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Dr Shaun Peck's presentation to the CRD's Core Area Liquid Waste Management Committee October 13th 2010.

 I am addressing agenda item #6 – the Land suitability for what is being called a “Biosolids Energy Center.”

 It is commendable that there is an effort to try and find a site that is closer than the 14 KM from McLoughlin point for the treatment of the sludge created by the currently planned land based sewage treatment plant. This hopefully will save capital and operating costs and reduce energy consumption.

 In my reading of the report and the staff recommendations I am concerned that there is no technical (a.k.a.) Engineering recommendation as to what might be the preferred sites to be considered. Surely there should be a staff recommended site?  As the elected officials should not you be requiring a technical recommendation based on all the criteria considered. This therefore may be a report with good technical analysis by the selected criteria – Elevation, Land use compatibility, Ecological integrity, construction conditions, slope stability, slope steepness, suitability for barge landing, proximity to truck routes and archeology and heritage features.  There is however no recommendation of preferred sites, only colored maps showing where a preferred site may be.

 Is the reader expected to conclude that the Hartland North site is the preferred site because there has been no recommendation for consideration of any other site?

 I do not see an analysis on energy use (pumping), cost of piping, disruption of communities because of piping etc?

 I would give the consultants good marks for their maps which enable the ready to better understand their analyses.

 Eventually the Committee is going to have to consider the whole issue of sludge, its environmental impact and whether the suggested disposal of the biosolids has any potential for revenue generation. From my understanding potential revenue generation from disposal of the biosolids – in cement kilns, pulp mills or other sites as a fuel is hypothetical.

 From my personal knowledge sewage treatment plants in Europe actually have to pay to dispose of the biosolids on farmland. 

 It is stated in the report that the proposed plant will process sludge in Thermophilic anaerobic digesters to produce pathogen free biosolids. This will require a great deal of energy as it does in the present Saanich Peninsular Sewage Treatment plant. Here heat treatment is used to ensure the killing of Nemotode worms that may affect potatoes when the biosolids are spread on the land on the Penninsular or sold to the public as garden fertilizer.

 If however the biosolids are eventually being burnt as fuel it does not make sense to expend the energy to make them pathogen free as the burning will kill any biological pathogens.

 I find it deceptive to call it a “Biosolids Energy Center”. It gives the impression that its purposes is either to create or use energy. This is not the case. The purpose is to treat and dispose of the biosolids and recover some energy if economically feasible. A better title might be “Biosolids processing or treatment center”.  

 The very preliminary cost estimate announced is now $782 Million with operating costs of $14.5 Million a year and revenues of $3.1 Million a year.  There will, I assume be reports in the future to revise this figure as with no clear decision on the location of the so called “Biosolids energy center”  and current discussion of even building a pipe across to the Western Communities these preliminary costs are going to change.  

 You have made some progress – the $782 Million is now only the cost of eleven blue bridges - the subject of the City of Victoria referendum on November 20th.

 Is the proposed trucking or barging of the treated sludge for incineration in the lower mainland really the best solution?  It is stated in the report that “The cement kilns in Greater Vancouver can burn the biosolids as a coal substitute, improving the wastewater management project’s carbon footprint.”  Let us be more honest about the carbon footprint.  It will not improve the carbon foot print. Offsets are claimed but this is a sham as it does not reduce the original carbon footprint.  The annual emissions, based on one set of calculations, will be the equivalent to the C02e put out by 7,736 automobiles per year.

 I remain hopefull that there will be an analysis of the impact that would be created, on the overall Environment by the proposed land based sewage treatment plants, compared with the current minimal effect on the Marine environment that occurs with the two deep sea outfalls.  Land Based Sewage Treatment Plants for Victoria will have a net adverse effect if the Marine, Land and Global environment is considered.

 Thank you, 

 

Dr Shaun Peck, Public Health Consultant

Member of Responsible Sewage Treatment Victoria  www.rstv.ca  

Board member of the Association for Responsible and Environmentally Sustainable Sewage Treatment. www.aresst.ca