Frequently Asked Questions
Who is ARESST?
ARESST is a group of Greater Victoria residents including physicians, scientists and engineers, deeply concerned about the local environment, who believe that potentially disastrous mistakes are being made in the rush to design and build a land-based secondary sewage treatment system by an arbitrarily imposed deadline. We believe that changes and improvements to our liquid-waste management system should be based upon science and sound engineering practice, and should incorporate what has been called “the most efficient and environmentally sound system in North America” – the existing combination of preliminary screening and deep-ocean diffusers.
What does ARESST hope to achieve?
To stop the Provincial government 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 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 nation’s 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?
Regulators have proposed a switch to “end of pipe” standards, mimicking US regulations which ignore the nature of the receiving waters. The US National Research Council, in the report of a three-year study concluded in 1993, urged that standards be based upon the effect of a discharge on the receiving environment, but this has been opposed by legislators and many environmental groups on the grounds of “fairness” or a “level playing field.”
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 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 ammonia 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.
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 cBOD5 (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 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 what about other contaminants: petroleum products, heavy metals, pesticides, PCBs and fire retardants, pharmaceuticals and personal care products?
The treatment systems being proposed are designed to address only the substances specified in the regulations [suspended solids, organic matter, nitrogen and chlorine] and will not destroy such contaminants, which will either remain in the discharged effluent or be concentrated in sludge. The only real solution to such substances is to prevent them entering the waste-water stream in the first place, by outright bans or interception at source.
Some of these contaminants have already been reduced through the CRD’s existing source-control program, which has produced reductions on the order of 90% in lead, mercury, oil and grease, etc., but much more could be done.
But treatment was ordered by BC’s then-Environment Minister Penner. Wasn’t 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 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!
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 or 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 approved by the Minister subject to completion in final form by June 30, 2010 – another impossible deadline which was addressed by the submission of another vague proposal. There is still no final plan!
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 about $800 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 about $230 million of the capital costs, but neither government has made a firm commitment. Even with 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. 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 – now the major source of contaminants – 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?
Environment Canada has reportedly received a significant response since the proposed new Regulation was gazetted in March 2010, much of it taking issue with the “one-size-fits-all” approach. The Federation of Canadian Municipalities has stated that if the Federal Government applies this standard blindly the capital cast could exceed $30Billion. We believe the Regulation can still be amended to recognize local environments.
What are the requirements in Europe and the USA?
As noted above, the US Clean Water Act sets a common standard for all. This has been challenged as illogical by the scientific community but largely supported by legislators and regulators “fair” and easier to enforce than a more flexible standard. However, the Act provides for exemptions and a few cities [notably Honolulu and San Diego] have been granted such exemptions after exhaustive studies showed that their non-conforming systems had a superior environmental impact.
European regulations specifically permit (and encourage) natural solutions – especially when the effluent is discharged into open ocean waters.
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, expanded recycling, more use of natural filters in our storm-water system.
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.
For more information visit RSTV.
CRD reports are on various pages of the CRD website