Dr Shaun Peck's comments to the annual meeting of ARESST November 3rd 2011
Thank you for the opportunity to speak at this second annual meeting of ARESST – the Association for Environmentally Sustainable Sewage Treatment in Victoria.
I would first like to congratulate members of ARESST on the success that we have had over the last four years in keeping in front of the community and elected officials the important message that Victoria does not need land based secondary treatment plants, that our liquid waste is treated naturally by the unique marine environment and that when you consider the overall environment – marine, land and global, building land based sewage treatment plants and creating a toxic sludge that has to be disposed of will do more harm that the minimal effect that is occurring on the ocean floor with our two deep sea outfalls.
I would like to thank our community partners – Save Haro Woods, the Esquimalt Residents Association and others with whom we have met and discussed common issues over the last few years.
There are many individuals who have volunteered and who are members of ARESST and who have put in an enormous amount of time and energy. Without naming any particular individual I would like to thank you all on behalf of the Board of ARESST.
I was amazed recently when the Georgia Strait Alliance and the T Buck Suzuki Environmental Foundation came up with a document called “Victoria’s Raw Sewage Discharge – Frequently asked questions” that has been provided to candidates in the upcoming municipal elections.
The document is full of misinformation, or what someone recently described to me as “junk science”, that is designed to feed into the public’s perceptions rather than to provide credible scientific evidence.
These organisations have full time staff to produce this information but it is appalling that they can produce such misinformation.
The T Buck Suzuki Environmental Foundation (TBSEF) is supported by the United Fisherman and Allied Workers Union which was taken over by the Canadian Autoworkers Union and is known as UFAW-CAW. In fact the TBSEF works out of the same address as the UFAW-CAW. I was also shocked to find out that the TBSEF receives a regular grant from Fisheries and Oceans Canada.
To counter some of the misinformation. Victoria’s sewage is not raw – it has preliminary treatment designed by civil engineers with fine screens (6 mm) and is then discharged through two 60 meter deep outfalls with long diffusers that ensure that the effluent is rapidly oxygenated. 130 Million Litres sounds a lot but as Dr Jack Littlepage showed eloquently last year this is less than “a drop in a bucket” when he showed that that there is the equivalent of 10,400 tankers per hour flowing out of the Strait of Juan de Fuca and that Victoria’s sewage flow is 1/10th of a tanker per hour. Victoria’s effluent is miniscule compared to the incredible volumes of seawater and Fraser River water travelling out of the Strait, along the Canadian shore to the Pacific Ocean. As Dr Jay Cullen has calculated it is 0.001% of the natural flow of water into the Strait of Juan de Fuca. This means that it is the equivalent of one drop in a 5 litre bucket of water (1 drop is 1/20th of an ml).
The closure of the coast line to shellfish harvesting has been given as a reason for treatment. This misinformation fails to mention that Victoria’s shore line, like any other urban area, will always be closed to shellfish harvesting due to the shoreline contamination from the storm water drains from road and other sources in the rainwater drains.
Victoria’s source control program has been highly successful in reducing contaminants in the sewage as is shown by the annual marine monitoring reports. If there is concern for the marine environment what is now needed is a source control program for the rainwater discharges that occur to the shoreline around the coast.
The fish toxicity test has often been mentioned – but what is not mentioned is that this test is performed using freshwater trout that are held in a container of seawater. This test is inappropriate for salt water. It also fails to acknowledge that fish naturally will swim away from any discharge where there is insufficient oxygen or substance that may be unappetising.
The TBSEF report suggests that what Victoria is doing is the same as 1894. This is far from the truth. The current civil engineered designed deep sea outfalls with diffusers and fine screening was installed about forty years ago and are very effective in ensuring the effluent is treated naturally by the marine environment.
It is suggested that spending $782 Million on land based treatment there may be some benefit. What needs to be acknowledged is that no one has been able to define in measurable terms what will be the benefit to the Marine Environment in Victoria’s unique situation.
B.C’s Ministry of Environment staff have even told me that we have to take a “one size fits all” approach because we do not have the resources (staff) to carry out site specific risk assessments. I find that a really weak argument when we are dealing with potentially spending $782 Million. When the US EPA was established in 1970 this “one size fits all” is the approach they took. Ten years later they realised that this approach was wrong and as the EPA administrator William Rukulshaus said “It is time we took aim before we shoot”. Are we really that many years behind in Environmental Regulation in Canada?
There are wonderful things you can do after you have built sewage treatment plants and there are many large and small engineering firms waiting in the wings to apply the latest technology – heat and energy recovery, creating methane gas that can be burned, recovering even metals. However this all comes at a cost to the taxpayers – the more of the latest technology that you use usually there is a greater up front capital cost. We must keep reminding people that we do not need to build the treatment plants in the first place. You can be sure if you build them there will be calls on the taxpayers dollar for more “add ons”.
The World Health Organisation publishes guidelines for the safety of wastewater, when there is human exposure (or contact) – like drinking the water or bathing. What is different for Victoria is that there is virtually no human contact either direct or indirectly (for example consuming fish) to the deep sea discharged plume. The Canadian Recreational Water guidelines are not exceeded at the surface over the plume where you can occasionally detect bacteria that may have originated in the then highly diluted plume 60 meters below the surface.
It is of interest that the World Bank recommends deep sea outfalls where what they call the “autopurification” capacity of receiving bodies needs to be taken into account. The World Bank references the low public health risk, supported by the World Health Organisation, when these outfalls are properly designed as they have been for the marine environment off Victoria.
The TBSEF trumpets the “its illegal” message. What they should be reminded of is that the Federal Fisheries Act has for years had fines for discharging anything that is deleterious to fish into the Environment. For Victoria this has never been applied because there was disagreement between the Province and the Federal Government on its application. The Provincial regulations allowed for a 100 meter initial dilution zone. At 100 meters to-day from the diffusers at the end of the deep sea discharge Victoria meets the proposed Federal Municipal Wastewater Regulation. You may have seen the remarkable underwater photographs that show an abundance of sea life and fish swimming close to the diffusers at the end of the deep ocean discharge.
I hear that candidates in this upcoming Municipal election have said “It is too late to rethink this project”. Nothing could be further from the truth. Admittedly $25 Million has been spent on planning but nothing has yet been built. There have been no shovels in the ground. Many projects in history have been cancelled even after construction – the Avro Arrow, the Fast Ferries etc. There is still plenty of time to take a second look at this plan.
At this time there is a lot of uncertainty as to the direction of the economy and Canadian Governments who may fund this project are taking a careful look at expenditures on Infrastructure projects. We have not to date been successful in convincing the regulatory side of Government that their regulatory requirements for Victoria’s liquid waste discharge are not based on the best science. I am optimistic that the Provincial and Federal Treasury Boards will take a look at this issue. They will ask the question – “what will be the benefit to the marine and overall environment from building these land based sewage treatment plants? Will there be a cost benefit?” They will be told – “well actually there will be no measurable benefit to public health or the marine environment and further more when you consider the overall marine, land and global environment there will be more harm than good.” They will then say – “given all our priorities we should review whether to cost share this $782 Million expenditure.”
Our provincial government has a budget deficit and is worried about the effects of a slumping worldwide economy. It's slashing costs to try to find $1.6 billion it must repay Ottawa after the Harmonized Sales Tax was rejected in the August referendum.
From my perspective – continuing to remind the public, elected officials in all levels of government that Victoria has a unique Marine environment that treats the sewage effluent naturally is worthwhile. This statement is solidly supported by Marine Scientists and Public Health Officials.
Recently columnist and successful industrialist Gwyn Morgan – wrote in the Globe and Mail and the Victoria Times Colonist a plea for public policy decisions to be based on the best science. I quote:
“Sometimes costly decisions are made in response to public perceptions, even when thorough scientific analysis shows an expenditure would not benefit, or might even harm, the environment. A current example is the proposed $782-million sewage treatment plan for Victoria. The city’s sewage currently undergoes primary screening before being pumped offshore into the Juan de Fuca Strait. Huge tidal flows through the strait drive strong currents that break up and oxidize the sewage quickly and thoroughly. Measurements show that within only 100 metres of the Victoria outflow point, effluent quality as good as that disposed of by much larger cities into rivers of comparatively tiny flow volumes.
An expert panel appointed by the Victoria Capital Regional District found no scientific evidence of significant contamination; and more than 10 marine scientists and six current and former medical health officers have stated that deep-ocean disposal has a minimal impact on the marine environment and no measureable public-health risk. Yet the federal and provincial governments insist that a land-based treatment system must be built. Why? Prophetically, the expert panel’s report signalled that its conclusions might be ignored because of public sentiment based on “ethics, aesthetics or other factors that cannot be resolved on purely scientific grounds.”
But the pending victory of public perception over scientific fact doesn’t end there. Although ocean disposal was thoroughly assessed, the environmental impacts of land-based treatment were not. These include using good farm and/or recreational land for sewage treatment plants; odour emissions to nearby residential areas; substantial energy consumption; atmospheric emissions; and surface contamination from treating, transporting and disposing thousands of tonnes of sewage sludge annually.
Public-policy decisions that ignore scientific facts in favour of pressure from vocal minorities can kill job-creating commercial ventures, or cause unnecessary public expenditures. In both cases, society loses.”
Thank you Gwyn for saying it so succinctly.
For members of ARESST there are still plenty of opportunities to remind the public and elected officials at the Federal, Provincial, Regional and Municipal level that this is not a done deal and it is worth a second look. ARESST has achieved a lot in the last four years.
We will continue to advocate for the most Environmentally Sustainable solution for Victoria’s liquid waste.
Thank you,
Dr Shaun Peck
Board Member at Large
The Association for Environmentally Sustainable Sewage Treatment for Victoria.