in drying the sludge if it is to be incinerated?
WHY NOT AQUIRE DND LAND FOR A SINGLE PLANT?
Why has the CRD not negotiated to aquire DND land adjacent to the CRD's Macaulay point pump station or even land adjacent to McLoughlin point where it would be possible to build the primary treatment and the sludge treatment in one facitlity? The Macaulay point pump station area was considered earlier on in the planning (five years ago) but the decision was not to persue it because the negotiations with the DND would take too long. The CRD has given no indication that it is prepared to persue this option.
WHEN WILL THE LEGAL AGREEMENT FOR FUNDING BE COMPLETED?
Will the public be made aware of a legal agreement for the Federal and Provincial contributions to the project? Without this agreement the CRD municipally elected officials are putting the local taxpayers at great financial risk. There is an agreement in principle but as of this date the Federal Government has not signed off on their contributions to the Capital Costs of the project. Based on a Seaterra February 2014 report the Province of BC have approved their $248 Million share, PPP Canada have approved their $83,400,000 share but the Federal Building Canada Fund share of $120 Million and the Green Infrastructure Fund contributiohn of $50 Million have not yet been approved.
WHAT WILL BE THE FINAL COST TO THE MUNICIPAL TAXPAYERS?
The CRD staff have provided estimates on the cost impact on municipal taxpayers based on the volume of sewage to be processed from each municipality. These costs are based on many assumptions. What will the eventual costs be to the Municipal taxpayers?
WILL MUNICIPAL TAXPAYERS NOTICE THE INCREASED COSTS ON THEIR HOUSEHOLD TAXES OR ON THEIR UTILITY BILLS?
Each of the seven municipalities (Victoria, Oak Bay, Esquimalt, Saanich, Langford, View Royal and Colwood) will be billing their taxpayers (households and busineses) in different ways. Victoria, Saanich and Oak Bay are adding the CRD sewage costs to the utility bills. Taxpayeers will be paying for the CRD sewer costs based on the volume of potable water consumed by each household. This will mean in some municipalities that if there is more water use for lawn watering then they will be paying more for sewage costs.
WILL THE SEDIMENTS IN THE VICTORIA HARBOUR BE OF CONCERN?
Given that the sediments in Victoria harbour are heavily contaminated due to previous industrial activity what will an environmental assessment show if the sediments are disturbed if sewer pipes cross the harbor floor?
WILL THE PLANNED SEWAGE TREATMENT PLANT BE AFFECTED BY AN EARTHQUAKE?
Will the CRD provide a written confirmation that the potential earthquake hazard affecting the McLoughlin point site has been completed and been professionally reviewed and the results published?
WILL CONSTRUCTION OF A MCLOUGHLIN POINT PLANT INTERFERE WILL THE HARBOUR AIRODROME?
What measures is the Commission (Seaterra) taking to ensure that during construction of a plant on the McLoughlin point site there will be conformaty with Transport Canada regulations for the aircraft traffic procedures, under a new harbour airport safety plan? There are frequent daily float plane flights that pass at low altitude directly over McLoughlin Point on their approach to the airodrome runway.
WILL THE DESIGN OF A PLANT AT MCLOUGHLIN POINT BE ACCEPTABLE TO VICTORIA, ESQUIMALT RESIDENTS AND VISITORS ENTERING THE HARBOUR?
If a treatment plant is to be constructed at McLoughlin point will the design meet the expectation of Victoria (and Esquimalt) residents and tourists entering Victoria harbour?
WILL APPLICABLE ENVIRONMENTAL IMPACT ASSESSMENTS BE CARRIED OUT?
Before the CRD begins any construction of the plant (after 2013), a complete EIA under the BCEAA and/or CEAA must be initiated, together with public hearings, must then be completed, must be submitted to both provincial and federal environment ministers for their review and then their approval before any construction begins. Will that be done and when will it be initiated? The CRD is relying on Environmental Impact Assessments (EIS) and Environmental and Social Assessments (ESA's) carried out in about 2008. It is of special interest that the ESA's do not include any assessment of worker safety (injuries or deaths) during the construction of the plants and pipelines.
WHAT IMPACT ARE THE CURRENT DEEP SEA DISCHARGES OF PRELIMINARY TREATMENT SEWAGE HAVING ON THE OCEAN FLOOR OFF VICTORIA?
What are the conclusions of the latest (2010) Marine Monitoring report of the two deep ocean outfalls at Clover and McLoughlin point? The latest (2012) draft marine monitoring report is currently being reviewed by the Marine Monitoring Advisory Committee.
REPAIRS TO CLOVER AND MACAULAY POINT OUTFALLS NEEDED
The 2010 Marine Monitoring report noted that repairs are needed to the Clover and Macaulay Point outfalls which will still be used during times of high sewage flows. Will these be carried out?
WILL A HEALTH AND SAFETY IMPACT BE CARRIED OUT FOR THE PLANNED LAND BASED SEWAGE TREATMENT PLANTS?
Will a Health Impact Assessment be carried out for this expenditure and the treatment plants as advocated for by the Regional Medical Health Officer, Dr Richard Stanwick? A triple bottom line assessment does not include a health and safety assessment. There has been no assessment carried out of the risk to the health and safety of the potentially hundred's of workers during the construction phase of the project. There will undoubtably worker injuries and there may even be fatalities. At least one fatality occurred in the contstruction of the Canada Line in Vancouver.
SHOULD NOT A FULL INDEPENDANT ENVIROMENTAL IMPACT ASSESSMENT BE COMPLETED?
Will a full, independent environmental impact assessment be completed for the sludge treatment plant (known as the Energy Centre)? Because the Energy Centre includes several processes that are not part of sewage treatment (i.e., phosphorus recovery and a Waste-To-Energy plant), it cannot be covered by the inadequate environmental review under the Municipal Sewage Regulations.
Original document 28 February, 2013 (Updated April 23rd 2014).