Subject: Victoria – correction of our classification to low risk
Dear Hon. Mr. Fassbender:
With regard to the CRD’s efforts to develop a wastewater treatment plan, are you aware that Justin Trudeau’s public criticisms have been that “There will be no net environmental benefit from this secondary treatment plant”, and that the CRD’s insistence to proceed with a plan is a “push of ideology over sound scientific evidence.”
Given that the provincial and federal governments expect to commit a quarter billion dollars each if the CRD’s project proceeds, would it not be prudent to review, with the Prime Minister, the basis of his criticisms?
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
The chair of ARESST says the group’s lobby against land-based sewage treatment has not ended with his failure to be elected mayor of View Royal on Saturday.
The man who was elected Mayor, David Screech, has said the outcome was a signal that the public has decided the debate over the need for sewage treatment is over..;.but Brian Burchill says he “does not interpret it that way”…
“The ARESST board is going to be meeting shortly to look at future actions. This project is so unnecessary; so rife with error that we are going to keep finding a way to get this corrected”
Burchill says the federal government needs to be persuaded that the currents in Juan de Fuca Strait make it a “low-risk” environment for sewage disposal, and there is therefore no need to be rushing into a land based solution.
OPEN LETTER TO THE CITIZENS OF VICTORIA, OCT. 23, 2013:
YOU ARE BEING MISLED ABOUT SEWAGE TREATMENT
The October 3rd media release(1) by Georgia Strait Alliance (GSA), TBuck Suzuki Foundation (TSF), and David Suzuki Foundation (DSF) presented misinformation suggesting that Victoria’s current system of natural marine treatment needs to be replaced.
In a subsequent October 4th CHEK TV news-cast(2), retired UVic microbiologist Dr. Ed Ishiguro presented informal test results that were neither scientifically peer-reviewed nor published.On the same news-cast, CRD director Judy Brownoff cited his tests to support her promotion of the CRD’s sewage plan.
ARESST offers the following documented clarifications:
Dr. Ishiguro, GSA, TSF, and DSF compared(3) fecal coliforms in local marine sediments to fecal coliform water standards (from Health Canada,(4) US EPA, and WHO).
They were negligent to apply water quality standards to evaluate sediments.Their claims of contamination and threat to human health are therefore unfounded.
Their claim that human fecal coliforms traveled 2-10 km is absurd. The marine environment is hostile to coliforms from the human gut.(5) A peer-reviewed analysis of 1700 samples found no evidence beyond 400 metres of fecal coliforms from Victoria’s outfalls(6).
Fecal coliforms from plants and animals exist throughout the marine environment.(7) Their presence in sediments off William Head or Trial Island is no more related to Victoria’s outfalls than sediment coliforms off Tofino or Alaska.
At an October 9th sewage meeting(8), in response to a query from Director Brownoff, CRD science staff reported no problems with fecal coliforms – thus contradicting Ishiguro, GSA, TSF, DSF, and herself.
The CRD offers many scientific studies online(9) confirming that Victoria’s current method of marine treatment is essentially as effective as secondary treatment. Victoria’s system already meets the objective of the new Federal regulation(10) because there is no evidence of a threat to fish, fish habitat or human health due to consumption of fish from the waters around Victoria.
Citizens should be outraged that the majority of CRD Directors voted NOT to invite experts(11) to explain all this evidence to the sewage committee.
Citizens should be equally outraged that our elected representatives are not using this abundance of scientific evidence to make the case to Ottawa that it is senseless to continue to force Victoria to build a costly and unnecessary land-based treatment system.
Victoria’s sewage discharge does not pollute Washington shores, according to guest columnist Brian Burchill.
26 July 2014
WASHINGTON residents concerned about Victoria’s sewage discharge might take comfort in knowing that it’s a treatment system based on research by such august U.S. institutions as University of California, Berkeley, the California Institute of Technology, and the U.S. National Research Council.
The Seattle Times editorial board raised concern about the sewage discharge in a June 17 editorial.Washington Gov. Jay Inslee has written to the British Columbia government demanding an end to the sewage flow, according to an Associated Press news report.
The system’s design is based on “sound scientific evidence” that “sea outfalls allow the sewage effluent to be subjected to the same processes of degradation and oxidation that occur in land-based sewage treatment plants,” according to a 1987 report by Water Research Laboratory.
Such research led the World Health Organization and a British Royal Commission to conclude in 1984 that ocean treatment of sewage is an acceptable, sometimes preferable, practice.
U.S. Congress, overwhelmed with such research and opinion, realized in 1975 that some marine discharges don’t require secondary treatment. Victoria’s is one such discharge. Washington state marine scientists, in a joint study with British Columbia scientists, found no evidence that it fouls our shared waters. They concluded in a 1994 report that “sewage discharges from Victoria have a negligible effect on the shared waters.”
Victoria’s wastewater is treated. Greases and oils are removed, and screening filters out trash items. As per the National Research Council recommendations, a source-control program prevents deleterious substances from going into drains in the first place that, combined with Victoria’s lack of heavy industry, results in concentrations of metals in our discharge being well below EPA standards for drinking water. The million gallons per hour that Victoria discharges is more than 99.9 percent fresh water.
The screens also cause size reduction. Then the final stage of treatment is provided by the ocean, driven by the free, sustainable energy of the tides and currents. The Strait of Juan de Fuca’s strong turbulence and abundance of microbes rapidly disperses the discharge and assimilates it into the marine food chain.
Coliforms from the warm human gut are rapidly reduced, due to the cold seawater and the abundance of predatory microbes, to seawater’s natural background levels, according to a 2000 report in the Canadian Water Resources Journal. These actions, and the high-oxygen content of the strait, prevent Victoria’s discharge from fouling our shared waters.
These rich treatment conditions are continuously replenished by a flow of about 100,000 cubic yards per second that, independent of the tides, sweeps into and back out of the Strait of Juan de Fuca. The inflow presses against Washington state’s north shore until it’s deflected by Whidbey Island.
A small portion sweeps through Puget Sound and rejoins the main flow north to the San Juan Islands. There, the outflow of the Strait of Georgia southward through the islands forces the current to turn back. It flows westward past Victoria, pressing against the south shore of Vancouver Island as it flows to the Pacific.
Hence, Washington’s discharges into Juan de Fuca Strait and Puget Sound — and British Columbia’s discharges into Georgia Strait — flow to Victoria, not the reverse. This current is so strong and persistent that, contrary to popular concern, it’s extremely unlikely for Victoria’s discharge to flow to Washington’s shores. If it ever did, good luck detecting it because it would be infinitesimally dilute and indistinguishable from all of the other discharges.
The suggested study to measure the effect of Victoria’s discharge on U.S. waters would likely be a waste of taxpayers funds. Wisely spent funds have revealed the much more important issue that, even with a 21st-century respect for the environment, the climate-change disaster is still escalating. Infrastructure and land-based treatment systems contribute to the problem.
Given the facts and evidence, not replacing Victoria’s world-class, low-impact system with an unnecessary land-based treatment system would support the U.S. federal administration’s initiatives to reduce climate change, a stance that green Gov. Inslee’s administration ought to seriously consider.
- Brian Burchill is an engineer based in Victoria, B.C.
Canadian Taxpayers Federation
July 16, 2014
Seaterra’s proposed Esquimalt bribe should leave Capital Regional District (CRD) taxpayers Seaterr-ified.
With the $788 million sewage treatment plan reeling like a bloodied prizefighter on his last legs, the CRD voted last week to send a letter to every Esquimalt property owner, offering to pay a portion of the community’s capital costs in return for allowing a massive sewage plant to be built at McLoughlin Point.
The Times Colonist reported that the CRD believes this deal would bring the average sewage tax increase for Esquimalt residents down to $125 a year. But that number is wildly inaccurate – and should be considered by Esquimalt taxpayers as just more Seaterra spin.
Earlier this year, the Canadian Taxpayers Federation (CTF) released an independent report by off-Island Certified Management Accountant, Sacha Peter, showing the CRD was grossly downplaying the true tax implications of the Seaterra scheme. Back then, the CRD’s plan understated the average Victoria homeowner’s tax bill by $579 over the first six years, Esquimalt by $555, and View Royal by $195.
Re: “CRD selected best possible sewage-treatment plan,” April 16.
The writers erred in suggesting that the sewage debate includes persons advocating no sewage treatment.
The Capital Regional District years ago selected the proven science of marine treatment via long ocean outfalls as the best option for Victoria. Based on CRD documentation, the province was convinced that the system would not pollute, but approved the system with the condition that the CRD monitor it and use the data to show non-believers that the system safely treats our sewage.
If the writers review that science and data, they could understand why marine-based treatment has been accepted by a British Royal Commission, the U.S. National Research Council and the World Health Organization.
Such a review reveals that keeping our current low-environmental-impact system is a viable option, and accords with Prof. Caterino Valeo’s statement that “low-impact development in urban regions is now recognized as the only option in sustainable urban design.”
Also, after such review, they might wish to retract their claim that our effluent discharge practice is dangerous.
Chairman, Association for Responsible and Environmentally Sustainable Sewage Treatment
Guernsey does not need to build a full sewage treatment plant, according to a report into the impact of pumping the waste out to sea.
UK firm Metoc investigated the potential cost and benefits of additional sewage treatment.
It found a treatment plant, estimated at a cost of £100m over 25 years, would provide no environmental benefit.
Public Services Minister Bernard Flouquet said the report showed nature provided effective sewage treatment.
He said the current system met most European and international standards.
At the moment waste water, including sewage, is screened before being discharged from the Belle Greve pumping station into the Little Russel, about one mile offshore via the main long sea outfall.
The States approved an £11m upgrade to the existing station on Thursday to improve the screening process.
‘May be unpalatable’
The £200,000 report found the only requirement the island does not currently meet could be achieved by installing a new long sea outfall, at a cost of £6-8m, which is set to be approved in January.
It also concluded the current method had no adverse impact on bathing water quality at beaches outside Belle Greve, or on local shell fisheries.
The report recommended continued monitoring of the impact and changing international requirements.
Deputy Flouquet said the studies were commissioned to identify the best method for adopting full sewage treatment.
He said: “The current method of dealing with sewage may be unpalatable to a lot of us, but if it currently meets international standards you have to question what rationale there is for spending such large amounts of money to implement further treatment.
“However, this is an issue which we know many people have strong views about, so we need to have an informed debate. The scientific work that has been carried out will assist with that.”
The estimated cost of £100m for a full sewage treatment plant was based on a similar UK scheme.
It included construction costs of £45-55m and annual costs of £2m, but did not include a budget to buy the land needed for the building or any interest payments needed for any loans.