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(Updated July 31st 2015) 

BRIEF HISTORY SINCE 2006 

The Capital Regional District has been planning 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 plans was 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: Marine Scientists Review

LIQUID WASTE MANAGEMENT PLAN

The CRD must have a Liquid Waste Management plan approved by the BC Minister of Environment. Amendment 8 involved a treatment plant at McLoughlin 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 was to provide secondary treatment for 2x Average Dry Water Flow and primary treatment for up to 4x ADWF. This treatment plant would increase 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 that was planned to be at McLoughlin point after removal of the solids (sludge). There was to be an additional 4 KM of pipeline from Clover Point to McLoughlin Point. An Amendment 9  of the LWMP (which had a few adjustments of Amendment 8) was approved by the CRD Board and submitted to the Provincial Minister of Environment for approval in January 2014. Amendment 9 was later given conditional approval by the Minister of Environment on July 3rd 2014.

On May 27th 2014 the CRD announced that it would not be proceeding with a Sewage Treatment Plant at McLoughlin Point. This meant that the complete treatment plan has to be revised including the pipelines and a new Liquid Waste Management Plan submitted to the Minister of the Environment for approval.

In January 2015 the CRD formed two public consultation groups. One group West Side Solutions and  is made up of Langford, Colwood, Esquimalt, View Royal and the Songhees Nation. See: www.WestsideSolutions.ca.   As of July 31st 2015 this group has been identifying many sites that could be used for land based sewage treatment. 

It is noted that it is considered out of scope for the public to comment on "Challenging the regulatory requirements for wastewater treatment" which is what RSTV has been advocating for for several years. 
  

The second group called East Side solutions lead by elected officials from Victoria, Saanich and Oak Bay has been carrying out public consultations and as of July 31st 2015 has identified a number of sites for land based sewage treatment plants to be built. 

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 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 after hearing of the public opostion to the plant in that site. However there was still an agreement to purchase the land with a closing date of September 2014.

On February 27th 2014 the CRD announced a lease agreement. "The Capital Regional District (CRD) will own the two buildings located at 808 and 836 Viewfield Road on September 30, 2014. In advance of taking ownership the CRD is entering into a lease agreement with Wilson Foods for both buildings." 

APPROVED PLAN IS NOW INVALID

There were uncertainties in the approved plan (Amendment 8) which staff informed the CRD’s core area liquid waste management committee (CALWMC) would need to be revised. Changes were included in Amendment 9 that was submitted to the provincial Minister of the Environment in 2014. On July 3rd 2014 the Minister of Environment gave conditional approval to Amendment 9 subject to certain conditions.

The public was informed that there would 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 still (May 2015) no legal agreement for the Federal cost sharing of 1/3 of the capital costs of the project. It appears that there has been an extension for the deadline for approval of the Federal constributions.

Following the May 27th 2014 announcement there will need to be a revised Liquid Waste Management Plan submitted to the Provincial Minister of the Environment for approval.

The many options were discussed by the CALWMC on June 11th 2014.

FINANCIAL ISSUES

It was expected that the current cost estimate of the plan of $788.5 Million capital costs and on going $14.5 Million operating costs, which were “Class C” estimates (which means +/- 25%) would be exceeded as is the norm for mega projects of this type. (The estimate was increased from $783 to $788.5 Million in May 2014)  There was an assumption that there would be $5 Million in resource recovery revenue in the annual operating costs. This was hypothetical.

Published in the May issue of Public Sector Digest, University of Victoria Economist Rebecca Warburton estimated that the 2014 building costs were now $847,204,281. (when adjusted for 2% annual inflation)  The total costs including the present value of the operating costs were estimated at $1,149,535,641. (This is using a discount rate of 5% and 50 year project life).

All these estimates are now hypothetical since with McLoughlin Point now not able to be used (based on the CRD's May 27th 2014 announcement) for a treatment plant. New cost estimates will need to be created for an ammended Liquid Waste Management Plan. 

 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 were 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 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. (the $47.3 Million is only a one year cost - the CRD has incurred additional costs since 2006 in the planning of land based sewage treatment).

Following the announcement on May 27th 2014 that a sewage treatment plant would not be built at McLoughlin Point the CRD will now have to spend more funds planning for the future before a new projected estimate for the capital costs will be available.

Staff reports to the CALWMC for June 11th 2014 indicated there was no way of estimating the cost at that time. The staff report does give estimated financial impacts if the Federal funding contributions are not received.

As of October 31st 2014 the Seaterra Commission reported that they had spent $36,814,301 on the project.

Based on staff presentations to the Core Area Liquid Waste Management Committee in January 2015 the CRD has already spent $69.4 Million on planning including land acquisition. 

PROJECT OFFICE AND COMMISSION 

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).

The Project team established an office at 510-1675 Douglas Street. 

Following the announcement on May 27th 2014, the future of the Seaterra Commission is in doubt since it was created to carry out an approved Liquid Waste Management Plan (Amendment 9).

The Seaterra Commission ceased all planning activities with the exception of the construction of the Craigflower Pump Station and the planning for the Arbutus Road attenuation tanks on June 27th 2014. 

In May 2015 public speakers to the CALWMC were advocating for abolishment of the Seaterra Commission.

COMMISSION HIRED A NEW PROJECT DIRECTOR

On July 31st 2013 the Commission 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.

On July 31st 2015 the CRD announced that: "the head of the Seaterra sewage program, who was still receiving a $290,000 annual salary even though the project was stalled, will be let go at the end of September.

Albert Sweetnam was at the top of the Capital Regional District’s salary list for 2014. He will receive just under $500,000 in severance pay.

Sweetnam was hired on a five-year contract in 2013 to manage a staff of more than 20 people. But after the project halted, along with the prospect of McLoughlin Point as a treatment site, he maintained the same pay, even though he was managing a pared-down program with the equivalent of four full-time workers.

The CRD announced Sweetnam’s departure Friday morning, following a meeting of the Seaterra Commission, which has been renamed the core area wastewater treatment program commission.

By the end of September, all staff will have completed their assignments and the office will close, the CRD said.

The commission office space will be leased out by the CRD. Almost all of the contracts specific to the project have been terminated. Outstanding items remaining in October will transition to CRD staff for wrap-up."

 

COMMISSION RENAMED PROJECT

On October 7th 2013 the Commission created a brand and renamed the project the Seaterra project.

McLOUGHLIN POINT

On April 19th 2013 the CRD purchased McLoughlin Point from Imperial Oil for $4.6 Million. On May 27th 2014 CRD announced it will not be using McLoughlin Point for a sewage treatment plant. (What will the CRD do with this site if if it not used for a Sewage Treatment Plant?) 

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.  It appears now (July 2015) that all three companies will receive this payment.

In spite of not having approval to build on the site, on May 6th 2014 Seaterra chairperson Brenda Eaton announced that it has selected it's preferred company to build a new sewage treatment plant at McLoughlin Point. Harbour Resource Partners was picked to design, build and partially finance the planned treatment plant as well as the Victoria Harbour crossing and the marine outfall.

The McLoughlin Point required rezoning by the Municipality of Esquimalt. This rezoning hearing took place on 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 amenities 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 the Provincial Minister of Environment has declined to exercise that power. 

At the CRD’s Core Area Liquid Waste Management  committee meeting on Wednesday 9th April 2014, CRD directors voted to ask the provincial cabinet to intervene: either force through McLoughlin Point rezoning or provide other options. This the Province declined to do.

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.

Following a response to a formal request from the CRD, Environment Minister Polak announced on May 27th that the Province was not going to be involved and the CRD then announced that it will not be building a sewage treatment plant at McLoughlin Point.

Staff reports for the June 11th 2014 meeting of the CALWMC indicate this matter was discussed in camera at the meeting.

NEW OUTFALL AT McLOUGHLIN POINT

A study of the marine environment around the proposed new outfall at McLoughlin point was 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”.  

Following the May 27th 2014 announcement this outfall may not be required in any future plan for land based sewage treatment for the core area of the CRD. 

NO SIGNIFICANT 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.)  Since May 27th 2014 the cost of land based sewage treatment will undoubtedly be more than the current estimate of $788.3 Million but until a new plan is developed this cost will not be known. 

There are still many uncertainties in this project. RSTV recommends that the following questions continue to be asked. 

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. Until the agreement is finalised it will not be know exactly what the enforcement will be.  Up until May 2015 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.They have even published that during the present public consultations on the West and East side that challenging the provincial and federal regulators is "out of scope".

This challenge would need to be done with the help of a legal firm that has experience in challenging Federal and Provincial Legislation based on the fact that it is not based in the best science.

In the Public Health field there is a precedent for this. When there has been widespread reluctance of the population to immunize children against serious infectious diseases (like Whooping Cough and Measles) Judicial reviews have been carried out on the safety of vaccines and the court examines scientific evidence from both sides of an argument and then concludes as to whether a vaccine is safe. 

A key point to consider is that prior to the Federal Wastewater Systems Effluent Regulations the CRD was in compliance with Provincial requirements because the Province of BC allowed an initial dilution zone of 100 meters. The current sewage discharges at Clover and Macaulay points meet the Federal Wastewater Systems Effluent Regulations if a 100 meter diffusion zone is used to interpret the regulated parameters of Carbonaceous Biochemical Oxygen Demand (cBOD) and Total Suspended Solids (TSS). The Federal regulator has always (under the Fisheries Act) expected an "End of Pipe" interpretation of the regulation.   

The Federal Wastewater Systems Effluent Regulations is unreasonable from a scientific perspective because it has taken a "One size fits all" approach to all sewage treatment in Canada irrespective of the receiving environment. The waters off Victoria are a unique receiving environment where the sewage effluent after preliminary treatment is assimilated and treated naturally by the marine environment. Intensive monitoring has shown a minimal effect on the ocean floor around the outfalls.

It is of interest that Municipalities (Vancouver and Victoria) are considering by-laws that legitimize the sale of Cannabis against the objections of the Federal Government as defined by the Marihuana for Medical Purposes Regulations (MMPR). Maybe the CRD will consider this in the future for the need for increased land based sewage treatment!

 

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 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?

Here are some questions the marine scientists have posed that should be answered before spending more taxpayers dollars on land based sewage treatment in Victoria.

  • What are the present or potential problems with wastewater and other discharges into the local marine environment?
  • How serious are these problems?
  • What are the major sources of the problems?
  • Will a proposed remedy eliminate or even reduce the problems without creating bigger impacts?
  • Are there better solutions than the ones proposed?
  • Is addressing the problems a high priority for marine environmental protection?

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?

In a table in the May 2014 issue of Public Sector Digest (www.publicsectordigest.com) economist Dr Rebecca Warburton calculates that the 2014 cost of Victoria's Land Based Sewage Treatment Plan is $1.103 Billion and that this is a negative cost benefit because no benefit is definable. (This calculation adjusted for inflation at 2% per year, using a discount rate of 4%, and project life of 25 years). The article is titled "Optics trump evidence:The Seaterra Project in Victoria".

This analysis was carried out using previous estimates that included McLoughlin Point as the site for a sewage treatment plant. (The May 27th 2014 announcement from the CRD was that McLoughlin Point would not be used.) The estimated costs of a new Liquid Waste Management Plan will only be known once a plan is developed.

IS NOT A RAINWATER/STORMWATER SOURCE CONTROL PROGRAM MORE IMPORTANT THAN LAND BASED SEWAGE TREATMENT IN PROTECTING THE MARINE ENVIRONMENT?

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? Another question that must always be asked is what is the evidence of an effect on the marine environment? Just because a substance can me measured in minute quantities does not mean that it is having a detectable effect. The perception is that if a substance is present it must be causing an effect. However this has to be shown and is certainly not the case with many substances.

DO SEWAGE TREATMENT PLANTS INCREASE ANTIBIOTIC RESISTANT BACTERIA?

In most urban environments, antibiotics are released 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 Resistant Bacteria showed proliferation in one wastewater plant even though the final effluent was chlorinated wastewater. (Letter to CRD from Dr Richard Stanwick, Medical Health Officer for the Region and Tim Lambert Ph.D. Executive Director Health Protection Branch Ministry of Health).

There is clear evidence that antibiotic resistant bacteria are multiplied in secondary sewage treatment plants due to the activated sludge process.

(Reference: Journal of Toxicology and Environmental Health, Part B: Critical Reviews Potential Ecological and Human Health Impacts of Antibiotics and Antibiotic-Resistant Bacteria from Wastewater Treatment Plants Sungpyo Kim a & Diana S. Aga a a Department of Chemistry , State University of New York at Buffalo , Buffalo, New York, USA Published online: 28 Nov 2007.) The full text should be reviewed for the context and the references.

This is evidence that the present practice of discharging sewage through two deep sea outfalls where bacteria in the sewage a subject to die off in the marine (salt) water within less than 100 meters is the best practice for Victoria and why building land based sewage treatment plants will create a public health concern due to multiplication of antibiotic resistant bacteria. 

HOW EFFECTIVE HAS THE SEWER SOURCE CONTROL PROGRAM BEEN?

What has the source control program prevented from entering the Marine environment – such as fats and grease, mercury, pharmaceuticals? The sewer source control program has been highly effective in diverting unused antibiotics and other medications from the sewer. See: Regional Source Control Program. The latest annual reports are here.

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.

In a letter dated July 3rd 2014 Environment Minister Mary Polak stated; " With regard to Condition l,I understand the CRD Regional Biosolids Management Policy does not support the land application of biosolids at CRD parks and facilities or on farmland. Provincial legislation, regulations and guidelines allow the beneficial use of biosolids, including beneficial land application. I am sure you can appreciate that it would be inappropriate for me to approve CRD policy that is inconsistent with provincial legislation, regulations and guidelines."

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? The Seaterra project in May 2014 said that the dried biosolids will be put to a beneficial use as a fuel substitute. Before this can be done much energy will be required to dry the sludge.

WHY NOT ACQUIRE DND LAND FOR A SINGLE PLANT?

Why has the CRD not negotiated to acquire DND land adjacent to the CRD's Macaulay point pump station where it would be possible to build the primary treatment and the sludge treatment in one facility? The Macaulay point pump station area was considered earlier on in the planning (more than eight years ago) but the decision was not to pursue it because the negotiations with the DND would take too long.  The CRD has given no indication that it is prepared to pursue 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 there has been no signed agreement for the contribution from the Federal Building Canada Fund share of $120 Million and the Green Infrastructure Fund contribution of $50 Million.

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?

Since the May 27th 2014 announcement any cost estimate on the impact on Municipal taxpayers is hypothetical.

A June 11th 2014 staff report to the CALWMC gives estimates for the impact on the local taxpayers with and without the Federal funding contributions to the Capital costs.

See:Agenda Item 7 CALWMC June 11th 2014 

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 businesses) in different ways. Victoria, Saanich and Oak Bay are adding the CRD sewage costs to the utility bills. Taxpayers 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? 

This 2007 Report from Tansport Canada gives an idea of the magnitude of the harbors sediment and the health and environmental risks.

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? 

With the decision announced on May 27th 2014 by the CRD to abandon McLoughlin Point as a sewage treatment site this risk has been mitigated!

WOULD CONSTRUCTION OF A MCLOUGHLIN POINT PLANT INTERFERE WILL THE HARBOUR AERODROME?

What measures is the Commission (Seaterra) taking to ensure that during construction of a plant on the McLoughlin point site there will be conformity 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 aerodrome runway.

This concern is mitigated with McLoughlin Point being abandoned as a potential site for a sewage treatment plant as was announced on May 27th 2014.

WOULD THE DESIGN OF A PLANT AT MCLOUGHLIN POINT BE ACCEPTABLE TO VICTORIA, ESQUIMALT RESIDENTS AND VISITORS ENTERING THE HARBOUR?

If a treatment plant was to be constructed at McLoughlin point would the design meet the expectation of Victoria (and Esquimalt) residents and tourists entering Victoria harbour?

With McLoughlin Point being abandoned (as announced on May 27th 2014) as a site this concern will be mitigated.

WILL APPLICABLE ENVIRONMENTAL IMPACT ASSESSMENTS BE CARRIED OUT?

Before the CRD begins any construction of a plant (after 2015), will a complete EIA under the BCEAA and/or CEAA must be initiated, together with public hearings? This should then be completed and 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 Marine Monitoring report of the two deep ocean outfalls at Clover and McLoughlin point? 

Here is the latest Marine Monitoring Report.

 

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. Some repairs have been 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 undoubtedly worker injuries and there may even be fatalities. At least one fatality occurred in the construction of the Canada Line in Vancouver.  

SHOULD NOT A FULL INDEPENDENT ENVIRONMENTAL IMPACT ASSESSMENT BE COMPLETED?

Will a full, independent environmental impact assessment be completed for the sludge treatment plant (known as the Energy Centre) at the Hartland Land Fill site? 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.

WHAT WILL HAPPEN NEXT?

As of May 27th 2014 when the CRD announced that it had abandoned the plan to construct a sewage treatment plant at McLoughlin Point a new Liquid Waste Plan will have to be developed. As of May 2015 the CALWMC aim to have a revised Liquid Waste Management Plan developed for approval by the Provincial Minister of Environment by the end of 2015.

Prior to this the Westshore and Eastside Committees are developing plans and carrying out public consultations with a view to having their plans developed by the end of June 2015 but this deadline has passed. Many sites are being considered for land based sewage treatment plans.

If for example it was possible to acquire DND land adjacent to the Macaulay Point Pump station the 15 KM pipe to and from the Hartland Land Fill site and the sludge treatment plant could be excluded from the plan.  A site adjacent to the Macaulay Point Pump station could be acquired that would enable both the primary treatment and the sludge treatment plants to be built on one site. Whether the Macaulay Point site is considered remains to be seen. 

There have been many suggestions for advanced sewage treatment beyond secondary but fortunately the public commentary still includes the acknowledgement that the credible science does not support increased treatment for Victoria.

Elected Officials seem to have lost sight of the fact that whatever is going to be planned now is going to increase the costs to the taxpayers.  In addition some of the announced Federal funding may not be available.

COMMENT: With the current delay in the planning for sewage treatment there is still time for the CRD to consider whether to challenge the Federal and Provincial regulators since based on credible Marine Scientist judgements there is no need for increased treatment for Victoria. In January 2015 a new Core Area Liquid Waste Management Committee was formed who intend to develop a new plan by the end of 2015. The first stage in this plan is the development of a West side and East side public consultation. The present plan was based on the use of McLoughlin Point but with Esquimalt's rejection of that site a completely new plan is needed. So far more than $69.4 Millionhas spent on planning and land aquisition for land based treatment for Victoria. 

 

Original document 28 February, 2013 (Updated July 31st 2015).