Frequently Asked Questions

What does ARESST hope to achieve?

To stop the Provincial government (in the person of the present Environment Minister) and the Capital Regional District (CRD), from forcing an unnecessary, costly, and environmentally harmful new system onto Greater Victoria taxpayers. The decision to build this system has already led the CRD to spend tens of millions on planning and design. It will soon require the commitment of a billion more for construction and annual millions for operation – at a time of cutbacks in everything from libraries to health care.

Is ARESST therefore opposed to sewage treatment?

No! We are simply opposed to inappropriate treatment. If we were based in Seattle we would support that city’s effective mix of treatment systems; if in Honolulu or San Diego their systems of primary treatment plus deep ocean outfalls; if in Kamloops or Calgary the advanced tertiary treatment systems currently in place. But all of those systems were designed to reflect the nature of the receiving waters – be they lakes, rivers, estuaries, or marine environments of various kinds. The test should be a system’s ability to meet accepted water quality standards in the receiving environment and all of those cities pass that test, though by different means.

So how does Victoria’s system measure up?

Victoria’s present system was designed to the same rigorous standards as those of the cities cited above. It meets the existing Provincial standard but not the first draft of the proposed new National standards. However, we think the proposed new standards are poorly drafted, as they fail to recognize our Country’s great diversity of aquatic ecosystems.

How do you know we are meeting Provincial standards?

The CRD is required to monitor water quality and bottom sediments in the area surrounding the effluent outfalls. That work is monitored in turn by an independent committee of scientists. An annual report is published and can be found on the CRD Website. The most recent report confirms that the system’s effluent quality falls well within Provincial standards when measured in the receiving environment.

Why is this important?

It challenges regulators to review their emphasis on “end of pipe” standards, which ignore the nature of the receiving waters. The US Environmental Protection Agency rethought this approach two decades ago and most sewage treatment systems are designed with the receiving environment in mind. The US EPA has titled this “Aiming before we shoot”.¹

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What is the difference between “end of pipe” and “receiving environment” standards?

End of pipe standards apply to the effluent leaving a treatment plant – a “one size fits all” approach. But the single most important variable to be considered in designing a treatment system is the nature of the receiving waters and the effect (both measured and potential) of the effluent on the local environment. And of course the test should be: Does the system work? Engineers have recognized this for years.

How are the standards defined?

Present Provincial regulations define successful secondary treatment as producing effluent with less than a maximum of 45 milligrams/litre TSS and BOD. Victoria’s present Discharge Permit specifies that these must be achieved within the Initial Dilution Zone (IDZ). The proposed new National standard is a monthly average of 25 mg/L TSS and BOD, with additional standards for nitrogen and chlorine content, all measured at the “Final Discharge Point” (FDP or “end of pipe”). There is actually little difference between a maximum of 45 and average of 25 – the major difference is between IDZ and FDP. The proposed new regulation defines FDP as “the point….beyond which (the) operator no longer exercises control over the
quality of the wastewater before its deposit as effluent in water or a place.”

What is the IDZ?

Provincial regulations define the IDZ as the volume of water within 100 meters of the point of discharge. It is the space in which the final stage of treatment (organic breakdown and absorption) takes place.

What is TSS?

TSS is Total Suspended Solids – a measure of suspended matter in the effluent. The levels found at 100 meters from Victoria’s deep-ocean diffusers (the edge of the IDZ) are well below the regulated maximum.

What is BOD?

Oxygen is needed for organic matter to be broken down and the amount of oxygen required is the Biochemical Oxygen Demand of a sample – sometimes written cBOD or cBOD ₅ (c for carbonaceous and 5 for a method of measurement over a period of five days) In a conventional treatment plant, air must be pumped in to enable the organic matter in the sewage to be digested by microorganisms. But the waters of the Strait of Juan de Fuca are rich in oxygen and organisms and the ocean treats Victoria’s sewage naturally, so that the levels of BOD found at the edge of the IDZ again fall well within the regulated standard.

What do CRD Scientists have to say about this?

A letter dated October 29, 2009 from Glenn Harris, PhD, RPBio, Senior Manager of CRD Scientific Programs reads in part: “Based on (our) calculations, 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”. Worst-case concentrations are reported as TSS 1.27-1.29 mg/L, BOD 0.77-1.16.

Regardless of standards, aren’t there “dead zones” at the outfalls?

The most recent reports, published on the CRD website, show that sea life is thriving around both the Clover and Macaulay Point outfalls. Concentrations of chemical pollutants near the outfalls are comparable to those around outfalls from land-based secondary treatment plants and some are actually lower near the outfalls than further away, indicating other sources such as storm drains. There are NO dead zones.

But there have been beach closures due to high levels of coliform bacteria. Isn’t treatment required to protect public health?

Greater Victoria’s current and previous Chief Medical Health Officers state categorically that sewage discharged through deep ocean outfalls poses NO measurable threat to human health. None of the beach closures are related to sewage from the outfalls. But after heavy rainfall sewage is sometimes discharged onto our beaches through overflows which are diverted into storm drains. This would not be prevented by any of the treatment systems currently under consideration but could be corrected at a fraction of the cost. ARESST has consistently urged that this problem be addressed.

But treatment has been ordered by BC’s Environment Minister. Wasn’t the Minister Penner’s order based on good science?

No! The decision to impose a new treatment system on the Capital Region’s core was based not on science, or engineering studies, or cost-benefit analysis, or environmental-impact studies, or any logical process involving identifying a problem and designing a solution. Rather it was a political decision in response to some active special-interest groups, the antics of a clown in a turd suit, and some unfavourable press. It’s all about image!

Why is Victoria different from Chilliwack? (Minister Penner’s riding)

Minister Penner has been quoted as saying that if Chilliwack has to have treatment then so should Victoria. But Chilliwack discharges into the Fraser River where there is a potential for downstream health hazards, little natural digestion, and minimal diffusion of the effluent. At Victoria the highly oxygenated, turbulent waters of the Juan de Fuca Strait are filled with active organisms which treat our liquid waste naturally. The receiving environment is radically different, posing no health hazard and able to naturally treat all of the screened and diffused effluent within the IDZ. If the discharge were into a lake, river, or estuary we would advocate land-based treatment!

But Victoria is not unique in the world. Many other jurisdictions have taken advantage of favourable receiving environments.

What was Minister Penner’s order to the CRD?

Sewage is managed in accordance with a Liquid Waste Management Plan (LWMP) approved by the Minister. In July 2006 the Minister ordered the CRD to develop an amended LWMP “detailing a schedule for the provision of sewage treatment” by July 2007 (later extended to December 2009).

Did the CRD have any choice in the matter?

The CRD Board had considerable latitude as to the content of such a plan and could have incorporated the present system but chose not to do so, deciding without investigation or debate to commit to a land-based system providing “secondary treatment or better.” A tentative “plan” was submitted by the December deadline, but as it fails to establish where plants pr pipelines will be located, how many there will be, what systems will be used, or what will be done with the resulting toxic sludge, it falls far short of a final plan. Nevertheless, it was recently approved by the Minister (subject to completion in final form by June 30, 2010 – an impossible deadline).

What will the new system cost?

The CRD spent about $10 Million in 2008 and $12 Million in 2009 for studies and some land acquisition. The latest estimates are $967,500 Million for one-time capital costs and $20 Million annually for operating costs, but as plans are far from complete the final figure will probably be much higher. The CRD expects that Canadian and BC taxpayers will each contribute up to one third of the capital costs, but neither government has made a firm commitment. Even with two-thirds funding from senior governments the system will add $500 to $1000 to local homeowners’ taxes. And this enormous expenditure will produce no definable benefit to public health or the environment.

What is the CRD doing right?

The CRD has an exemplary Source Control Program which has led to a significant reduction of many contaminants – such as mercury from dentists’ offices and fats from food premises – over the past few years. Pharmaceuticals are now being collected by pharmacies. There is good control of petroleum products from Motor Vehicle Repair premises. The CRD has taken a lead with its member Municipalities in promoting programs to control Inflow and Infiltration of storm water to the sewers. It has an excellent record of protecting the local land environment and its staff has done a fine job of operating and monitoring the existing waste-water system.

But the source-control program could be expanded, overflows to beaches could be eliminated, storm-water systems could be improved. There is much that should be higher priority than building new treatment plants.

Won’t the plants be required by the new National Standards?

There has still been no public input or debate on the proposed new regulations, although the Federation of Canadian Municipalities has stated that if the Federal Government applies this standard to all Municipalities they will need some assurance of Federal grants. We believe the regulations can still be amended to recognize local environments.

Hasn’t Victoria’s LWMP already been debated to death?

Although many credible critics have expressed concerns, and there has been at least the appearance of a public consultation process, there has been no debate. Ten marine scientists, six Public Health officials, and several engineers have publicly questioned the need for land-based treatment plants and noted problems with the evolving Plan, but Minister Penner and the CRD Board have consistently refused to consider their input. ARESST would welcome a true public debate on this issue.

But if the decisions are final and debate is not possible, why is ARESST still fighting this?

We recognize that once a decision has been announced and a project undertaken it is almost impossible for politicians to say “we were wrong” and reverse the process – especially once the first few million dollars have been spent, as is now the case.

But it’s not over ‘till it’s over. Although the CRD has spent over $20 million to date its planning is still at a preliminary stage. Many decisions need to be made on financing, site locations, methods of treatment, and disposal of the toxic sludge. Until firm commitments have been made and construction contracts let there is still an opportunity for Regulators and the CRD to take a sober second look at what is actually required.

What should be the priorities for spending $1 Billion ($1000 Million) on Victoria’s Environment?

Many suggestions have been made which all together would cost a lot less than a Billion Dollars: improvements to the source control program (including its extension to residences and storm-water drains), an end to the existing inflow, infiltration, and cross connection problems in our antiquated sewers, major upgrades to the storm-water system, a cleaned-up Inner Harbor, more green space, expanded recycling. And there would be lots left over for better health care facilities, housing for the homeless, a local light rail system, and other worthy projects.

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Sewage FAQs