To: Justin Sabourin,
Ministry of Environment BC
Copy: James Arnott
The following is submitted in response to the request for feedback to the proposed Equivalency Agreement between Environment Canada and the Province of BC.
Please consider the following before finalizing this Equivalency Agreement.
The "one size fits all” approach that is the basis for the Federal Municipal Wastewater Regulation (MWR) should not be applied for Victoria’s unique receiving environment.
For at least 20 years the Capital Regional District has monitored the marine sediments and the receiving waters off Victoria in comprehensive studies. The findings are that because of the more than 1 KM deep ocean outfalls with their 200 meter diffusers, Victoria’s sewage is producing a minimal effect on the marine environment. Marine Scientists from the University of Victoria and other very credible marine scientists have consistently and collectively given their best judgments. These are that the amount of contamination of the ocean floor is minimal compared with the effects on the land and global environment that will be created by proposed land based treatment plants.
It is acknowledged that in the MWR, that TSS and CBOD are the regulated parameters that have been chosen and that as presently defined, because of “end of pipe” requirements, cannot be met without land based secondary sewage treatment plants being constructed for Victoria.
For years the Province of BC accepted an Initial Dilution Zone, outside of which the regulated parameters are met, but now if the Equivalency Agreement is ratified it may be “end of pipe” regulation. The CRD meets the regulated levels of TSS and CBOD if an Initial Dilution Zone is allowed.
The MWR takes the same approach for discharges into rivers (fresh water) as it does into the marine (salt water) where in Victoria’s case the sewage is rapidly diluted and naturally treated.
As mentioned above marine scientists and public health officials have provided judgments, that have been published, that indicate that the unique marine receiving environment off Victoria treats the sewage effluent naturally (it is auto-purified) and that land based treatment will have a net adverse effect on the environment (when marine, land and global environment are taken into account).
It is noted that the Federal MWR will stand down in BC following harmonization but that the federal Fisheries Act will still be applicable.
In the original documents that the Canadian Council of Ministers of the Environment (CCME) used as a justification for the “one size fits all” approach there was a cost-benefit study. This study however does not apply to the Victoria situation. (Benefits included were safety of drinking water and increased property values, which do not apply). It does not make sense to spend currently estimated over $1Billion of tax dollars when there is clearly no definable cost-benefit.
The CCME received much advocacy from groups such as Ecojustice, the Georgia Strait Alliance and the T-Buck Suzuki Environmental Foundation. It has been shown that much of the information presented by these groups was misinformation. For example they claimed in a letter to the CRD that the ocean floor off Victoria was a Contaminated Site based on the CRD’s Contaminated Site Regulation. The study that was carried out only concluded that it was a preliminary finding based on a very small sample size. The ocean floor has never been designated a Contaminated Site as would be required by the regulation. For more information on misinformation provided by these groups please see: http://www.rstv.ca/countering-misinformation-and/
ARESST (the Association for Responsible and Environmentally Sustainable Sewage Treatment) on June 16th 2015 wrote a letter to the Auditor General for Canada. This provides detailed facts in support of the above request to you (see www.aresst.ca). The letter asks the Auditor General to carry out a review of the issue. I urge you to review the full document, particularly the CCME definition of low-risk.
Thanks for your consideration,
Dr Shaun Peck
(Medical Health Officer for the CRD 1989-1995)