Wastewater management practice within the Capital Regional District [CRD] is described in aLiquid Waste Management Plan [LWMP] which, once approved by the Minister of the Environment, becomes the legal framework within which operations are carried out. The CRD’s Core Area [Greater Victoria] is still operating within the conditions of an LWMP approved by Minister Joyce Murray on March 26, 2003, key features of which include a source control program, a program to reduce inflow and infiltration of rainwater to the sanitary sewer system, preliminary sewage treatment using fine screens and skimmers, and effluent disposal to the marine environment through diffusers at the ends of long outfalls extending into Juan de Fuca Strait from Clover Point in Victoria and Macaulay Point in Esquimalt. Subsequent amendments to the LWMP have been approved in principle [the most recent, #8, was approved by Minister Barry Penner in August 2010] but the amended plan remains in far-from-final form, and the
practice remains unchanged.
Current Provincial water-quality standards require that total suspended solids [TSS] and biochemical oxygen demand [BOD] from effluent each fall below 45 mg/litre. Victoria’s system achieves significantly lower concentrations within 100 meters of the diffusers. As far as these two parameters are concerned, the system works very well!
For over 30 years, Victoria and the CRD have been subjected to assault by environmental activist groups and a generally ill-informed press [spearheaded by Victoria’s “Mr. Floatie” and Seattle columnist Joel Connolly] objecting to the practice of “dumping raw sewage into the ocean” and alleging terrible environmental damage including “dead zones” around the outfalls. While these allegations are almost entirely unfounded, they have become a continuing source of embarrassment to the City and Province and a number of Municipal, Provincial, Federal and US politicians have joined the cry for “treatment.” The response of successive CRD Boards has
been to convene investigative panels or hire consultants to conduct studies. None of these found problems related to the discharge of organic waste through the outfalls, but several identified pollution via storm drains and a 1992 study found toxins [particularly mercury and 1,4-dichlorobenzene] in the sanitary sewage effluent. A joint BC-Washington scientific panel convened in 1994 concluded that human waste was a low-priority concern. The CRD responded to these findings by implementing a [generally successful] source-control program and by encouraging [generally unsuccessfully] upgrades to municipally-owned storm drains.
Criticism then shifted to the assertion that, while this might be adequate at present, population growth would eventually require some more-advanced form of treatment. In response a “trigger mechanism,” based on regular monitoring of water quality and sea-bed sediments and requiring further treatment should certain levels be surpassed, was proposed. Such a mechanism was incorporated in the 2003 LWMP.
Monitoring, originally by consultants and later by the CRD’s own staff [overseen by the Marine Monitoring Advisory Group – an independent body of scientists] has been conducted to an exemplary standard and has consistently documented water and sediment quality as good as, or better than, that found off outfalls from secondary treatment plants. Toxins in the sediments are decreasing year-over-year, as documented in the CRD’s Annual Reports.
The SETAC Report
Nevertheless, criticism continued and in 2006 the CRD again responded with a study, this time by the Society of Environmental Toxicology and Chemistry [SETAC]. The CRD’s stated intent was to follow the report with a series of public hearings over a five-month period before deciding on a further course of action.
The SETAC report was submitted on July 12, 2006 and, as anticipated, confirmed that the outfalls were not causing adverse environmental effects. It stated ‘‘There is no reason to believe that serious human health effects or severe ecological consequences not yet in evidence will arise in future” and noted that stormwater, sanitary and combined sewer overflows and other near-shore discharges, particularly into the waters of Victoria’s harbours, presented more pressing environmental issues than the offshore diffusers. However, while such facts and a number of related opinions were clearly presented in the body of the report [e.g. while applauding the quality of the monitoring program it suggested that the “trigger” mechanism was too loosely defined], its conclusion was essentially that the issue should be decided on the basis of public opinion, not science, stating in part: “Advocates of the status quo have argued eloquently and convincingly that treatment is unnecessary and even wasteful. However, the fact remains that, after many years of discourse, many people would decide the issue on grounds other than an absence of currently demonstrated health and ecological effects. The Panel cannot refute sentiments based on willingness to bear risks, ethics, esthetics, or other factors that cannot be resolved on purely ‘scientific’ grounds.” The report concluded: “Given the difficulty in estimating benefits, however, a potential approach might be to install treatment comparable to that now employed in … similar cities.” This appears to say: “There’s no reason to do it, but if you want to do it anyway you may as well just copy someone else.”
The MacDonald Report
About the same time, the Sierra Legal Defense Fund [now Ecojustice Canada] wrote to then-Minister Barry Penner alleging that toxins in sediments near the diffusers exceeded the provincial standard for classification as “contaminated” and the Ministry retained MacDonald Environmental Services Ltd. [MES] to review the CRD reports. In a report dated May 2006 MES confirmed that the reported toxin levels were sufficiently high to warrant preliminary classification as “contaminated” and made three recommendations: implementation of an electronic data-management system [since done]; further study to determine the source of those contaminants and an appropriate course of action [the normal action after preliminary classification]; refinement of the seafloor “trigger” mechanism. It did not comment on trend [i.e. that toxins were decreasing with time], but concluded [astonishingly, as there is nothing in the body of the report to suggest this]: “Alternatively, the seafloor trigger could be abandoned and arrangements made for providing wastewater treatment of these sites within three years.”
The Order to “Treat”
On receipt of these two reports, Minister Penner wrote to the CRD [undated letter received July 21, 2006] directing the CRD Board to submit to him, by June 30, 2007, an amendment to the LWMP “detailing a fixed schedule for the provision of sewage treatment,” as well as a progress report, by December 31, 2006. The letter cited as justification the SETAC and MES reports as well as reported difficulties in agreeing on an appropriate trigger mechanism. It did not specify a standard of treatment, but suggested consideration of “new technologies and alternative financing and delivery options, including the potential for private sector involvement.”
The reports, together with Minister Penner’s letter, were tabled at a meeting of the CRD’s Core Area Liquid Waste Management Committee [CALWMC] on July 26, 2006. The meeting was addressed by representatives of the T. Buck Suzuki Foundation [who urged the committee to immediately commit to land-based secondary treatment] and the Victoria Sewage Alliance [who urged that any treatment plan include a resource recovery program]. As the Committee had not had an opportunity to study the SETAC or MES reports, CRD staff were asked to prepare a briefing on their content. It was then moved that CALWMC “commit to implement, as soon as possible, comprehensive sewage treatment [secondary or better]” but agreed that consideration of the motion be postponed until after the requested briefing. [The motion later passed.] The CRD was thus committed to a billion-dollar project without any cost-benefit analysis, environmental impact assessment, or in fact any study appropriate to a project of that size.
At the same meeting, CRD staff tabled the Stormwater Quality Annual Report for 2005, which noted a significant increase in the number of discharges rated “high” for public health concern, particularly in areas with aging infrastructure. This was received and filed. [See more below.]
Proposed Federal Standards
For several years, staff at the Federal Ministry of the Environment have advocated establishment of a national wastewater treatment standard on the US model. In 2009 the Canadian Council of Ministers of the Environment [CCME] endorsed the Canada-wide Strategy for the Management of Municipal Wastewater Effluent, a policy statement intended to facilitate a nationally harmonized approach. There is much to support in that document – certainly most of the principles stated therein. But fundamental principles have been ignored in the formulation of the resulting draft Regulations: Although lip service is paid to the recognition of local environments, and exemptions granted for the arctic and parts of Quebec and Newfoundland, the general approach is “one size fits all.” This approach has been criticized by the scientific and public health community in at least 190 submissions, many from recognized experts in their fields, as ignoring the enormous variation in Canada’s receiving environments. The draft is still undergoing review, but if approved in its present form it will almost certainly lead to the waste of billions of dollars on unnecessary treatment levels for coastal communities, while permitting inadequate treatment in jurisdictions with highly sensitive receiving waters. The threat of implementation of this legislation has been repeatedly cited as a reason for the CRD to proceed with its treatment plans, but the appropriate action would be to seek exemption from, or amendments to, the draft Regulations.
More Recent History:
With the decision to implement land-based secondary treatment the trigger mechanism was abandoned and CALWMC invited the submission of plans and proposals. Some ideas [such as a system of many small treatment plants] were seized on with enthusiasm, then abandoned after studies showed they were impractical. Others equally impractical [such as large-scale heat and/or water recovery] continue to be advocated despite consultants’ negative reports.
The CRD was unable to meet the Minister’s original planning deadline and it was eventually extended to December 31, 2009. CALWMC met that deadline, but the submitted “plan” was largely conceptual and the accompanying business plans in support of funds [one to the Federal and one to the Provincial Governments], while claiming “Class C” estimates, were inconsistent and largely speculative, citing figures which could not be substantiated. Nevertheless, it was approved with the proviso that a final version be produced by June 30, 2010, when once again an incomplete “plan” [incorporating major revisions since December] was presented and duly approved. The plan remains unworkable [see below] and is once again slated for change.
The Stormwater Issue
Critics within the science community have long asserted that the real threat to our marine environments [including our harbours] lies in contaminated runoff through storm drains. In its 2009 report to the Ministry of Environment the Marine Monitoring Advisory Group stated: “…the Group identified a significant gap in knowledge with respect to contaminant loadings coming from stormwater discharges …, particularly as the “first flush” is ignored in current stormwater sampling programs. There is potential that the stormwater discharges could be a greater source of some contaminants to the marine environment than the wastewater outfalls.”
In the Spring of 2010, the Environmental Law Clinic at the University of Victoria prepared a report [presented to the CRD on July 28, 2010] titled “Re-inventing Rainwater Management: a Strategy to Protect Health and Restore Nature in the Capital City” which noted that toxic discharges from a great many storm-drain outfalls exceeded Provincial standards and quoted an observation in the SETAC Report: “Perhaps the most significant challenge the CRD faces is that it appears to have responsibility for stormwater, while at the same time it does not have authority to regulate stormwater.” That is, the CRD can monitor the effects of rainwater runoff but can only attempt to persuade its member municipalities to take corrective action. The draft federal regulation ignores stormwater altogether!
The Present Status
As of January 2011 CRD’s “treatment” planning is a mess:
- The discharge of screened organic matter through deep offshore diffusers is the least-pressing of environmental concerns, yet all of the effort and expenditure has been focused on that issue while most of the real environmental damage is caused by substances [such as pharmaceuticals, fire retardants, and other “chemicals of concern”] which would not be adequately dealt with by the proposed treatment plants.
- Land was purchased for a plant at Haro Woods [the “Saanich East” plant] before studies confirmed critics’ allegations that such a plant would have no net benefit. CALWMC is now considering heat recovery from attenuation tanks at that location, even though studies have clearly demonstrated the impracticality of such a proposal.
- The CRD holds an option on land at McLoughlin Point [Victoria Harbour entrance] but that location poses numerous problems, including the need for pipes under the harbour, the problem of odour in a sensitive area [including the Legislative Precinct], a high risk of spills, and the fact that the site is far too small. Half of the plant must be located elsewhere and connected by a double pipeline; even so, the site may be outgrown by 2030. Splitting a treatment plant is contrary to established practice, which demands close proximity of elements for efficiency. If the sludge treatment half of the plant [optimistically called the Resource Recovery Centre] is located at the Hartland landfill as presently planned, nearly 18 km of double pipes and several pumping stations will be required. Construction of such a system must involve major disruptions and right-of-way problems, excessive energy consumption, and an ongoing risk of spills.
- Meanwhile, toxins in storm drains bypass the treatment system altogether [see Appendix B]. Ancient leaky pipes and cross-connected storm and sanitary sewers are the principal sources of beach contamination. Many of the offending discharges flow directly into Victoria’s harbours. CRD staff have been working with municipalities in an attempt to correct some of these problems, but with inadequate funds and resources little has been accomplished to date.
- Plans to sell sludge as fertilizer or fuel must face the fact that no such market exists. Cost projections are little more than guesstimates. Resource-recovery plans, and the associated revenue projections, are mostly wishful thinking.
- To date, the CRD has authorized borrowing of $20 million, and most of this has been spent on studies and planning. This has already led to cutbacks elsewhere – to libraries, recreation services, and recently to funding for public health. The presently-projected $800 million capital cost [almost certainly optimistic] will have serious impacts elsewhere.
Some Good News
All evidence suggests that the present combination of source control, screening, and offshore ocean discharge through diffusers works very well so far as sanitary sewage is concerned. The Source Control Program, in particular, has led to a major reduction of toxins in effluent and a steady improvement in the quality of marine sediments.
The CRD’s Stormwater, Harbours and Watershed Program [SHWP] staff have been working with core area municipalities to address the increasing number of stormwater discharges rated High for environmental and public health concerns. Through 2008-2009 enhanced investigative work was performed on 42 discharge points previously rated High. A combination of municipal repairs, municipal infrastructure maintenance and reduced contaminants led to significant improvement in 14 of those discharges. [This program was scheduled for termination at the end of 2010 due to funding constraints, but some sampling will continue.] Saanich Municipality recently initiated a storm-water source-control program and the CRD Board has asked its staff to report on the feasibility of expanding such a program.
What Should Be Done?
This process began as a solution in search of a problem, rather than the other way around, and is slated to provide minimal benefit to the marine environment while creating major problems on land, so that the net environmental impact will be negative. If the objective is to protect public health and the marine environment it should be vital to identify and prioritize problems before committing to a costly program which will tie managers’ hands for decades.
There is a natural desire not to “waste” the money already spent on planning, but much of that planning was based on faulty premises and a new start is essential. The treatment-plant-centered process should be halted, unrealistic deadlines abandoned, and a fresh approach undertaken – a holistic approach which addresses the issue of waste-water management in its entirety. It should start with a science-based, results-oriented Triple-Bottom-Line assessment which considers all options, including retention of and improvements to the present system. Rather than addressing sanitary sewage alone it should consider all sources and all discharges and focus on identifying actions with the most favourable environmental impact. Consideration should be given to wetlands and watercourses as well as the atmospheric, terrestrial, and marine environments.
The presently gazetted draft Regulation [proposed under Section 36(3) of the Fisheries Act] should be amended to recognize the variation in Canadian aquatic ecosystems, and to better reflect the intent of the 2009 Strategy paper endorsed by the CCME, by adopting a Europeanstyle environmentally-centered approach rather than “one-size-fits-all.” [This would require intervention on the part of the BC Minister but is perfectly feasible at this stage and has already been suggested by the CRD’s staff. It would potentially save several billion dollars nationally over the next twenty years.] To quote the CRD proposal: “We encourage the federal government to consider an environmental risk-assessment approach … rather than the single set of … standards for all receiving environments. … Alternatively, we suggest … a waiver system, similar to the US EPA 301(h) waivers, that supports exemptions to secondary treatmentstandards in less sensitive receiving environments. ”
Objectives should be stated in terms of goals rather than processes. Instead of “constructing a secondary sewage treatment system” we suggest:
- Limiting organic matter in effluent to volumes and concentrations which can demonstrably be absorbed, without harm, by the specific receiving environment.
- Reducing organic pathogens to a very low risk level within all of the receiving environments.
- Preventing chemicals of concern from entering the wastewater stream [rather than trying, ineffectively and at great expense, to remove them later].
- Minimizing energy consumption and greenhouse gas emissions [rather than attempting partial recovery through fuel sales and carbon offsets].
See Appendix A for a discussion of possible methodology.
APPENDIX A – AN ENVIRONMENTALLY-CENTERED APPROACH
Instead of the existing fragmented management system, with its multiple overlapping jurisdictions, administration should be concentrated in a single body which could take a district wide integrated approach to storm-water and sanitary sewage management. Such a body [possibly a Commission under the CRD] could, with assistance from Provincial and Federal agencies, obtain the best-possible balance of environmental impact, social issues, and cost.
The following could form elements of a local master plan:
- Establishing specialized wastewater treatment facilities at major contaminant point-sources such as hospitals and food-processing plants. [As an example, the fat-removal system recently installed at Island Farms Dairy].
- Expanding the Source Control Program, presently concentrated on commercial activity, to include residences and substances not presently collected. [A “red box” collection program could be a cost effective approach].
Expanding the monitoring program to include thorough sampling of storm drains and identification of sources of contamination, with the goal of intercepting discharges before they occur. Appointing enforcement officers with the authority to levy fines.
Expanding and accelerating programs to upgrade antiquated pipes and other infrastructure.
Initiating improvements designed to drastically reduce near-shore sewage overflows during storm events and to ensure that all overflows meet accepted concentration standards. [Such improvements could include extended or relocated outfalls and/or the use of attenuation tanks, as well as inflow and infiltration reduction through acceleration and expansion of existing and projected programs].
Refining and enforcing the existing CRD Model Storm Sewer and Watercourse Protection Bylaw across the Region.
Encouraging natural rainwater treatment methods such as swales and artificial wetlands.
Encouraging the incorporation of resource-recovery initiatives in new development, on a local or communal basis. [Examples are the Dockside Green project on Victoria’s upper harbour, or the Athlete’s Village on Vancouver’s False Creek].
Concentrating on known problems and practical solutions while encouraging research into the effects of, and ways of dealing with, potential chemicals of concern.
Establishing an Aquatic Environment Protection Fund which could serve to assist programs run by non-governmental bodies [Volunteer groups often give the best “bang for the buck”].
APPENDIX B – THE STATUS QUO
Extract from the 2007 Stormwater Quality Annual Report showing stormwater outfalls posing threats to public health and the environment:
[Regarding the present system] “…we predict environmental concentrations of TSS and cBOD at both outfalls to be well below either of the 45 mg/L Municipal Sewage Regulation or 25 mg/L National Performance Standards discharge limits at the edge of the initial dilution zone, even under the worst case conditions of highest concentrations and lowest dilutions.”
Dr. Glenn Harris, Biologist,
Senior Manager, CRD Scientific Programs
“….there is no evidence of the requirement for a [land-based] sewage treatment facility. It will not solve the pollution problem in Victoria and it may be environmentally irresponsible.”
Dr. Jack Littlepage, Biological Oceanographer,
Centre for Global Studies, University of Victoria
“If we are looking for real risks to public health, this [stormwater] is the one… My plea is do not
ignore this, in terms of planning for our aging sewer system. …This is something that should be
causing some angst.”
Dr. Richard Stanwick, Chief Medical Health Officer,
Vancouver Island Health Authority
APPENDIX C – SOME USEFUL REFERENCES
Managing Wastewater in Coastal Urban Areas Report of the US National Research Council, 1993
The Shared Marine Waters of British Columbia and Washington Report of the British Columbia/Washington Marine Science Panel, 2004
Potential Environmental Effects from the Macaulay and Clover Point Outfalls and Review of the Wastewater and Marine Environment Program
Report prepared for the CRD by Golder Associates Ltd., 2005
Sewage Treatment Wasted – The Victoria (BC, Canada) example Editorial in the Marine Pollution Bulletin, 2008
CRD comments on the CCME Strategy
Paper Submitted by CRD Science and Engineering staff,
2009Macaulay and Clover Points Wastewater and Marine Environment Program Report
CRD Annual Reports for 2009 and previous years
Regional Source Control Program Report
CRD Annual Reports for 2009 and previous years
Feasibility studies for heat recovery from sewage: James Bay, Downtown Victoria and the University of Victoria area. Studies for water recovery, Saanich East
Reports to the CRD by STANTEC Consulting Ltd., January 2010
Re-Inventing Rainwater Management
Report by the Environmental Law Clinic, University of Victoria, Spring 2010
CRD comments on the proposed Wastewater Systems Effluent Regulation
As submitted to the federal Department of the Environment, May 2010
Additional comments on the proposed Regulation
As submitted by scientists, engineers and public health physicians – available on request
Core Area Inflow & Infiltration Program Progress Report, October 2008-March 2010
CRD staff report, Fall 2010