Presentation to the CRD’s Liquid Waste Management Committee November 26th 2008
by Dr Shaun Peck, Member of Responsible Sewage Treatment Victoria.
My comments to you to-day are on the report“MACAULAY AND CLOVER POINT WASTEWATER AND MARINE ENVIRONMENT PROGRAM 2007 ANNUAL REPORT” – to highlight some of the results and mention their relevance to the plans being developed for land based sewage treatment.
The results show that predicted wastewater concentrations in the marine environment met receiving water quality guidelines for the protection of aquatic life and that the potential for sea surface human exposure to wastewaters from the outfalls was low. The seafloor monitoring component showed some effects on seafloor organisms (higher numbers and types of animals) and deep-water mussels (longer and fatter mussels), restricted to within 100m at Clover Point and within approximately 200m east of the Macaulay Point outfall diffuser.
Because all priority substances met applicable Water Quality Guidelines in the marine receiving environment (following the application of minimum initial dilution factors), it is unlikely that significant effects on aquatic life will occur from the substances being discharged.
At Macaulay Point the sediment chemistry monitoring shows that there are some Sediment Quality Guideline exceedences but mostly within the 100m Initial Dilution Zone and these were predominantly Poly Aromatic Hydrocarbons – the source of these is likely gasoline, oil etc. The frequency was lower than 2006. These substances most likely come from street runoff, and storm drain cross-connections.
It is important to note that values above Sediment Quality Guidelines should not be interpreted as equating with adverse biological effects, but only as an indication of potential for effects on the receiving environment.
A special study was carried out to test sediment and mussel tissue samples for substances that are in wastewater and are potentially environmentally persistent, toxic, and/or bioaccumulative. The results were generally below most potential environmental effects thresholds set to protect aquatic life suggesting negligible potential for adverse biological effects in the marine environment.
The overall conclusion is that the impact on the receiving environment are limited both spatially and temporally. The areas of impact are generally within 200m of Macaulay Point and 100m of Clover Point.
As the CRD moves forward with its plans for land based treatment I urge you to consider carefully the results of this monitoring.
The biggest myth that Victoria-area residents believe is that the $1-billion-plus secondary sewage treatment that’s being proposed will remove most chemical contaminants from our sewage and end discharge to the ocean.
The facts are that most treatment methods will remove only a proportion of these chemical contaminants – metals, chemicals, and pharmaceuticals.
The rest of these chemical contaminants will still be discharged into our marine environment through the existing outfalls, while the chemicals which are removed will be concentrated in sludge that will be disposed of on the land or treated in some other fashion.
The best way to keep these contaminants out of the environment is not through sewage treatment, but by expanding the existing CRD’s exemplary Source Control Program.
I urge the CRD to do three things:
1. In collaboration with member municipalities commit to undertaking significant additional expenditures to correct more pressing environmental problems of inflow and infiltration, storm water quality, habitat protectionand removing contaminants at source.
2. To call for a cost-benefit analysis before final decisions are made on the land based sewage treatment plans and
3. When carrying out the “Triple Bottom Line” and environmental impact of the proposed land based sewage treatment plants do the analysis so that it includes the overall environmental effect on the Marine, Land and Global environment – including the minimal impacts demonstrated in to-day’s report.
It is the view of members of Responsible Sewage Treatment Victoria that the land based treatment plants will result in measurable environmental damage. During construction and operation, the treatment plants will create significant amounts of greenhouse gases. Treatment will leave behind a toxic sludge in which contaminants are concentrated, with its associated disposal problems. Scientists say these harms would easily outweigh the negligible benefit to the marine environment.
I appreciate the CRD is moving forward with a planning process ordered by the Minister of the Environment and that you are keen to take advantage of Federal and Provincial assistance for funding the capital costs. However before any final decisions are made I urge you to consider the overall environment and what may be limited cost-benefits.
Members of our group would be pleased to meet anytime to discuss these issues with the new members of the CRD Liquid Waste Management Committee and Board.
Thank you for your time to-day.
Dr Shaun Peck,
Member of Responsible Sewage Treatment Victoria
Comments to the CRD Liquid Waste Management Committee Wednesday November 28th 2007. Dr Shaun Peck
My comments are on three of the staff reports before you to-day.
First - the Site Identification and Evaluation Update report. It is a positive step that the environmental impacts of the proposed land based liquid waste treatment plants are being assessed. These proposed plants are going to be removing solids in the form of sludge from the liquid stream which is 99.97% water.
The public and governments are becoming increasingly concerned about any activities that are going to impact future Climate Change. It is a positive step that there is to be an assessment of Green House Gas Production and Energy use by these proposed plants during their operation. I urge you also to ensure that this includes Greenhouse gas production during the construction phases. You may be aware that when one ton of cement (which is used to make concrete) is manufactured the process releases approximately one ton of Carbon Dioxide into the atmosphere. There will be many thousands of tons of concrete needed for the proposed sewage treatment plants.
My request to you on the $10 Million borrowing bylaw report for less than 1% of the estimated $1.1 Billion capital cost of this Mega Project is that you continue to inform the taxpayers on the impact of this on the local (home owner) tax base and also provincial and federal tax payers. After all it is the taxpayers who will be paying for this. They deserve to know how their tax dollars are being spent. Taxpayers would also like to know what will be the benefits of this expenditure.
The results from the 2006 Marine Monitoring report. This is a very important report from the perspective of those of us who have been trying to get more attention paid to the minimal environmental impact of the present practice of discharging the liquid waste through two deep sea outfalls after screening and a world class source control program.
Results of the 2006 monitoring shows that very low contaminant levels in the marine environment met receiving water quality guidelines for the protection of aquatic life, and that surface waters off the outfalls were not at levels of concern for human health.
The seafloor monitoring component shows some effects on seafloor organisms (higher numbers of animals and types of animals) and deep-water mussels (longer and fatter mussels), restricted to within 100 to 200m at Clover Point and within approximately 200m southeast of the Macaulay Point outfall diffuser. Those effects are not detrimental.
Between 1990 and 2006 at Macaulay point concentrations in sediments have gone down over this time for a number of substances. These include nickel, zinc, lead, several polycyclic aromatic hydrocarbons (PAH) and 1,4-dichlorobenzene.
At Clover point between 1990 to 2006 a number of substances in sediments have also gone down over this time, including phenol, total phenols and several PAHs. Some substances have shown increases. Enhanced source control strategies are proposed to deal with the substances that have increased.
The 2006 sediment chemistry results are generally consistent with previous years and the recent review conducted by the Society of Environmental Toxicology and Chemistry (SETAC) panel that concluded the sediment chemistry findings do not indicate a negative change over time.
The independent Marine Monitoring Advisory Group (MMAG) reviewed this 2006 Wastewater and Marine Environmental Program. They pointed out that c onditions around the Macaulay and Clover Point outfalls have been found to be similar to the conditions around the outfalls from municipalities with secondary treatment. In view of this, the success of the CRD's source control program, and the apparently small impact of the discharges on the marine environment, members of the MMAG expressed the view that the current scenario for wastewater treatment should have been included as an option in the CRD's "triple bottom line" comparison of different treatment options.
M embers of the MMAG also expressed the view that land-based treatment should not be a high priority in measures to protect the marine environment and human health. They argued that far greater return for an expenditure of several hundred million dollars could be obtained from other actions.
I would like to complement the CRD on this very interesting (if highly complex) staff report that outlines as objectively as possible the, I would say, minimal effects that the current deep sea outfalls are having, after screening and source controls. It also outlines further research being carried out and some enhancements to the source control program.
Before the decisions are made on the expenditures of the remaining 99% of the initially estimated $1.1 Billion I would urge you to compare the information contained in this comprehensive Wastewater and Marine Environment Program Report with the emerging information that is being collected on the environmental impact of the proposed land based treatment.
In the view of Responsible Sewage Treatment Victoria (www.rstv.ca) the priorities for treatment of the Core and Westshore area’s liquid waste, to protect the marine environment and public health, should first be to a) Place more emphasis on the storm drains that are discharging liquid waste around our shorelines particularly at times of heavy rainfall b) Continue to enhance the source control program.
Thank you.
Dr Shaun Peck's comments to CRD Board June 13th 2007.
I speak to you today, out of a sense of duty, as a concerned citizen and City of Victoria taxpayer, and as a member of a group called RSTV – Responsible Sewage Treatment Victoria. The following is an analysis on the costs to the taxpayer of the plan before you today based on a report provided by the CRD of detailed cost estimates. The net present value (NPV) of the total estimated capital and operating costs is $1.142 Billion in 2007 dollars. This NPV reflects the estimated lump sum that would need to be paid, in 2007, in order to acquire the necessary land and build and operate the system for 50 years (from 2015 to 2065). An understandable comparison would be that this capital cost would build six new BC Ferries – like the Coastal Renaissance being delivered this year. The additional municipal taxes needed to cover the full cost of combined capital and operating costs would, if added to local tax bills as an annual charge, be equivalent to $557 per $500,000 of 2007 assessed value, every year for the next 50 years (ranging from $390 to $725, should cost vary plus or minus 30% from the published figures). What would be an understandable comparison? I will quote one example. For the City of Victoria the annual total cost of the police department from the 2007 taxes is $596 per $500,000 assessed household value. We can say therefore that the additional annual cost for land based liquid waste treatment would be similar to the annual cost of operating the Victoria Police Department. Spending $1.2 billion, the figure in the CRD public documents, is something that is not scientifically justified, and it in fact may worsen environmental impacts. This is not evidence based public policy. The energy used (for land-based treatment) would be equivalent to that consumed by 1000-1500 homes’ annual energy use. There will be the need to dispose of the sludge, which must be kept isolated from land-based aquifers. This can hardly be justified on economic grounds. Even if Victorians would pay only 1/3 of the capital costs through property taxes, Canadian or BC taxpayers (including Victorians) would be paying the other 2/3. It surely is not reasonable to argue that we should make our local decision only on the visible local taxes we would pay, ignoring the costs to be imposed (invisibly) onto other provincial and federal taxes. And since Victorians would pay 100% of operating costs, our independent analysis shows that overall, 54% of the combined capital/operating costs would be paid locally, levied on property tax bills. There could potentially be some minor benefits to the tourism sector by providing land based sewage treatment; but nothing like $1.2 billion in 2007. So it's a net loss, any way you look at it, and a big one. The $1.2 billion does not even include fixing the most important aspects of the problem; the overflows (during storms) because of cross connected storm drains. This could apparently be fixed (for the whole region) for under $100 million; obviously that would be a much more cost-effective first step. The $1.2 billion also does not include greatly expanded source control, which (again) would have much greater benefits (for the ocean environment) than land based treatment. The CRD has an excellent source control program as documented in its recent annual report. The program is effectively removing many of the contaminants of concern. * Protecting and cleaning the creeks and waterways * Building light rapid transit to the Western Communities * Providing housing for the homeless * Funding the new patient tower at the Royal Jubilee Hospital It is likely that ALL of the above could be provided at a lower total cost than land-based sewage treatment alone; clearly with greater overall benefits in terms of environmental protection, human health, and quality of life in the capital region. This analysis referred to above has been posted at our website - www.rstv.ca In the future there may well be an opportunity to review the wisdom of the Ministers order. In the mean time a group of us “Responsible Sewage Treatment Victoria” – will continue to remind the public that scientific evidence and scientific opinion does not support the construction of these land based sewage treatment plants. The current natural treatment of Victoria’s effluent is highly effective and should be championed.
Dr Shaun Peck’s comments to the CRD’s Liquid Waste Management Committee April 25th 2007.
I speak to you as a concerned citizen and taxpayer, as a previous Regional Medical Health Officer and as a member of a group called RSTV – Responsible Sewage Treatment Victoria.
Our group which includes environmentalists, scientists, engineers, health care professionals and concerned individuals has been reviewing the development of events over the last couple of years. The events culminated in the Minister of the Environment ordering the CRD to develop a revision to the liquid waste management plan that includes a schedule for treatment. We are to-day publishing our perspectives on the issues on a web site – www.rstv.ca.
Advocacy Groups and some scientific reports have persuaded the Minister, and some of you, that additional land based sewage treatment is needed for the Capital Region’s Core and Westshore areas. There has, however, been a great deal of mis-information provided that influenced this decision.
I urge all CRD Board members to focus on some issues not fully addressed in this draft strategic plan outline which is being presented today.
There will be a significant environmental impact from land based treatment plants. These plants will be consuming enormous amounts of energy. They will be producing - greenhouse gases (Carbon Dioxide and Methane) during both construction and operation, there will be habitat loss, and at least 1000 tonnes/year of sewage sludge (biosolids) and other continuing negative impacts. These plants will have a much greater negative environmental effect than the current deep ocean discharge. I implore you to ensure that in the “Triple Bottom Line” (the social, environmental and economic) assessment there is a comprehensive risk analysis (as called for by the SETAC report), and a comparison with the present ocean discharges with their long outfalls, source controls and screenings.
The two deep ocean outfalls have proven to be highly effective in aiding the natural treatment of Victoria’s sewage. Many of you have been on the CRD Board for years and have received the dozens of studies and reports that have been done. All the studies have shown no public health risk and minimal environmental impact. Much of the Board’s previous resistance to developing further land based treatment was based on this – the environmental cost benefit analysis.
Victoria is renowned for the ocean environment and attracts tourists for world class scuba diving, wind and kite surfing, sailing, whale watching, etc. which demonstrates the truly pristine nature of our marine environment. The location of the outfalls – 60 meters below the ocean surface – not (as perceived by some) in the Harbour ensures that there is negligible human exposure. Our group is willing to help Tourism officials craft accurate statements, promoting our fabulous marine environment.
It is ironic that at long last the public is beginning to understand the science behind the need to take action on greenhouse gas emissions and global warming (the science was in the CRD’s “Healthy Atmosphere 2000” report that was developed 15 years ago in 1992 – which, incidentally, I was the chairman of the group that put it together). However the decision to plan for land based sewage treatment is ignoring the best science that demonstrates the effectiveness of the two deep sea ocean sewage discharges from a public health and environmental perspective.
I have been informed that there is no intention to develop updated plans for alleviating Victoria’s storm water over flows – 19 sites listed in to-days report. This is where unscreened sewage will continue to be discharged to the shorelines during times of heavy rainfall. There were 42 sanitary sewer overflow events in January 2007. Surely this should be the first priority.
I am sure it is of some concern to you, as it is to many taxpayers, that this first phase cost estimate of $1.2 Billion will undoubtedly escalate in the second and operational phases if this unnecessary mega-project proceeds . Two weeks ago the presentation from Edmonton demonstrated clearly that is what happens.
If some of this money was to be put to more pressing environmental concerns such as storm water overflows, continuing to improve the CRD’s excellent source control program, and reducing the pollution in Victoria Harbour, the taxpayers dollar will be more wisely spent.
The CRD and Victoria can lead the Nation in the best Ecological Practices in 2007 rather than planning to put in place extremely costly, unnecessary, and environmentally harmful land based sewage treatment plants. These will be soon be seen as the old “status quo” technological solution rather that the natural, environmentally sound solution that is best for todays environmentally sensitive world.
I urge you to include these perspectives in the final version of “The Path Forward”.