An analysis of the significance of the July 2006 report conclusions concerning liquid waste management in Victoria. A report by the Society of Environmental Toxicology and Chemistry (SETAC) commissioned by the Capital Regional District (CRD). Analysis by Ted Dew-Jones P.Eng.
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The significance of this report is that a quotation from it was given by the B.C. Minister of Environment as the reason for requiring the CRD to plan for land based sewage treatment.
It is the conclusions of any report like the one under consideration that matter. When the clients are not experts in the topic under examination it is all they should need to read. They should leave the rest for consideration by their own expert staff who will pass on any reservations they may have about such conclusions. Medical, marine science and engineering staff were all available to the CRD. Therefore this analysis simply examines the report’s conclusions but before that a number of issues need clarifying.
The members of the SETAC review were highly qualified and had held prestigious positions but it does not follow that they should have been retained for this study. That action presumes they would know better what to do than our own Canadian marine scientists and medical health officers who had been examining the issue for a generation. It ignores the fact that an internationally renowned oceanographic center is located at Patricia Bay on the Saanich Peninsular that had been monitoring these waters since the 1920s. Why the SETAC panel, rather than Canadian and local experts, was retained received no publicity.
Whether covered in the terms of reference or otherwise, the CRD clearly needed to know in brief the history of long outfalls. One page would have been enough to explain the presentation by the USA’s most renowned Oceanographer at the time to a committee of Congress explaining why secondary treatment was not needed with long outfalls; that a British Royal Commission had deduced that under the right conditions, “long outfalls could be environmentally preferable”.
The marine environmental conditions off Victoria are ideal. The issue has been treated by the CRD and SETAC as though this was the world’s first long outfall whereas there had been 35 years of study in four countries.
A brief explanation about the sea and how long outfalls work was needed but is not there. Many imagined problems would be overcome, for example, if it were known that the sea has been eroding whole mountain ranges over the millennia and is full of potentially toxic metals in vast amounts but tiny concentrations. It is not possible to pollute the sea with such materials beyond the zone needed to dilute it to acceptable levels.
The relative significance of the long outfall discharges compared with other discharges is not given. A secondary treatment plant will effectively dilute the sewage tenfold before discharge. Since long outfalls can ensure the dilution is about ten times more it is therefore likely that the environmental impact of the long outfalls on the waters to which they discharge is less than that of any secondary treatment plants. The heavy metal content is less than that of the discharge from the Annacis island secondary plant that discharges into the Fraser River, a delicate fresh water environment and a major fish resource. If environmental impacts of concern throughout the Province were priorized our long outfalls would not get onto the list at all.
The adverse impact of building and operating land based plants are substantial on health, safety, environmental and energy use grounds. The manufacture transportation and installation of the materials for the massive contract is only one of many items. They have not been examined in comparison with the current minimal effect on the marine environment. It is beyond reasonable doubt that they exceed that of our long outfalls and do so by a wide margin. An Act (the BC Environmental Management Act) to protect the environment is being used to damage it. It follows that the order by the Minister under an Act to protect the environment is probably not valid but it has not been challenged.
The SETAC report never received a Peer review, as the CRD had intended, which means it’s value is limited. However this was the report used by the Minister of Environment to justify the order he gave to the CRD to plan for land based sewage treatment.
That order used a passage from the text of the report and ignored the conclusions. They do not support that passage.
The Conclusions of the SETAC report.
Relevant paragraphs from the conclusions are quoted with my comments inset below each one.
“While there is a tremendous volume of scientific data, the benefits of treatment cannot be described or calculated with precision”.
They are not even described imprecisely either. No benefits of treatment are described at all.
“This observation does not mean that the benefits of treatment would be insignificant.”
A sentence that describes what another sentence does not mean has no logical meaning.
“People can reach different conclusions based on their own interpretation of the available evidence.....in such circumstances great deference is due to the expressed will of the electorate......residents of the CRD indicated through a referendum 14 years ago that the benefits of treatment did not outweigh its considerable costs. Due to changed circumstances, decision makers should assume that this may no longer be the case”.
These are political opinions and clearly have no place in the report that is meant to be a scientific review. These opinions may well be wrong, were not supported by any data and imply that technical issues were not the SETAC panel’s main concern.
“The panel believes it is likely that, if a BCA (benefit cost analysis) could be conducted to state of the art standards, it would find that treatment is justified. This conclusion rests on the Panel’s perception that the electorate would now support treatment”.
Whether the electorate would now support treatment (for which there is no evidence) has nothing whatever to do with a BCA. A real BCA would be valuable and would comprise an examination of the benefits of providing land based treatment with the benefits that the same money could bring to the environment if spent in other ways. Clearly those benefits would be massive but a BCA can never be carried out if, as is the case, no benefits of providing land based treatment have been established. The benefits of spending the money on other ways would be infinite!
“The CRD might consider steps to.....refine its estimates of the costs of different treatment options.... The latter activity would be a proactive step toward identifying the treatment option that, if selected, would best meet the long term needs of the community and the anticipated future regulatory environment. Benefit-cost prescriptions have been suggested for such choices: the best choice among options is that for which the last dollar spent on treatment costs is just balanced by an equal gain in benefits. However, a potential approach might be to install treatment comparable to that now employed in the similar cities surveyed in Section 4.8 of the report”. ( i.e. land based treatment plants).
This is the only paragraph that mentions treatment and it should therefore provide the answer by SETAC to the essential question as to whether the CRD should be providing land based treatment or not. The value of the whole report can be fairly judged on the clarity of this final paragraph in answering the CRD’s question.
J.E.Dew-Jones, P.Eng.
February 12th 2011