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.
"Great is the power of mis-representation, but the history of science shows that fortunately this power is not long enjoyed" Charles Darwin - the Origin of Species - 1872
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 have been 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 November 2015 the CRD has not given any indication that they are prepared to challenge the requirements of the Wastewater Systems Effluent Regulationsbased 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.
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.
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?
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! However the earthquake concern will apply to any land based sewage treatment plant.
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?
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.
It has not been determined (November 2015) how the sludge will be treated in a new Liquid Waste Management Plan that will need to be developed.
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. As of November 2015 this appears to have been delayed.
The Westshore and Eastside Committees have developed plans and are 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. It does not appear in November 2015 that a Macaulay Point site is being considered.
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. In November 2015 this has not occurred. The first stage in this plan was 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 November 20th 2015).