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Motion to CRD Board to correct Risk Classification

Motion for Correction of the Risk Classification of the CRD's Existing Marine-Based Wastewater Treatment System    

1. The 2012 federal Wastewater Systems Effluent Regulations (the Regulations) have classified our existing system of natural marine wastewater treatment as high risk;
2. According to the Canadian Council of Ministers of the Environment's (CCME's) published documents, the classification of high risk applies only to treatment systems which discharge into fresh water receiving environments;
3. The classification of high risk is, therefore, not applicable to the CRD's exisiting marine-based treatment system because it discharges into salt water;
4. The CCME's published definition of medium risk is not applicable to our existing treatment system because its discharge flow volume of approx. 1 m3/sec. is not “a moderate portion” of the Strait's flow volume of approx. 100,000 m3/sec.; 
5. The CCME's's published definition of low risk applies perfectly to our existing system because its discharge volume is “a minor portion” of the flow volume of the Strait (1/100,000 = o.oo1%), and meets all of the definition's requirements for a marine discharge;
6. Classifying our system as low risk would accord with such facts as:
a) metals in our wastewater are not at toxic concentrations, but are as low as 1000 times less than drinking water standards and
b) no illness has been attributed to the discharge from the system's deep-sea outfalls;
7. Any risk to the marine environment by plastic micro-beads will diminish as manufacturers' commitments to stop using the beads, and as planned legislation banning their use in consumer products, come into effect;
8. The Regulations, which are being interpreted as requiring the CRD to develop and implement a wastewater treatment plan, are in a statute of the Dept. of Fisheries and Oceans (DFO);
9. This interpretation of the DFO's Regulations is not supported by the DFO's own 2014 study which concluded that:
a) federal requirement of secondary treatment will have a negligible effect on present levels of nitrogen, organic carbon, and PCBs in the Straits, and that 
b) source control can be more effective than treatment for removal from the environment of persistent contaminants, such as PolyBrominated Diphenyl Ethers (flame retardants); 
10. The CRD has not yet complied with the CCME's published policy for implementation of the Regulations, which states that it is not acceptable to simply presume that benefits of a wastewater treatment plant will exceed its costs, but that cost-benefit analysis is required;
11. Prime Minster Justin Trudeau’s published opinion about the CRD’s drive to create and implement  the plan is that it's a “push of ideology over sound scientific evidence” and that “There will be no net environmental benefit from this secondary treatment plant”;
12. The Prime Minster's Office has forwarded to the Minister of the Environment and Climate Change, and to the Minster of Infrastructure, a Victoria citizens’ plea for review whether or not the federal government ought to provide funding for the CRD’s sewage project;
13. Consultants to the CRD have estimated that construction of the land-based system will produce 15,516 tonnes of greenhouse gases (GHGs), and that operation of the system will produce 7,917 tonnes of GHGs annually;
14. Construction of the system would, therefore, be contrary to CRD municipalities' commitments to significantly reduce their emissions of GHGs, and contrary to the Ministerial Mandate Letters issued by Prime Minster Trudeau, which identify that a top priority of the federal government is to reduce emissions of GHGs to combat climate change;
15. Our present system has a low carbon footprint because its auto-purification treatment process is powered by the safe, reliable, sustainable, non-polluting energy of ocean currents;
16. The P3 Canada deadline of March 31, 2016, for eligibility of a grant may no longer be in effect because the Mandate Letter to the federal Minister of Infrastructure specifically instructs the Minister to remove the P3 screening process for infrastructure projects;  
17. Protestations that discharges from the CRD's deep-sea outfalls are polluting Puget Sound are not supported by oceanographic studies which have determined that it is highly improbable that the Strait's currents ever carry material from the discharges into Puget Sound;
18. Correction of the CRD's present treatment system's classification from high risk to low risk would carry with it a change of compliance deadline from 2020 to 2040;
Be it resolved that the CRD vigorously pursue negotiations with the federal government to correct the risk classification of Victoria’s present treatment system of long, deep-sea outfalls from high risk to low risk.


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