Presentations to CRD March 24th 2010

This page has presentations made by Dr Shaun Peck, Mr Stuart Hertzog and Mr Bob Furber to the CRD's Core Area Liquid Waste Management Committee on March 24th 2010

Presentation by Dr Shaun Peck.

Thank you for the opportunity to speak to you again.

I am really concerned that the public discussion around agenda item 7 has been mostly about the procurement options and not about the overall costs of the proposed land based sewage treatment plants.

On March 25^th 2009 you (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 l 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.

In this 150 page document that you are considering to-day for forwarding to the Minister of Community and Rural development there has 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 previously in the Options 1A,1B,1C document.

I accept that in agenda item 6 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.

I would like to remind you that the CRD is currently meeting the secondary sewage treatment requirements in the Municipal Sewage Regulation because the Province allows a 100 meter dilution zone. It is deceptive to say the Province requires secondary sewage treatment. 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 is meeting the outcome, to be met by treatment, to be levels of Suspended Solids (TSS) and Oxygen Demand (BOD).

What I really like is this outcome based regulation because it does not mean a particular technology has to be used.

There seems to have been no attempt to design a much more economic, engineered, treatment system that would enable you to meet the requirements of the Provincial and the draft Federal regulations.

Since the Minister’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.

When senior Governments look at to-days report are they not going to say – surely the CRD wants to buy a “Cadillac” treatment system. Are we really prepared to cost share that? (Some have described it as a “Billion Dollar Boondogle”). To understand what the cost is locally consider that you could build 14 new Blue Bridges for the current proposed expenditure.

Why are you still wanting to commit taxpayers to resource recovery when it is just an add-on cost and it is not cost effective. (You have had at least two consultants give that opinion).

The second influence is the compelling science that indicates that Global Warming is occurring and all measures need to be taken to reduce the emission of Green House Gases to the atmosphere.

Inspite 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.

What therefore do I propose to you to-day?

Firstly consider whether you really want to forward this report without having tried more diligently to reduce the overall cost.

Secondly – ask the consultants to design for your consideration 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. It might avoid having to build the proposed two additional outfalls.

Today’s report (agenda item 7) 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 environment from building these land based sewage treatment plants.

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 when something has been constructed there will be no measurable benefit to public health or the environment.

Thank you,

Dr Shaun Peck, Public Health Consultant

Member of Responsible Sewage Treatment Victoria

www.rstv.ca

Member of the Association for Responsible and Environmentally Sustainable Sewage Treatment.

www.aresst.ca

Presentation by Stuart Hertzog

Good morning and thank you for the opportunity to speak. My name is Stuart Hertzog.

I have come here today to tell you that the Business Case before you is incomplete, misleading, and deficient. You should not vote on this today. You should defer it.

It is as full of holes as a Swiss cheese. It is hugely expensive, smells worse than a Swiss cheese, and offers no social, financial, or environmental benefits to the taxpayer.

When I spoke to you recently about procurement, I suggested that you would likely vote for a hybrid solution in which the two plum biosolid plants would be privatised, while the costly supporting infrastructure would be publicly owned.

It appears that I may be correct, as this Business Case recommends the hybrid option. But strangely, it goes even further, recommending that the biosolids plants be publicly owned, while any resource recovery options be offered to the private sector. This is very puzzling.

This may be an acceptable political compromise, but it will not produce an efficient and integrated system.

Whether this peculiar approach is acceptable to the province, remains to be seen. There may not be enough "P" in this Business Case for the province's politicians.

Although the Business Case still maintains the illusion that the central biosolids facility will be at the Hartland Landfill, apparently this is just a placeholder. It also suggests that "an alternate biosolids processing and resource recovery facility site is still under consideration, which may allow consolidation of some liquid treatment as well as solids treatment."

Is this the mythical Upper Harbour/South Bay site? Where is this harbourside site? South Bay? Rock Bay? Down-By-the Bay?

Members of the committee, you cannot proceed with public engagement until the exact site and technology are known -- but that is what you plan to do. To make matters worse, you have engaged Stantec to manage public involvement around this facility. This is extremely bad public process, as many people do not regard Stantec as neutral. Stantec should not have been offered this crucial public engagement contract, especially as it was awarded apparently without going out to tender.

The Business Case suggests that the CRD has conducted "extensive due diligence, planning, and analysis into resource recovery," which is "fully documented in CRD’s online archive." But it offers no details -- no market studies, no letters of interest -- just an archive of several years of very expensive reports: millions of dollars worth of reports.

How much has the CRD spent on consultants and staff time in compiling this mountain of paper? Is this counted as part of the CRD's contribution to the overall cost of the project? And will the province reimburse the CRD for the extra cost of considering the P3 option?

I note that last week, the City of San Diego was given permission to continue with ocean disposal by the California Coastal Commission. San Diego spent just $2million to achieve that result. How many millions have you spent so far, without a satisfactory or sensible outcome?

This Business Plan suggests that the CRD may do this, or it may do that -- but doesn't say exactly what benefits would be achieved after spending a billion dollars of taxpayers' money. Clearly, this business plan is incomplete. Lacking details, it's just a bunch of vague promises.

A business student submitting such a business plan would be given an "F." The province should return this seriously flawed Business Case to you for more detail.

Finally, this Business Case makes misleading and inaccurate claims around environmental benefits. The amended permit for the City of San Diego I just mentioned, removed language that suggested San Diego’s ocean sewage disposal could be creating environmental problems.

The Minister of Environment has never proven that on-land sewage treatment is necessary, or that it offers environmental benefits over ocean disposal. This entire project has been politically mandated as part of the BC government's drive to privatise all government services.

Minister Penner is attempting to avoid any public environmental assessment by directing it to be administered under the Environmental Land Management Act, which was originally written to regulate only conventional sewage filtration, before biosolid technology came along.

This Business Case skates over the many environmental impacts of biosolid production, transportation, and disposal, and on that ground alone, you should reject it.

Members of the Committee, you are all municipal politicians. You must be aware by now that there is considerable public interest in how you vote today. You have functioned so far mostly out of public purview -- but that grace period is now ended.

You have awakened the sleeping dragon of public wrath. Be careful how you vote today. The public is watching you. You must reject this flawed Business Case. It will not work. It must go.

Thank you.

Stuart Hertzog

Presentation by Mr Bob Furber.

Chair, Members of the Committee: My name is Bob Furber. Thank you yet again for the opportunity to speak. As you are aware, I have many concerns about our current Sewage Treatment plans. Today it is about Resource Recovery.

I am baffled as to why the Business Case is still being presented as if Resource Recovery was actually going to happen. The Resource Recovery reports for Downtown and UVic have already made it clear that heat recovery and water reclamation are not economically viable, yet the Business Case appears to be totally unaware.

I realize, the Downtown report contained a hint that heat recovery might be possible in future redevelopment of the area north of Pandora, but this was largely wishful thinking. Why is it wishful thinking? Because it does not make sense to mix warm gray waters with cold black waters, cool the mixture in the sewers and then try to extract the heat – especially in view of the alternative of recovering heat directly from warm gray waters before they hit the sewers. This is but one of several reasons why district heating in this plan will not work. It is a futile attempt to force a square peg in a round hole.

But, despite the absence of an opportunity for practical heat recovery or water reclamation, and the recognition of this fact by the committee, the Business Plan still incorporates resource recovery. It commits about $60 Million for interfaces to permit possible future recovery without any evidence that such recovery will ever become practical. It shows an additional $2.3 Million per year to operate these interfaces with the hopes of generating $1 Million per year in revenues from outside parties – parties that if the Provincial plan is approved will be the only ones to profit. Excuse me: You propose to invest $60 Million in capital plus $2.3 Million per year for the dream of recovering $1 Million? Can someone explain to me how this is in the public's interest?

Regarding other suggested forms of resource recovery, I understand the Ernst and Young market study is now available, although it has not yet been reviewed. This committee should take a very close look at that document before committing $60 million to resource recovery programs.

Further to this issue, now that Resource Recovery has been virtually eliminated as a justification for a Saanich East plant we have been presented with a new justification: that the McLoughlin plant cannot handle the extra 11.1 ML/d generated in Saanich East. Please note that extra capacity was recently discovered there to take half the sewage from the Westshore – a need that could be eliminated at a significant cost saving by enlargement of the proposed Upper Harbour plant. The savings would be enormous. I suggest that there is no longer any justification for the Saanich East plant and it should be eliminated from the Plans.

These Business Plans, as presented, should be withheld until these and numerous other concerns are addressed.

Thank you,

Bob Furber

Member of the Association for Responsible and Environmentally Sustainable Sewage Treatment