Open Letter to Government of Canada Re Victoria Sewage Issue
Rt. Hon. Justin Trudeau, P.C., M.P., Prime Minister of Canada
Hon. Amarjeet Sohi, P.C., M.P., Min. of Infrastructure
Hon. Catherine McKenna, P.C., M.P., Min. of Environment and Climate Change
Hon. Hunter Tootoo, P.C., M.P., Min. of Fisheries and Oceans
Hon. Jim Carr, P.C., M.P., Min. of Natural Resources
Hon. Jane Philpott, P.C., M.P., Min. of Health
Hon. Scott Brison, P.C., M.P., Treasury Board President
We are heartened that Prime Minister Trudeau is committed to evidence-based decision-making, and that his government’s infrastructure program will be directed to results-oriented projects of lasting value to Canadians, and will be based on rigorous cost-benefit analysis.
We strongly agree with this new approach, and ask that it be top-of-mind when considering the Capital Regional District’s (CRD’s) request for a federal financial contribution of 253 million dollars to help pay for its land-based sewage treatment project.
Though this request was sent to the previous government, we understand it will now be redirected to the new government’s infrastructure program.
We believe your government’s new approach is important because the present treatment system:
- Is deemed by British Columbia and Washington State marine scientists to have negligible impact on the marine environment;
- Already meets the objectives of the federal Regulations;
and compared to any of the proposed replacement systems,
- It has substantially lower greenhouse gas emissions, thereby supporting your government’s commitment to address climate change;
- According to six current and past Regional Health Officers, it provides equal or better health benefits.
We further note that, because the Regulations poorly differentiate between fresh water and marine receiving environments, Victoria’s marine treatment system has been erroneously designated as ‘high risk’.
In fact, it perfectly fits the regulators’ own definition of low risk and is likely the lowest risk system in Canada for a city of comparable size.
The purpose of risk designation is to prioritize funding to high risk systems first. The CRD’s erroneous ‘high risk’ designation enables it to receive funding 20 years prematurely, thus jeopardizing federal infrastructure funding for truly high risk systems.
Finally, we note that neither a cost/benefit analysis nor an environmental impact study has been carried out to compare the existing versus the proposed treatment systems.
We therefore respectfully request that these comparative studies be required before your government will consider the CRD’s funding request.
The Association for Responsible and Environmentally SustainableSewage Treatment
Brian Burchill, Chair.