The following document was provided by the Georgia Strait Alliance and the T.Buck Suzuki Foundation to prospective Councillors to Victoria’s Core Area Municipalities prior to elections in November 2011. It contains enough truth to appear reasonable but is largely a collection of half-truths and few downright untruths. To provide a credible counter to some of the information presented in these statements RSTV has added comments following each. (Updated July 28th 2012)

Victoria’s Raw Sewage Discharge - Frequently Asked Questions 

How much raw sewage is discharged? 

Victoria and core municipalities, Oak Bay, Saanich, Esquimalt, View Royal, Langford and Colwood, with over 350,000 residents, discharge 130 million litres of raw sewage daily. The sewage is carried through two outfall pipes, 1.1km and 1.8km long, into Victoria Bight and the waters the Strait of Juan de Fuca. 

RSTV Response: 130 Million Litres sounds a lot but it is 99.97% water, has been subjected to preliminary treatment including 6mm screens (6 mm), and is discharged through 60 meter deep outfalls with long diffusers that ensure that the effluent is rapidly oxygenated.  And the volume 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.  Dr. Jay Cullen, a UVic oceanographer, has calculated it is 0.001% of the natural flow of water into the Strait of Juan de Fuca – the equivalent of one drop in a 5 liter bucket of water.(Another way of illustrating this is 130 Million Litres a day is 1 cubic meter per second. The Fraser river average discharge is 3500 cubic meters per second.) 

Don't currents in the Strait of Juan de Fuca dilute the sewage rapidly? 

Contrary to what we’ve been told, the currents near the outfalls do not carry the sewage out into the Pacific. The net current at the outfall depth, 65 meters, is east towards Haro Strait or San Juan Island. Therefore, because currents change direction with the ebb and flow of the tide, a lot of the sewage either stays nearby or flows back into Georgia Strait. Also, dilution does not get rid of what’s in sewage (organics, pathogens like hepatitis, heavy metals or chemicals) and, therefore, it doesn’t prevent the long-term damage to the environment, or the waste of the energy and mineral resources carried by sewage. Further, a 60 square kilometre closure to shellfish harvesting is now in effect due to releases of bacteria and other contaminants from the sewage outfalls, a 50% increase from 2002 (Fisheries and Oceans Canada). 

RSTV Response: Dr Andrea Copping from the Marine Science Laboratory of the Pacific Northwest Natural Laboratory in Washington State has shown that the net flow travels out into the Strait of Juan de Fuca and along the Canadian coast line to the open sea; the source of any counter to her data should be provided.  But the direction of flow is largely immaterial as organic effluent is rapidly assimilated through natural “composting” processes; pathogens do not survive long enough to be of concern; and most heavy metals and chemicals are intercepted at source.  Years of monitoring has shown a minimal effect on the ocean floor, even within meters of the outfalls.   

It is possible to recover heat from sewage before it is discharged, but that does not require secondary sewage treatment plants; in fact recovery for other uses simply diminishes the efficiency of such plants.  Mineral recovery is impractical with present technology and will probably never become practical.

Shellfish harvesting closures are a “red herring”.  There will always be shellfish closures near urban areas because of the contaminants discharged to the shorelines by storm drains and because DFO policy does not permit harvesting near outfalls whether the effluent is treated or not. There is no evidence that the current deep sea discharges are contaminating the shorelines.    

Victoria has concentrated on source control - isn't this enough? 

Source control is an important part of keeping our environment healthy, and responsible municipalities both control the sources of contaminants and treat their sewage. However, according to a Decision Note prepared by the Ministry of Water, Land and Air Protection (MWLAP) staff for the Minister on February 20, 2002 concerning Victoria's raw sewage situation, " source control has limited capacity to reduce contaminants … Treatment is not only more effective in reducing contaminants, it is effective immediately upon implementation and will remove a wide array of contaminants not targeted under source control." Victoria’s 20 year old source control program has had limited success in reducing overall contaminant loading. 

RSTV Response: The CRD’s sewer source control program has been highly successful in reducing or removing a large number of contaminants that were entering the sewage system. For example, because of the requirement for food premises to install traps for oil and grease and to dispose of them in an environmentally sustainable manner we no longer see the grease surfacing off the end of the deep sea outfalls. Mercury originating in dental office has been removed and many pharmaceuticals prevented from entering the sewage stream.

Until recently there has been no program to prevent contaminants entering the rain water drains around the coast line. This is where the shorelines and the marine environment are being contaminated.

There is minimal contamination of the ocean floor around the diffusers at the end of the deep sea outfalls.

Land based treatment may remove or destroy some contaminants but others are simply concentrated in the sludge.

 Isn’t Victoria’s sewage non-industrial, unlike most other cities, so we don’t need treatment? 

Most industrialized cities have a sewer use bylaw similar to Victoria’s sewer use bylaw, which ensures all industrial waste is pre-treated before entering the sewers. These bylaws will ensure that industrial wastewater on a level similar to Victoria’s, however these more industrialized cities also have sewage treatment before discharging wastewater into the ocean or other surface water. 

RSTV Response: There is a mindset that land based treatment will solve the problems of contaminated sewage. A better solution is to improve the sewage source control and put more emphasis on source control of the contaminants entering the rain water discharges. Contaminated rainwater is discharged directly to the shoreline and enters the marine environment. This can be prevented with a rainwater source control program. Increased sewage treatment will have no effect on this except where the rainwater is entering the sewerage system.

There are combined sewers in the Uplands  and  the City of Victoria has a large number of old combined rainwater and sewerage pipes that means that sewage is entering the rainwater drainage system around the coast line. 

But science has not proven that raw sewage harms the environment, has it? 

Yes it has. In fish toxicity tests on Victoria's sewage, the fish died within 20 minutes[1]. In identical tests on pulp mill effluent, fish routinely survive for more than 96 hours[2]. These are just a few examples of the growing amount of independent scientific data (i.e. not conducted by an organization biased against sewage treatment) that supports the need for treatment. 

RSTV Response: Survival tests using rainbow trout fingerlings are commonly used by regulators to measure toxicity, but the practice has been widely criticised by the scientific community as ignoring the nature of a marine receiving environment.  Trout fingerlings will die in a sterile salt water solution, but no one would suggest that such a solution would be harmful to the marine environment.  Generally the trout fingerlings die in sewage due to a lack of oxygen – a condition which vanishes as soon as the effluent enters the highly-oxygenated waters surrounding Victoria’s outfalls.  The test also fails to acknowledge that fish will naturally swim away from areas of insufficient oxygen or harmful substances. 

Victoria has discharged raw sewage since 1894; why change now? 

In 1894, those responsible for Victoria's sewage did what they were first asked to do - get rid of it. In that era, industry also discharged its effluent untreated; but, as our understanding of the effects of industrial effluent discharges changed, so did society’s tolerance for pollution. We now understand that raw sewage includes many harmful pathogens and toxic chemicals – from pharmaceuticals to personal care products to heavy metals. Therefore, environmental laws no longer tolerate raw sewage discharges from municipalities.

RSTV Response: To suggest that Victoria is doing is the same as was carried out in 1894 is absurd.  This is far from the truth. The current civil engineered designed deep sea outfalls with diffusers and fine screening were installed in 1972 (MacCaulay Point) and 1980 (Clover Point) and are very effective in ensuring the effluent is treated naturally by the marine environment. The World Bank calls this “autopurification”. Monitoring of the seafloor has shown a minimum effect on the environment.  There is no doubt there are human pathogens in the initial sewerage but they become highly diluted and do not survive for more than 100 meters in the cold salt water. Traces of pharmaceuticals, metals and personal care products have been detected by monitors, but at concentrations well below accepted safe levels. The lack of heavy industry in Victoria, combined with good source control, means that toxic chemicals are not a serious problem in Victoria; in fact the screened effluent (undiluted)meets the Canadian drinking water standards for metals, in most cases being below the maximum amounts by a factor of 1,000 or more.

Of more concern is the much higher concentration of chemicals of concern in the sludge produced by secondary sewage treatment plants. 

 

 

Shouldn't we wait for better technology? 

Treatment technology will always be improving, and doing nothing is no longer an option. We have the technology to treat our sewage. We know that secondary sewage treatment kills most pathogens, removes a large amount of organic matter, as well as many chemicals such as heavy metals and PCBs and keeps them out of the marine environment. 

RSTV Response: No-one suggests that we should do nothing.  But treatment system designs should be adapted to the local environment, taking into account the nature and volume of sewage and the nature of the receiving waters.  Secondary treatment is not a one-size-sits-all solution, although it is certainly the most common:  sometimes some form of tertiary treatment is required [as at Calgary or Vernon], sometimes primary systems are enough [as at Honolulu or San Diego], and occasionally [as at Victoria or the Channel Island of Guernsey] a combination of preliminary treatment, source control, and offshore diffusers is the most effective.   Most first-world jurisdictions [including the UN, EU and US] recognize this.

The question that should be asked is why do we need a better technology for Victoria’s sewage treatment atall?  The current technology is very effective in enabling the Victoria’s sewage to be assimilated (autopurified) by the unique marine environment off Victoria. There is no question that there are many emerging technologies of interest that can be used when needed. The need should be determined after an assessment of the receiving environment. For all the technologies there is a toxic sludge produced which then has to be disposed of or treated using increased energy but also from which energy can be recovered. These technologies impact both the land and the global environments.  

Isn't sewage treatment too expensive in Victoria? 

The sewage treatment plant will cost money, an estimated $782 million, though this cost should beshared equally with the provincial and federal governments. It will also provide economic benefits to the community during plant construction and operation. The gains to tourism may be harder to measure, but they are no less significant. Can we really afford not to protect our marine environment? Is it really an option to go on ignoring Federal and Provincial environmental laws? 

RSTV Response: Is it really worth spending $791 Million (The most current published estimate of capital Costs) and $14.5 Million (annual operating costs) on a major engineering project where there has not been defined any measurable benefit ? At this time it seems that Provincial and Federal Treasury Boards have taken a look at this issue and have postponed any decision on funding their share of 1/3 of the capital costs. They should 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 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 $791 Million expenditure.” 

Should Victoria hold a referendum on this issue? 

The waters that are affected by Victoria’s discharge belong to all citizens of Canada, not just the CRD. Therefore any referendum would need to be Canada wide and ask all Canadians to support a special polluter exemption for Victoria. This would be a ridiculous exercise given that all polls in the last decade show over 70% of people inside the CRD support treatment, and the non-trivial matter of contravening existing laws. 

RSTV Response: In 1992 a referendum was held in the capital region and the plans for increased land based sewage treatment at that time were defeated.  However it is noted that the BC Environmental Management Act was changed to state (Section 24(7)) “Despite anything in the Community Charter or the Local Government Act, if a waste management plan (a) is required under subsection (2) or (3) (a), or (b) has been approved by the minister under subsection (5),a bylaw adopted by a municipality for the purpose of preparing the waste management plan referred to in paragraph (a), or implementing the waste management plan referred to in paragraph (b), does not require a petition, the assent of the electors or the approval of the electors.

The statement “the waters….belong to all citizens of Canada” should be clarified according to international law. Does anyone really own the waters?  

Why is Treatment Needed? 

Environmental and Human Health Impacts 

1. It's Toxic: Apart from the astonishingly high levels of Biological Oxygen Demand (BOD) and Total Suspended Solids (TSS)[3] in untreated effluent, many of the chemicals contained in Victoria’s sewage, such as ammonia and nitrite, are known to be toxic to fish and other aquatic organisms; 28 contaminants have been measured in the effluent at levels that exceed guidelines established for the protection of fish and aquatic life (Golder Associates Ltd. 2005). 

RSTV Response: The cBOD and TSS are used by Provincial and Federal Regulators to determine effectiveness of treatment. At 100 meters from Victoria’s deep sea outfall diffusers these proposed regulatory level parameters (cBOD and TSS) are met based on reports from the CRD’s Scientific programs. The 2010 Marine Monitoring report published by the CRD says that all the contaminant levels on the ocean floor are below the regulated levels.

It should be noted that the correct terminology is “Biochemical Oxygen Demand” for the cBOD measurement.   

 

2. Risk to Public Health: According to Capital Regional District (CRD) reports, the CRD's engineers, and Environment Canada studies, sewage carrying faecal coliform bacteria does rise to the ocean surface for as many as eight months per year. Wind surfers, leisure boats, eco-tourist, fishing, and other vessels routinely travel through these polluted surface waters, exposing the public to third-world health risks. 

RSTV Response: The very dilute plume does surface occasionally throughout the year as measured by individual faecal coliform counts. To determine Public Health Risk of disease there is the requirement for a mean level of five readings to be calculated. When this is carried out the levels are below that which is considered a health risk by the Canadian Recreational Water Guidelines. The CRD has published an extensive report that demonstrates that there is a minimal risk of human exposure to even the dilute plume.      

 

3. Victoria Fails World Health Organization (WHO) Guidelines: Victoria's sewage situation doesn't even meet the basic WHO guidelines for wastewater treatment in developing countries. 

RSTV Response: This is incorrect. The World Health Organisation has determined that sewage disposal through deep sea outfalls is appropriate when the receiving waters are able to “autopurify” the effluent as is occurring off Victoria. Furthermore the World Bank, based on the risk assessment by the World Health Organisation approves deep sea discharges of sewage with preliminary or minimal pre-treatment for many cities throughout the world. Victoria’s discharge would almost certainly meet current EU standards. 

4. Food Chain Contamination: Some of the chemicals in Victoria’s sewage, such as PCBs and mercury, can accumulate in fish and marine invertebrates, representing a major hazard to wildlife. Although experts can't agree on the most significant sources of PCBs in ocean waters, Victoria's sewage contribution of several kilograms per year is a notable contribution to the contamination. 

RSTV Response: There is no question that very small amounts of chemicals can be detected in marine organisms that are close to urban areas as a result of these chemicals in sewage and storm water runoff.  What has not been determined is at what levels certain chemicals cause harmful effects. To say this is a “major” hazard is an overstatement and cannot be supported by facts. Each chemical needs to be analysed as to whether it can be eliminated at source, whether it will be affected by secondary sewage treatment, will it be accumulated in the sludge or will it be water soluble and still discharged into the ocean after treatment. It should be noted that there has been a significant reduction of Mercury detected in Victoria’s sewage as a result of the source control program in dental offices. 

 

5. Harm to the Environment: The long-term impact of dumping raw sewage into the ocean is unpredictable, but seabed contamination studies already show serious impacts[4], including acute toxicity to marine invertebrates. If society doesn't allow industry to pollute in this way, how can we tolerate polluting behaviour from our own government? 

RSTV Response: The following statement is from the CRD’s Scientific Programs 2010 Marine Monitoring report and indicates that there is a minimal effect on the marine environment. “Substances that were detected frequently in 2010 included conventional parameters, metals, some PAH’s, phthalates and phenols. Concentrations of these compounds in the ocean were predicted using dilution factors from a custom oceanographic computer model and then compared to the BC Water Quality Guidelines (WQGs). Results were all below WQGs after the predicted environmental dilution was taken into account, with most concentrations below guidelines even in undiluted waste water.”  

6. Contribution to Greenhouse Gases: As untreated sewage decomposes, it generates carbon dioxide and methane – which are greenhouse gases. Enough methane gas could be recovered from Victoria’s sewage to run a large number of Victoria’s buses, reducing reliance on fossil fuels and overall greenhouse gases. The Greater Vancouver Regional District’s (GVRD) sewage treatment plants recover enough energy to generate 7 megawatts of electricity, worth over $1.6M/year.  

RSTV Response: There is no doubt that construction and operations of secondary treatment plants would significantly increase the discharge of greenhouse gases, whereas the present system has minimal GHG impact. The most efficient fully-integrated plants are able to recover up to 80% of their operational energy needs. The proposed CRD system, with the sludge treatment plant located 18 Kilometers from the primary treatment plant, would be much less efficient.  There will be no net energy surplus. 

 Legal Issues 

7. It's Illegal: Dumping raw sewage is against the law, and Victoria residents and others are increasingly aware of this fact. Tests show Victoria's sewage kills fish; the current situation contravenes the Federal Fisheries Act and the Provincial Waste Management Act.  

RSTV Response: Lobby groups such as the Georgia Strait Alliance have long alleged that Victoria’ sewage discharges could contravene section 36(3) of the Fisheries Act, which prohibits “deleterious substances” from being discharged into the marine environment.  However, in the absence of evidence of any actual harm, regulators have not taken any action.  Until 2006 Victoria was fully in compliance with Provincial regulations, and the only thing which changed was an order by the Provincial Minister [who is not legally required to justify his action] that the CRD submit plans to treat its sewage.  

8. Liability: Environment Canada has considered charging Victoria under the Fisheries Act, but so far has worked hard to change Victoria’s raw sewage discharge without resorting to legal actions. Acting now to get secondary sewage treatment will also reduce the risk of US parties taking legal action (Washington State farmers vs. Cominco in 1993; EPA and Colville Confederated Tribes vs. Tech Cominco in 2004).  

RSTV Response: It may be that Environment Canada has not charged Victoria under section 36(3) of the Fisheries Act because they are aware that within 100 meters of the diffusers Victoria meets both present and the standards in the recently proclaimed Wastewater Systems Effluent Regulations.  It would be interesting to determine whether any US parties have the authority to take action against Victoria, but if they did they would have to prove their case.  If the best science were to be used, a good starting point would be the joint Canada/US Marine Science panel report “The Shared Marine Waters of British Columbia and Washington” 1994, which indicated that land based sewage treatment for Victoria was not considered a priority.  

9. Uneven Enforcement: The CRD is being given preferential treatment when it comes to enforcement of environmental laws, and this is not lost on other municipalities and the BC business community. Victoria's unregulated sewage discharge places a loading on the environment equal to all of the kraft pulp mills in BC combined, concentrated around Victoria's harbour. All sewage treatment plants in BC, including the CRD's own sewage treatment plant in North Saanich, pay permit fees based on BOD, TSS, and discharge volume, and if they exceed their permit, charges and fines are applied. Victoria however does not. Why? Also, Environment Canada has seen fit to lay charges again Dawson City, North Battleford and Iqualuit for the discharge of raw sewage into the environment, but not Victoria whose offence is far greater than any of these cities. 

RSTV Response: The problem with this statement is that it is biased by the “one size fits all” thinking. A more reasonable regulatory approach is for there to be a risk assessment of the receiving environment (in Victoria’s case the deep ocean with dynamic tidal action) before requiring any extra treatment. Dawson City is on the Yukon River, North Battleford is on the North Saskatchewan River and Iqualuit (in Nunavut, on Baffin Island) is at the head of Frobisher Bay where the sea freezes in the winter. All these three have completely different receiving environments compared with Victoria’s unique deep marine discharges into tidal waters.       

Social and Economic Impacts

 10. Harm to Ocean-based Industries: Those making their living through fisheries, eco-tourism, and other ocean-based industries are being directly affected by ocean pollution. The lucrative swimming scallop fishery off Victoria Harbour has been closed for over 20 years and local whale watch operators’ access to whales has been severely limited, in part, because of the high levels of toxins in local orcas. 

RSTV Response: The Victoria harbor has heavily contaminated sediments due to previous industrial use. This is why even crab fishing is not permitted. This has nothing to do with the deep ocean sewage discharges. The whale watching industry is a year round very successful business from the Victoria harbour. The levels of anthropogenic (man made) persistent organic chemicals in Orcas is a serious concern. Because of the nomadic ocean travels of Orcas it is unreasonable to attribute these levels of concern to Victoria’s sewage discharge.  

11. Harm to Tourism: Victoria's reputation as a polluter does not enhance tourism, especially among the residents of Washington State. In 2003, the BC tourism industry brought in nearly $10 billion; reductions in this revenue because of Victoria’s growing reputation as a polluter will be felt throughout the province. On the other hand, we have an opportunity to become a showcase for advanced sewage treatment and resource recovery processes if we take steps now to treat our sewage.  

RSTV Response: There is no doubt that Victoria’s tourism has been affected by the world economic situation and in particular because of less tourists coming from the U.S. For U.S. tourists there has been a greater financial impact than in Canada due to the exposure to the sub-prime mortgage and other financial difficulties – federal, state and municipal unsustainable debt etc.  It should be questioned as to whether constructing a land based sewage treatment plant within sight of the cruise ship terminal, at the entrance to Victoria harbour, would be considered part of the “show case” for Victoria.  

12. Financial Losses for the CRD: Under the BC Contaminated Site Regulation, the province could force the CRD to not only stop polluting (put in sewage treatment) but clean up the contaminated seabed.  Environment Canada could charge the CRD with violations of the Fisheries Act, and doing so could lead to fines of up to $300,000 per day. 

RSTV Response: The ocean floor at the end of the deep sea outfalls has not been designated a Contaminated Site under BC regulations.  One report [the so-called MacDonald Report] offered a “preliminary” opinion based on an analysis of a very small number of samples. The conclusions of that report have been questioned by scientists.  As noted above, Environment Canada would have to demonstrate actual harm, something difficult to do in the face of years of reports to the contrary. Environment Canada could charge the CRD but it could have done for many years under section 36(3) of the Fisheries Act.  It has likely not done so because it is known that at 100 meters from the outfalls the effluent meets the regulated cBOD and TSS standards.  

13. Pride vs Shame: BC residents and Victorians in particular feel ashamed that one of their major cities operates below third-world standards. An Ipsos Reid Survey conducted for the CRD in 2007 showed sewage treatment as the number one priority for CRD residents. All other public polls conducted in the CRD over the last decade clearly showed majority support among Victorians for moving ahead with sewage treatment.

RSTV Response: There is much to be proud of in our careful monitoring and research of the marine environment that has supported our current system. Other cities are no doubt envious of Victoria, not only because of our unique marine geography that permits our relatively simple and cost-effective approach, but for our continuing initiatives in our "best practices" monitoring and source controls programs.

Shame and embarrassment about our present sewage treatment system are words used often by organizations seeking to exploit natural concerns for our environment, even to the extent that some politicians have been parroting these same words. However, that is not a sound reason to discard our satisfactory sewage treatment system in favour of an unknown leap into an embarrassing morass of financial burdens, with no measurable improvements in our environment. That would be shameful, indeed!

As Dr Jack Littlepage, University of Victoria Oceanographer has stated “Victoria can boast of having the finest and most effective sewage treatment system in North America”.  

14. Leading by Example: How can we convince our children of the value of protecting our environment when we dump the equivalent of 2,600 tractor-trailer loads of raw sewage into the ocean every day?  

RSTV Response: This statement is pure rhetoric and hyperbole.  As stated above 130 Million Litres sounds a lot but as Dr Jack Littlepage showed eloquently in 2009 this is less than “a drop in a bucket” when he showed that that there is the equivalent of the volume 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. It should also be noted that the effluent is 99.97% water. What we should be teaching our children is to learn what is the best science supporting any environmental concern or policy.  

15. Increased Awareness: Canadians are becoming more aware of our impacts on the environment, partly though the education and activism of environmental organizations, and partly through Canada’s participation in initiatives like the Kyoto Accord. In fact, the CRD shows tremendous initiative on other environmental fronts such as recycling. With this kind of leadership in other areas, the public is ready for leadership on this issue too. 

RSTV Response: What is hoped that Canadians will continue to ask what is the best science behind any environmental concern or policy inspite of what may be being said by some environmental organisations. 

Opportunities

 16. Recovery of Resources: Victoria's sewage contains valuable resources: water, energy, and minerals. These resources should be captured and reclaimed, as they are in other modern treatment plants. MOE's website encourages re-use of wastewater, as do the LEED[5] criteria for sustainable building design. Current sewage treatment technologies require less land, and can generate energy through co-generation or provide natural gas to run public transportation.

RSTV Response: It is encouraging that the CRD is working towards the recovery of resources, and the recent initiative for methane gas recovery from kitchen scraps is a potentially cost- effective initiative.  But expensive [in dollars, energy, and environmental impact] reuse of wastewater needs to have a clearly beneficial business case before it is proceeded with. It makes sense for cities in desert environments but not where an abundance of pure water is already available.  

 


[1]  The results of industry standard fish toxicity (LC96) tests on samples of Victoria’s sewage. EVS Consultants 1994.

 2 Other BC municipal sewage treatment plants and industry must conduct fish toxicity (LC96) tests monthly; results are available to the public through the Ministry of Environment. 

[3] BOD and TSS are measurement standards used to describe the state of the effluents. The BOD is "biological oxygen demand", which measures how much the decomposition of organic matter depletes oxygen in the receiving waters, threatening natural organisms' survival. TSS refers to the total suspended solids, which is simply the solid matter suspended in the effluent, which blocks light and effects processes like photosynthesis. 

[4] Golder Associates Ltd. 2005CRD's Wastewater and Marine Environment Program Annual Reports 

[5] LEED - Leadership in Energy and Environmental Design, a green building rating system, is a voluntary, consensus based international standard for developing high-performance, sustainable buildings.