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Politics Ignore Science

  Outfall Marine Life

The Victoria Wastewater Issue – A Historical Perspective


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!


Some History

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.





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”].





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





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

Revenues from dried sludge will simply not materialize

Presentation to the CRD’s Core Area Liquid Waste Management Committee on November 24th 2010

by Dr Shaun Peck

Dr. Shaun Peck, Public Health Consultant

Dr. Shaun Peck, Public Health Consultant

Thank you for the opportunity to speak to you again.

I will address to-day agenda items # 5 Resource Recovery use plan and #7 The Macaulay and Clover Point Wastewater and Marine Environment Annual Report. I would like to complement staff on these two excellent reports. The first one answers many questions that have been in my mind since hearing from your consultants. Many of the concerns that I had are addressed in the summaries or may be included in contract documents. The agenda items can be accessed via:

You have been informed by your consultants that you may expect to receive revenues of $2 Million per year from sending dried sewage sludge to cement kilns. This I have determined is far from the truth. I personally spoke to LaFarge and they informed me that a) they would not consider receiving the biosoldis unless there were other sources to make it economic and b) Paying for the sludge was just not on the cards – they would need to be paid. I am glad to see that this error is not in to-day’s report. It does mean that the current advertised annual revenue of $3.1 Million needs to be reduced to $1.1 Million. The potential revenue generation from disposal of the biosolids is hypothetical.

On November 10th you were informed by your consultants that sewage treatment plants create a noxious, odourous concentrated sludge that is considered a dangerous material and is a Public Health risk to sewage plant workers. (This I completely agree with). Therefore you need to put in extra treatment to treat something you did not need to create in the first place. The consultants are therefore recommending thermophilic anaerobic digesters to produce pathogen free biosolids. This will require a great deal of energy as it does in the present Saanich Peninsular Sewage Treatment plant.

Off Victoria the Ocean treats the screened effluent naturally by biologic and chemical processes after passing through the deep sea outfalls with their diffusers. (It is not dilution – there is an active biological and a chemical process that occurs). On land the treatment plants concentrate the effluent into this noxious, odourous substance. A great deal of energy is later used to dewater the sludge or biosolids as it is planned that they will be thermally dried to increase the solids content to about 95%. The dried biosolids will weigh about 15 tonnes/day.

There have been recent developments in the US related to the treatment of sludge. In the US (whose regulations do not apply to Canada but are often adopted in similar form) the Environmental Protection Agency has released proposed Air Emission Standards Impacting the Management of Sewage Sludge Nationwide. They will have a major impact on the limited options local governments have for the management of sewage sludge.

Rather than encouraging upgrades to newer, cleaner incinerators paired with energy recovery that can offset a significant amount of the energy needs for treating wastewater, the proposed standards will result in many of the US’s wastewater utilities abandoning their significant capital investments and simply sending an energy-rich secondary material for disposal in a landfill.

At this time due to the limited space available for curing of biosolds at the Hartland landfill, the production of PenGrow is limited to about 180 tonnes per year, which represents only 5% of the 3,500 tonnes of residual solids produced annually by the Saanich Peninsular Treatment Plant.

Another issue I would like to draw to your attention to again, is carbon offsets. A University of Victoria Scientist has informed me that:

“There are very clear standards for claiming offsets. You can only claim an offset if a technology is introduced that is replacing an existing technology that is producing emissions. You also cannot claim an offset if you planned to do something anyway.”

Let us be more honest about the carbon footprint. Offsets are being claimed but this is a sham as it does not reduce the original carbon footprint. The annual emissions prior to claiming any offsets, based on one set of calculations from a previous report that you have received, will be the equivalent to the C02e put out by 7,736 automobiles per year.

By building these land based sewage treatment plants there will be an adverse effect on the land (terrestrial) and global environments.

Speaking briefly to Agenda #7. The report reinforces the fact that with the current two deep sea outfalls treating Victoria’s sewage naturally there is no measurable public health risk and a minimum effect on the Marine Environment.

  • · predicted wastewater concentrations in the marine environment met receiving water quality guidelines for the protection of aquatic life,
  • · the potential for sea surface human exposure to wastewaters from the outfalls is low (public health officials have said not measurable), and
  • · there are some limited effects on marine organisms which are restricted to within 100m at Clover Point and within approximately 200m east of the Macaulay Point outfall diffuser. Overall monitoring results…………indicate that the effects of the outfalls are not expanding or increasing over time.

Thank you,

Dr Shaun Peck, Public Health Consultant

Member of Responsible Sewage Treatment Victoria

Board member of the Association for Responsible and Environmentally Sustainable Sewage Treatment.

Wastewater treatment – Is it worth the $1,43 Billion pricetag?

Rob McDermot, PEng, Letter to 4th Dimension, Newsletter, of Victoria Branch Association of Professional Engineers and Geoscientists of BC, October 2010

At the outset I would like to express my sincere appreciation to each of the speakers that contributed to making the September 15 APEGBC meeting the success it was, in particular Mr. Jack Hull, P.Eng – Project manager for the proposed wastewater treatment facility. His agreeing to present knowing full well the positions of each of the other three speakers is truly admirable. None the less, the arguments put forward by each of: Dr. Jack Littlepage, PhD – Biological Oceanographer; Dr. Shaun Peck, MD – former Deputy Provincial Health Officer; and Dr. Keith Martin, MD – Member of Parliament for Esquimalt-Juan de Fuca, lead one to question why the various levels of government feel it is necessary to throw taxpayers money away on a method of wastewater treatment that will have negligible net benefit to the Environment and a HUGE negative net benefit to the pocketbook of every resident of the Capital Regional District.

Each of the presentations put forward were very informative. Mr. Hull provided a polished presentation on the merits of the proposed wastewater treatment facility, which is scheduled to be built at McLaughlin Point for an estimated capital cost of $782,000,000.00 plus or minus 25%… if one were to assume the higher of the estimates, the likely capital cost would be closer to $977,500,000.00. Then there is the annual operating cost of $14,500,000.00 plus or minus 25%. Following the previous logic the likely cost would be $18,125,000.00 each and every year the facility is in operation. Therefore based on a 25 year design-life, the total cost of the facility could be as high as $1,430,625,000.00… or $1.43 Billion. $1.43 Billion is a very dear price to pay, but it’s to protect the environment… so it’s OK, right?

Not so! After listening to presentations from Dr. Jack Littlepage, PhD and Dr. Shaun Peck, MD one realizes that effects of the discharge from the deep-water diffusers are restricted to within 100m at Clover Point and within approximately 200m east of the Macaulay Point outfall diffuser. In fact, to quote the November 2008 Sewage Outfall Monitoring Test Results: The concept of natural sewage treatment has been criticized in the media, but in fact waste treatment is well recognized as a useful ecosystem service contributing to human well-being (Costanza et al., 1997; Boyd and Banzhaf, 2007). The focus of environmental protection is changing to preserving such ecosystem services to the benefit of both human beings and the natural environment (e.g., USEPA, 2008).

It makes no sense to replace a natural ecosystem service with a human creation that is energy inefficient and has other harmful environmental consequences.

All of which leads one to question why this is being endorsed. It is one thing to be blissfully ignorant of the science behind the issue, but to throw away the taxpayers money, our money, on an installation that, according to the scientists and medical professionals, will do absolutely nothing to correct the real dangers to our waters, (Arsenic, Chromium, Lead, Zinc, Mercury, PCBs and PBDEs) is irresponsible! Keep in mind the cost to build and maintain this less than effective solution could be $1.43 Billion… that’s more than the cost of 18 new Johnson Street Bridges, or 59 McTavish Rd/Hwy 17 Overpasses, to build a facility that could end up having a greater negative impact on the Environment as a whole than if we left the situation the way it is!

Toward the end of Dr. Jack Littlepage’s presentation he listed the following items as requisites for the protection of the marine environment:
Inclusion of the present system (plus enhancements) in the “triple bottom line” (environmental, social, economic) comparison of options

  • Greater public understanding of the Victoria Marine Discharge System
  • Action on more pressing marine environmental* and public health issues
  • Action on storm sewer discharges and their connections to sanitary sewers

*Habitat protection, prevention of introduction of non-native species, regulation of fishing practices, elimination of some persistent pollutants

He concludes his presentation with this rather telling statement: “Land-based treatment of Victoria’s sewage is a low priority for marine environmental protection,” and to back up his statement he cites the Marine Pollution Bulletin, October 2008. If an expert in the field of Oceanography feels that the proposed wastewater treatment facility is a “low priority” and if the former Regional Medical Health Officer feels “there is no measurable public health risk from Victoria’s current method of offshore liquid waste disposal…”, then why is this facility being built?

It is not too late for us to have our opinions heard. This Wastewater Treatment Facility is not a “done-deal”, but the window of opportunity to have our opinions heard is fast closing. It is critically important to let those in power know how we, the taxpayers, feel about this decision. If you are interested in saving yourself somewhere in the neighbourhood of $400.00 to $500.00 of taxes per annum for as long as you choose to live in Greater Victoria, then please visit the websites ARESST (The Association for Responsible and Environmentally Sustainable Sewage Treatment in Victoria) and RSTV (Responsible Sewage Treatment Victoria)

Please make your voice heard.

Rob McDermot, PEng

Published on: Oct 25, 2010 @ 12:09
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Sewage project damage will be irreversible

Ted Dew-Jones, letter to Victoria News, October 22, 2010 6:00 AM

University of Victoria oceanography professor Jack Littlepage, who wrote one chapter of my book Victoria’s Sewage Circus, points out that “we should be promoting our system as one of the most efficient and environmentally sound systems in North America.”

Nobody knows more about it.

To change to land-based secondary sewage treatment plants would be environmentally backwards. The proposal to do so is based on lack of knowledge.

Such a proposal does not yet take account of the environmental and health damage that the building and operating of land-based plants would cause.

The politicians will die but the environmental and financial damage will go on generation after generation for the change is irreversible. Environment Minister Barry Penner is out of his depth. Must we and our environment all suffer?

Published on: Oct 24, 2010 @ 11:41
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Tags damage, Dew-Jones, environment, environmental, land-based, Littlepage, sewage, treatment
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Advocacy group seeks answes to to greater Victoria’s sewage questions

Roszan Holmen, Victoria News and Saanich News, October 14, 2010

As ARESST passes its one-year anniversary, the activist group opposed to secondary sewage treatment continues to questions the changing plans of the Capital Regional District.

Under the microscope now is the proposal to put a sludge treatment plant at the Hartland Landfill or an alternative site.

“We’re questioning what they’re going to do with it,” said Shaun Peck, former medical health officer for the B.C. Health Ministry and a board member at large for ARESST. “Are they going to turn it into energy on site? Are they going to send it to cement kilns in Vancouver by barge? They’re talking about all these things.”

Peck points to a great deal of uncertainty about the environmental effects of treating sludge.

At its core, ARESST opposes the province’s directive to the CRD to introduce a secondary sewage treatment system.

It believes the current plan will be costly but do nothing to improve the health of our ocean environment and little to prevent trace amounts of chemicals.

The greenhouse gases produced by the plants would equal emissions 7,736 automobiles annually, said Peck.

“The two deep-sea outfalls that treat the sewage naturally would no question be the best thing to do from an environmental point of view.”

While the CRD is working to meet its commitments, Peck insists no decision is irreversible until a contract for the construction has been signed.

ARESST has about 80 members. It hosted its annual general meeting last night in Victoria. University of Victoria professor emeritus Jack Littlepage gave a public lecture before the event.

The CRD was ordered to create a secondary sewage treatment centre by the B.C. Environment Ministry. Costs to construct and run the facilities could be as high as $800 million.

The McLoughlin Plan is the wrong plan

A gross misuse of a public treasure — and a wasteful system to boot

John Motherwell, PEng.

John Motherwell, PEng.

John Motherwell, Bob Furber and Alex Murdoch, Special to Times Colonist, September 23, 2010

Capital Regional District board chairman Geoff Young defended the choice of McLoughlin Point as the site of a sewage treatment plant, citing “significant resource recovery, lower cost and reduced impacts on neighbourhoods” plus “social, economic and environmental sustainability.”

We disagree, and support Esquimalt council in its call for a second look.

McLoughlin Point is a magnificent setting and, as View Royal Mayor Graham Hill has remarked, if this were Sydney, it would support an opera house. Treating it simply as available industrial land would be a gross misuse of a unique public treasure and this alone has upset many people.

But even if that were not an issue there is a great deal wrong with the McLoughlin Plan. And many of the “advantages” cited by the CRD board are wishful thinking at best.

Modern, efficient treatment plants generate energy through heat recovery and methane production, often enough to supply 80 per cent of their needs. But McLoughlin Point will not house a treatment plant, but rather half of a plant, the other half to be up to 18 kilometres away and connected by two large pipes — a system dictated by the fact that the site is too small!

Designers strive to integrate plants as closely as possible and we know of no other case where components have been so widely separated.

This is an extremely inefficient system demanding huge amounts of energy, and any “recovery” will be a fraction of that expended; to suggest that there will be a surplus is to ignore the laws of physics.

Methane generated at Hartland could be sold, but that energy would have to be replaced at McLoughlin through the purchase of electricity — essentially a shell game. The suggestion that phosphorus (fertilizer) and/or dried biosolids (fuel pellets) could be sold ignores the fact that production costs (in dollars, energy, and greenhouse gases) would be many times the value of the finished products. Digging up roads and existing utilities for pipelines and pumping stations would be costly and very disruptive.

Young says a tunnel under Esquimalt Harbour to supply a West Shore plant would be “an extremely high-risk and high-cost endeavour.” We agree, but note that the McLoughlin option requires not one but three large pipes beneath Victoria harbour — one delivering sewage (mostly water) from the Victoria side, one with a thicker “slurry” to the solids plant, and one returning still-contaminated water from the solids plant for reprocessing at McLoughlin.

He states categorically that “there will be no problematic odours” and that “planned redundancies … will prevent any discharge of raw sewage into the harbour” — essentially “Trust us, nothing can go wrong.”

But all such plants (even the CRD plant at Bazan Bay) produce odours and, although these are commonly mitigated, malfunctions can be very unpleasant indeed. As for the impossibility of spills, Halifax is still cleaning up the mess discharged into its harbour by a malfunction two years past.

And those pipes below the harbour in a high-risk seismic zone?

Murphy’s law applies: Things will go wrong.

- John Motherwell is a practising civil engineer who designs sewage treatment systems; Bob Furber is a retired chemical engineer with experience in both sewage treatment and resource recovery; Alex Murdoch is a director of the Society for Responsible and Environmentally Sustainable Sewage Treatment [].

For a Tax revolt, think of Sewage

Times Colonist, letter from John Vukovic, September 07, 2010

Many people are upset with the harmonized sales tax and the impact this tax will have on their lives. For some it may be substantial, but for most it is really just a few extra dollars a year.

Because it is a consumption tax you can choose to buy an item or not. As for the tax dollars collected, they go toward paying for all the services our government provides, such as health care and education. These are direct benefits for all British Columbians.

Compare that to a billion-dollar sewage plant in Esquimalt that no one wants, scientific evidence says we don’t need, will not significantly improve the quality of the discharge liquids, will do nothing to stop contaminants from entering the system at the source, will not fix our antiquated infrastructure, will cost every household in greater Victoria up to $500 per year in additional property taxes and will not directly benefit us in any way.

Where is the petition to stop this gross misdirection of public policy and waste of my hard-earned tax dollars? Why do we sign a petition against a tax that doesn’t change 80 per cent of the items we purchase yet there is no revolt against $500 added to your property tax for something that will not benefit you?

John Vukovic

Time to Rethink Sewage Plan

Time to rethink entire sewage plan

Dr. Jack Littlepage

Dr. Jack Littlepage, Professor Emeritus, University of Victoria

Jack L. Littlepage, Times Colonist, July 27, 2010

If anyone in Victoria doubts that the CRD is hopelessly mired in sewage they need only to read the report of last week’s CRD committee meeting.

View Royal Mayor Graham Hill summed it up by saying too many of the CRD’s decisions are being driven by funding, not poop.

It is time to look at what we are getting for our $780 million-plus: A liquids-only sewer plant on prime harbour waterfront, pipelines to Hartland, unspecified biosolids treatment (somewhere) and annual operating costs in the millions.

We are not getting improved health benefits, environmental enhancement or elimination of deepwater marine outfalls. This is confirmed by volumes of local, national and international reports.

The CRD sewer committee should revisit its goals and adopt a waste-water treatment system that emphasizes environmental protection.

Currently, they are focused on technical solutions without regard to environmental impacts.

With some improvements to our current treatment system and minor changes to proposed regulations that would recognize the concept of initial dilution-zone mixing we can easily meet or exceed the national standards for environmental protection as well as meet Environment Minister Barry Penner’s requirement for additional treatment.

And we would still have money left over to tackle real problems such as storm drain outfall systems, social housing and community health.

What ever it takes – Esquimalt residents ready to fight sewage treatment plant

Whatever It Takes! – Esquimalt residents ready to fight CRD’s sewage treatment plan

Esquimalt, Tim Morrison, July 27, 2010 at 6:03 pm

It was a hot summer evening last week at Esquimalt Municipal Hall….hot in temperatures and hot in tempers.

Of note, there was absolutely no CRD representation in attendance to hear the concerns of the community during this traditional Town Hall-style Meeting….not even one CRD official had the decency or, more likely, the courage to face the people most impacted by a the CRD’s irresponsible planning. One speaker after another lined up to point out the many foibles of the project, often referred to as “billion dollar boondoggle”.

Outrage at Esquimalt Chambers towards CRD

The crowd included experts, engineers, and environmentalists, all of whom pointed out that the project is not only too costly at $300 per year per household, but that it also hurts more than helps the environment.

The people of Esquimalt stressed that this is not about NIMBYism (Not In My Backyard syndrome), but rather more about common sense and doing what is in the best interests of the environment and the taxpayers. All of the public input pleaded with Council to do “whatever it takes” to halt the project from becoming reality, a message heard loud and clear by Council.

“This is not just an Esquimalt problem,” declared Mayor Barb Desjardins. “This is a regional disaster that is occurring. This is not the right plan.”

Councillor Don Linge, a lawyer by profession, described the situation as “a classic class-action case in which we are all impacted” in referring to the need for all CRD residents to join forces in stopping the project through whatever legal means available.

Councillor Randall Garrison vowed that he was willing to play nice with the CRD and approach the matter rationally to negotiate a solution in the best interests of Esquimalt, but if the CRD continue to ignore our community, then he is prepared to have Council obstruct the project through whatever means possible including bylaws that would ban trucking in/out of the site.

As the evening wore on and as both the public and Council expressed themselves so passionately, it became abundantly clear that the CRD have picked a fight with the wrong community and one that will not standby and allow this project to be bulldozed into our home.

“We are Esquimalt, we are proud, and we have a voice,” declared Councillor Meagan Brame.

Esquimalt’s next move will likely involve legal action against the CRD in a case of taxpayer suing taxpayer…a mess all of the CRD’s making and a mess much more revolting that anything in our sewage system.

Residents take action against sewage treatment in Esquimalt

Residents take action against sewage treatment in Esquimalt

Erin Cardone, Victoria News, July 16, 2010 2:59 PM

John Bergbusch and a team of Esquimalt residents are pounding the pavement this weekend.

Armed with 4,500 fliers with details and opinions on the Capital Regional District’s plans for a sewage treatment site at McLoughlin Point, the group are trying to rummage up folks to attend a special public meeting Monday (July 19).

Esquimalt council hopes to get public opinion on the sewage plan, which has already been sent to the province for approval.

“From there, they’ll come up with some sort of action plan based on residents’ comments,” said Carolyne Evans, the township’s manager of corporate services.

Bergbusch hopes enough residents will come to the Monday meeting that council chambers will overflow with people. A member of ARESST – the Association for Responsible and Environmentally Sustainable Sewage Treatment – Bergbusch is upset with the planning process and in disagreement with the CRD’s position that land-based treatment is necessary.

“We want to see residents out at the meeting to give council the ammunition to say ‘absolutely not’ (to the McLoughlin site),” he said
on a break from distributing pamphlets.

He added he’s confident a major groundswell could change CRD board members’ minds on the issue.

“I believe ultimately the CRD board and Minister (of Environment Barry Penner) will come to their senses.”

ARESST isn’t the only group opposed to a sole sewage treatment facility at McLoughlin Point.

“We feel quite slighted by the CRD and we support Esquimalt council in its efforts to hold the CRD accountable,” said Tim Morrison of the Esquimalt Residents’ Association. “The residents of Esquimalt are united with council in opposition to the CRD and in outrage to the way the CRD is ramming through a project that has received no meaningful consultation and no input from the people that are the most negatively impacted.”

The township’s mayor and councilors have all spoken strongly against the CRD’s sewage plan.

The meeting is at Esquimalt council chambers, 1229 Esquimalt Rd., 7-9 p.m. on Monday, July 19. To contact Bergbusch, call 250-532-2600.