Alex Murdoch is a retired Marine Consultant. The following is the presentation he made to the CRD's Core Area Liquid Waste Management Committee on August 19th 2009.
Comments to the CALWMC regarding proposals for a
Saanich East-North Oak Bay Treatment Plant
Emmanuel Baptist Church, August 19, 2009 by Alex Murdoch.
First, on a positive note, I commend the CRD and this committee for the degree to which it has made information and reports available to the public through web-sites and mailings. In fact the sheer volume of information can be daunting. But I have read the Westland Report [all 198 pages] as well as other related documents.
I’ve produced a lot of technical reports in my time and the Westland Report is of a familiar type. I consider it well-prepared and, given the parameters, criteria, and assumptions on which it was based I can’t quarrel with its implied conclusion that if a plant of the type proposed were to be built within the defined study area it should go at Haro Woods.
So my concerns are with the assumptions made, including whether there is a need for this plant at all and, more basic, to the assumed need [without any scientific evidence] for land-based secondary treatment.
First, a general concern regarding the way this project has gone forward, without any apparent sober second thought, despite the objections voiced by a host of experts. I know that this committee is familiar with those objections [most are posted on the website at RSTV.CA] and I won’t belabour them here, but none of them appear to have been addressed. When such issues are raised with CRD staff the mantra is always “that’s not open for discussion as the decision has already been made.”
I cannot believe that at least some members of this committee do not share my concerns, yet I hear no calls for restraint.
And regarding public consultation: I note with regard to the area under discussion this evening that although four potential sites have been suggested three may not actually be available and one – the clearly-favoured Finnerty-Arbutus site – has already been purchased. One cannot avoid the impression that the decision has already been made and that hearings such as this are mere window-dressing.
Next, a concern that even if multiple land-based treatment sites can be shown to have benefit there is little to justify one in this area.
As I understand the proposal, this plant would provide secondary treatment using a membrane-bioreactor system and the output would be a 1.5-2.0% slurry of still-contaminated solids which would be piped – via the existing Interceptor – to an as-yet unidentified treatment site somewhere across town plus a second stream of treated liquid waste which would be discharged into Haro Strait. The issue of eventual biosolid disposal [up to 6.8 tons per day from this plant alone] remains unresolved. As to liquids, once 2-times normal dry-weather flow was surpassed a partial bypass would occur and untreated or partially treated effluent would go to the outfall.
The proposed membrane system is expensive and very energy-demanding compared with more conventional systems [the report shows a best-case demand of 4.6 million kWh/year!] but is needed to minimise odour and health risks on the small sites available.
Your July/August Wastewater Update lists five rationales for this plant:
- reduced load on the downstream plant
- recovery of heat and energy
- enhanced wet-weather capacity
- provision for anticipated population increases
- avoidance of otherwise-necessary upgrades to the existing infrastructure
I submit that:
1. Load-reduction would be minimal, as solids would still go to the downstream plant.
2. If green-source heat [for UVic or Queen Alexandra] is an important objective, more cost-effective and environmentally-friendly solutions are available [e.g. deep-well or ocean-source heat-pump systems]; heat-energy recovery from sewage would be a small fraction of the excess electrical energy expended.
3. By your own figures wet-weather flow reduction would be less than 15%.
And while the proposed outfall probably meets accepted requirements for treated effluent it is not as good as Clover or Macaulay Points where there is better mixing and a net outflow to the open sea; the difference increases during wet-weather flows.
4. The plant would serve a largely-developed area with less than 7% of the Greater Victoria population and little growth potential.
5. As to avoiding infrastructure upgrades, it would make more sense to continue pumping all area waste to a more central facility and to spend the money saved on improvement of the existing infrastructure – leaky pipes and overflows are after all responsible for most of the existing health risks – plus extension of the source-interception program to private residences.
Regarding this last point: If our objective is truly the protection of the marine environment then interception at source – keeping toxic materials out of the system instead of trying to remove them later – is potentially the most efficient [and cost-effective] element in such a program. The CRD has already done a commendable job of reducing industrial-source toxins. But residents have shown their willingness to co-operate through their enthusiastic participation in existing recycling and composting plans. And a residential interception program could be implemented now, without waiting for plant construction.