Address by ARESST Chair (and former CRD Director) John Bergbusch to the Core Area Liquid Waste Management Committee (CALWMC) on the draft Biosolids Management Plan – November 10, 2009
Madame Chair, Members of the Liquid Waste Management Committee:
Thank you for allowing me to speak with regard to the Biosolids Management Plan.
Personally, I did not think I would be ever be speaking to a CRD committee again, as I have really been enjoying my retirement and was quite content to leave public business to others. However, being retired does not mean I have lost interest in the programmes for which the CRD is responsible; so I regularly monitor the CRD website and I want to commend the CRD for its overall excellent work in serving the public.
Today I am speaking to you as a member of the Association for Responsible and Environmentally Sustainable Sewage Treatment. The organization is a group of interested citizens who are concerned about the direction and cost of the land-based secondary sewage treatment proposals currently being considered by the CRD. The Biosolids Management Plan, surely the key plan to any land-based sewage treatment, is the subject of my comments today.
The report is a lengthy and complex document; it is easy to understand why consultants cost so much money!
Six options for land-based treatment are proposed in the staff report. Option 1 which is recommended has a capital cost approaching $260 million and a $7 million annual operating cost. All the other options cost considerably more. And these costs are optimistic. If one were to employ the Vancouver Convention Centre model, or the Olympics model or the Fast Ferries model, one can easily imagine that the final cost will be a great deal more. And then, what will we do with the biosolids and solid waste. Well, in the short term, the report says you will truck them to the mainland as cement kiln fuel or bury them in the Hartland dump.
And what does this mean? Well, you’re going to waste a lot of land on treatment plants, create a lot of greenhouse gasses in the processing and transportation of the “treated” waste, and even more in the burning of the so-called fuel. Alternatively, you will dispose the concentrated highly toxic biosolids and solid waste stream at Hartland… hardly an environmental benefit!
In addition, the construction of a large-scale Municipal Solid Waste biosolids co-combustion Waste-To-Energy facility requires additional environmental assessment (EA) according to the provincial BC Environmental Assessment Act (BCEAA) under the Reviewable Project Regulation. To carry out an EA, consultations with the public, government agencies, and First Nations must be conducted throughout the process development and review. A federal CEAA review would also be required for this type of project.” So in order to progress with the Biosolids Management Plan, you’re not only proposing a number of negative environmental outcomes, you’re going have to go through a provincial assessment, a federal assessment, and a series of consultations, and the price is going to escalate into further 10’s of millions, even hundreds of millions of dollars.
And there’s more… Have you read the read the consultants’ nine recommendations (pp12-3 and 12-4]? They are heavy on “ do more research.” The fact is, the report you have in front of you is far from a plan; it’s just a set of options based on general principles. You are a long way from adopting an amendment to the LWMP.
And you are already talking about a $965 million price tag, with large unknowns such as land acquisitions, potential markets for the proposed end products of the biosolids…. And you’re trying to meet an arbitrary December 31st.deadline. Well, arbitrary deadlines don’t support good planning, good consultation, or good decision-making.
And why are you considering this report anyway?
According to the most recent CRD report on the existing Macauley and Clover Point outfalls, a statistical analysis of 1990 to 2006 sediment samples showed that many substances in the seafloor sediments, including many metals and PAHs, have decreased over this time period. Only a few substances, mainly a few metals, have shown an increase close to the outfalls over time. There has been little change in seafloor organisms around the Macaulay Point outfall over 18 years except for the better. There are more organisms closer to the outfall due to an abundant food source in the form of organic matter (total organic carbon) in the discharge. (On land, we’d say the garden was well manured.) Some of the communities closer to the outfall had a slightly different makeup of organisms, although their function and health were the same as communities further away. Communities at stations 400 metres and 800 metres from the outfall were the most similar to those at the reference stations. At Clover Point, mussels near the outfall were larger than those further away or in the reference areas. Measures of age and reproductive status, as well as tissue chemistry showed no harmful effects of the outfall.
So, if I understand the CRD’s own monitoring reports correctly, there has been an improvement in the state of the receiving waters over the past 18 years and the marine environment in the vicinity of the current outfalls is in very good shape. In fact, we have one of the finest sewage treatment regimes in the world already in place, with Mother Nature playing the lead role in the success of that treatment, and at a cost which is affordable. And I don’t have to remind you, it’s not nice to mess with Mother Nature.
So here’s my advice. Take a break; write to the Minister explaining December 31st is impossible. Then seriously reconsider what you are doing. We already have an excellent natural secondary sewage treatment system. Work with it.