On May 17th 2011 John Bergbusch, Chair of ARESST, Alex Murdoch, Vice-Chair of ARESST, Dr Jay Cullen, Chemical Oceanographer and Dr Shaun Peck had a half hour meeting with Minister Dr Terry Lake and his staff. The following are the remarks made by Dr Shaun Peck.
Thank you for meeting with us to-day.
From a public health perspective there will be no measurable benefit from building land based sewage treatment plants for Victoria. This fact has been acknowledged by a previous BC Minister of Environment.
I wish to make a plea to you to-day to consider that the original decision to order the CRD to plan for land based sewage treatment was a political decision not a decision based on good science. You have heard from Dr Jay Cullen that the reasons given in your recent letter to me of April 28th about sustainability (annual flow in the Strait of Juan de Fuca), seabed metal contamination, the MacDonald and Smorong report and the proposed wastewater systems effluent regulations just do not hold up to scrutiny by a credible scientist.
As a veterinarian you are aware of how scientific and evidence based decisions are made for animal health, similar to human health. Decisions are made after careful risk assessments.
What we are experiencing in Canada and here in BC is the “one size fits all” approach that the US EPA originally adopted in Environmental policy but then in the 1980s modified it saying “its time we aimed before we shoot”. It is like saying every community has to have so many snow ploughs in Canada or even every dog should be spayed or have its tail clipped.
The documents supporting the “one size fits all” approach in the proposed Federal regulation included a “cost-benefit” analysis.
This 58 page report is titled “Cost-benefit analysis for cleaner source water”.
It is stated that “the policy objective becomes to not only improve surface water quality per se but rather to improve surface water quality in an economically efficient manner”. The report “ is designed to aid wastewater managers at all levels of government to better understand, estimate and communicate the benefits and costs of investments in sewage treatment.” The communication of the benefits for Victoria has not occurred and there appear to be none for our unique situation.
The report was based on studies conducted in Newfoundland and Labrador and New Brunswick. It is suggested in the report that there would be an increase in real estate values, an increase in fisheries, an improvement in public health and an increase in recreational opportunities. None of these apply to Victoria’s situation due to the unique receiving environment.
The regulators have chosen the quantity of BOD and TSS to regulate but in the Ocean environment off Victoria the vigorous mixing and oxygenation by tidal energy eliminates any potential for adverse effects and an increase in BOD and TSS potentially benefits the environment.
There is no question that there are some chemicals of concern, albeit in very small quantities, in municipal sewage but the best solution to removing them is the source control program and further study of what is known about the effects in the marine environment and what happens to each chemical of concern in a sewage treatment plant and in the disposal of the sludge or bio-solids created by the sewage treatment process.
There is still time to push back, make a political decision, and say the decision to build land based sewage treatment plants for Victoria is worth reviewing. The plants will cost more than $782 Million to build and $14.2 Million per year to operate. This is a huge cost.
As you know there have been many studies and reports. In particular the 1994 Shared Marine Waters of British Columbia and Washington Scientific Assessment report to Washington State and British Columbia and the National Research Council’s (NRC) 1993 report “Managing Wastewater in Coastal Urban Areas” National Academy of Science, Washington. D.C. are the most comprehensive and support how Victoria is currently treating its screened liquid waste through deep sea outfalls.
Here are some questions that I urge you and your Cabinet colleagues to make a political decision and have independently reviewed:
- · Are the Federal (and Provincial) regulated measures of TSS and BOD appropriate for application for the marine discharges through the two deep sea outfalls off Victoria?
- · Should not a risk assessment be carried out on this receiving environment prior to applying the proposed regulation?
- · What would be the finding of a triple bottom line assessment (Economic, Environmental and Social) comparing the present liquid waste disposal off Victoria with the impact of land based sewage treatment plants?
- · What will be the cost benefit of building and operating land based sewage treatment plants for the Capital Regional District’s core area?
- · What will be the overall impact on the environment (marine, terrestrial and global) of building land based sewage treatment plants for the CRD’s Core area?
- · What are the priorities for Marine environmental protection for the waters off Victoria and beyond?
Thank you for your consideration.
Dr Shaun Peck
Medical Health Officer for the CRD 1989-1995
Deputy Provincial Health Officer 1995-2004.