The following letter was sent to Minister Bennett on April 28th 2010 by Dr Shaun Peck.
To Honorable Bill Bennett,
Minister of Community and Rural Development.
Dear Minister Bennett,
RE: CRD’s Liquid Waste Plan.
I was the Medical Health Officer for Victoria’s, Capital Regional District from 1989 – 1995. Since that time I have followed with interest the demands for sewage treatment and the planning that has recently being carried out.
I was very pleased to see your letter in the 31st March Victoria Times Colonist in which you stated: “the province is committed to funding the best, lowest-cost solution” for the provision of sewage treatment for the Capital Regional District.
I have presented and regularly followed the deliberations of the CRD’s Core Area Liquid Waste Management Committee (CALWMC). Recently the committee was mostly concerned and have held public meetings and received advocacy – most of which has appeared to have been generated by CUPE - about the procurement options. The CALWMC has spent little time discussing and reviewing the overall costs of the proposed land based sewage treatment plants.
On March 25th 2009 the CALWMC passed a motion “that staff be directed to request that the consultants prepare a least cost option for sewage treatment that will meet both the requirements of the Provincial Government and the standards agreed to by the Council of Environment Ministers.”
I have been unimpressed with what has been done to look for the most economic way of meeting the Provincial and draft Federal requirements.
There has it appears been, as far as I can tell, no new attempt to significantly reduce the overall cost and look at more economic alternatives than those provided in the Options 1A,1B,1C document.
There has been a minor reduction in overall cost but the overall preliminary cost estimate is still going to be a huge burden on the local householder through the sewer charge or taxes on each house. It will also be a cost to all of us who are Provincial and the Federal taxpayers.
The CRD is currently meeting the secondary sewage treatment requirements in the BC΄s Municipal Sewage Regulation because the Province allows a 100 meter dilution zone.
It is deceptive and has been mentioned in the media that the Minister of the Environment requires secondary sewage treatment. All Minister Penner did in July 2006 was to order a plan for treatment. It was the CRD who, by Board Resolution in November 2006 resolved to plan for “secondary treatment or better.” There is a difference between land based secondary sewage treatment plants and meeting the provincial secondary sewage treatment requirements. In the Municipal Sewage Regulation the definition of secondary treatment is meeting the outcome, to be met by treatment, to be levels of Suspended Solids (TSS) and Oxygen Demand (BOD).
This is outcome based regulation and is to be applauded because it does not mean a particular technology has to be used.
There seems to have been no attempt by the CRD and their consultants to design a much more economic, engineered, treatment system that would enable the CRD to meet the requirements of the Provincial and the draft Federal regulations.
Since the Minister of Environment’s original order nearly four years ago we have had a major downturn in the world economy. This has resulted in all levels of Government reviewing their expenditure plans.
I am therefore writing to request that you should have your staff examine very carefully the report that has been forwarded to you for your consideration for funding of 1/3 of the Capital and other deemed eligible costs. It appears to me that the CRD wants to buy a “Cadillac” treatment system. Is the Provincial Government really prepared to cost share this? (Some have described it as a “Billion Dollar Boondoggle”). To understand what the cost is locally consider that you could build 14 new Blue Bridges across Victoria harbor for the current proposed expenditure on land based sewage treatment.
Mr. Bennett, your Ministry has to a certain extent been part of the problem. The Ministry commissioned a report on resource recovery (The IRM report.) This raised a lot of expectations but the ministry’s own technical review committee and another external report to the CRD have indicated that building land based sewage treatment plants that would recover resources was not economic – it would raise the capital costs by about 25% and only about 20% of the operating costs would be recovered. It is not therefore in the interests of the taxpayers to follow the claims in the IRM report.
The report and its critique can be viewed at your Ministries site at: http://www.cd.gov.bc.ca/ministry/whatsnew/IRM.htm
I have asked the CRD why they are still planning to commit taxpayers to resource recovery when it is just an add-on cost and it is not cost effective but my comments up to now seem to have fallen on deaf ears.
The second influence is the compelling science that indicates that Climate Change and Global Warming is occurring and all measures need to be taken to reduce the emission of Green House Gases to the atmosphere.
This has been examined by the CRD’s consultants. In spite of the fact that offsets are being claimed, based on an accepted methodology, there will still be a significant carbon foot print produced by the current plan. The emissions still occur even though offsets may be claimed. The estimated C02e emissions are 40,000 Tonnes per year or 1.6 Million Tonnes over 40 years. The annual emissions, based on one set of calculations, are equivalent to the C02e put out by 7,736 automobiles per year.
It is inappropriate to claim carbon offsets in this situation where any emissions can be prevented in the first place. To understand these issues better an excellent film and graphic description has been created that exposes the fallacy in the Cap and Trade approach. This has some relevance in the plan for land based sewage treatment plants. See: http://www.storyofstuff.com/capandtrade/
I hope that the Provincial Government will review this issue because if you consider the marine, land and global environment building land based sewage treatment plants will have more of an impact on the overall environment than the current natural treatment with the engineered deep sea outfalls.
A third influence that has occurred in the last four years is the realization that water conservation continues in the region and this means that there is less water getting into the sewers. A presentation to-day ( April 28th) by Engineers David Langley and Bob Furber to the CRD’s CALWMC demonstrated that the consultants were not adequately considering this in their predictions for sewer plant design in the future.
What therefore am I recommending?
That you’re Ministry requires the CRD to design a more economic treatment method that would meet the Provincial and draft Federal outcome requirements. This might include modifying the current deep sea outfalls – such design changes as 2 mm screens or extending the outfalls or planning to create dispersion of the effluent prior to discharge through the outfall diffusers. It might avoid having to build the proposed two additional outfalls. The need for a plant in the Saanich East location needs to be justified as to why it cannot be eliminated from the plan.
From what I can determine the dramatic reduction in sewage flows from the CRD's highly successful Water Conservation Program has not yet been fully factored into the overall design. This must be done. Flow reduction is so dramatic that the there is now sufficient excess capacity at the proposed Macloughlin plant to handle all of the Saanich East sewage and still handle all of the sewage from the fast growing Western Communities until well after 2020. In other words, the small but costly Saanich East plant is no longer needed and the Western Communities plant can be postponed for one or two decades. The economies are significant.
The CRD’s report that has been forwarded to you states that the plan will protect public health and the environment. This latter statement is not true – there will be a negative impact on public health and the overall environment from building these land based sewage treatment plants.
With the current deep sea outfalls the sewage is treated naturally and there is no measurable effect on public health and a minimal environmental effect on the ocean floor.
There are many exemplary water and waste water initiatives being carried out by the CRD and member municipalities which are all helping protect public health and the environment. These include – safe drinking water, greatly improved water disinfection, water conservation measures, reserved watershed areas for the future, provision of an excellent sewer source control program, many initiatives to prevent inflow and infiltration to sewers, more attention to rain water runoff and storm water drains that discharge directly on to the beaches.
Inspite of artificial deadlines that have been set there really is no need for haste in this project because at the end of the day if and when something has been constructed there will be no measurable benefit to public health or the environment.
Yours truly,
Dr Shaun Peck,
Medical Health Officer for the CRD 1989-1995,