February 15, 2010

The Honourable Barry Penner

Minister of the Environment

Province of British Columbia


Dear Minister Penner:


This “open” letter to you is intended to provide a minority opinion on the sewage treatment project being conducted by the Core Area Liquid Waste Committee of the Capital Regional District. I wish to state categorically that I am not opposed to stopping “dumping” sewage into the ocean. I am concerned, however, that the proposed project and the processes that produced it are fundamentally flawed.


In your letter of December 14, 2007, you conveyed to the core area committee your desire to see the sewage treatment project accomplish amongst other things the following: a) Minimize project cost to the taxpayer by maximizing economic benefits, including beneficial use of resources and generating offsetting revenue, b) Optimize the distribution of infrastructure based on the goals in “a”, c) Aggressively pursue opportunities to reduce and minimize greenhouse gas (GHG) emissions (e.g. Reduced requirement of energy for pumping purposes and beneficial reuse of energy) and d) Optimize ‘smart growth’ results (e.g., district services, density, ‘Dockside Green’ like innovation). I would contend that none of these requirements are even close to being met by what has been put forward to you.


It appears that the currently proposed project will provide minimal opportunities for resource recovery and offsetting revenues, as confirmed by a recent report to the core area committee from project consultants. This failure stems largely from the fact that distribution of infrastructure was determined primarily by a decision, at the start of the project, to use the existing system as a basic architecture or design for a new system and to not “open up” the project to other design possibilities. Consequently, limited resource recovery opportunities and continued effluent pumping around the region make it likely that GHG reduction will be far less than optimal. Finally, the selection of very traditional system architecture and infrastructure will do little to accomplish any “Dockside Green” type innovation.


As currently proposed, the sewage treatment project will likely provide only limited environmental benefit and will do little to meet significant local and provincial environmental goals such as the particularly pressing problem of climate change.  In addition, the very considerable cost to taxpayers will likely constrain the ability of the region to deal with other pressing problems and is arguably a poor way to spend local, provincial and federal tax dollars. This should be seen a particularly problematic in a time of limited resources for all levels of government. Furthermore, the considerable cost and long life of the proposed project will likely constrain the region’s flexibility to adopt more enlightened and environmentally appropriate approaches for the foreseeable future. Of greatest concern to me, however, is the sense of opportunity lost. In the face of an opportunity to create a truly visionary approach to management of all “waste” streams in the region, this project has proceeded in a “blind”, isolated manner and appears set to produce outcomes that are not even a shadow of what is possible.


I realize that it is not appropriate for the Capital Regional District to continue “with business as usual” as an answer to dealing with sewage issues. I would, however, suggest, that some combination of the following might allow a much more appropriate solution to be accomplished:


1. That the Capital Regional District (CRD) be required to immediately begin development of an Integrated Resource Management (IRM) strategy for all waste streams including sewage and that this approach should be designed around explicit goals to maximize environmental benefits and minimize net cost to taxpayers.

2. That the CRD be required to demonstrate that implementation of such a strategy will take maximum advantage of developments proposed by the Regional Growth Strategy (RGS).

3. That the CRD be required to dramatically expand its source control program which has already resulted in very significant reductions of heavy metals and other undesirable materials in sewage.

4. That the CRD and its member municipalities be required to establish new, more progressive criteria for the management of stormwater which is a very significant source of pollution in receiving waters and that plans for immediate application of such new criteria be required.

5. That the CRD be required to provide, as soon as possible, for the construction of pilot plants in appropriate locations that would serve to move towards the goals in “#1” while allowing the opportunity to evaluate innovative approaches to treatment of sewage, and the rest of the waste stream, as a resource.

6. That as an interim solution, the CRD be required to put in place underground holding tanks that could deal with problematic overflows currently occurring in the eastern part of the CRD sewage system.

7. That Core Area CRD municipalities be strongly encouraged to deal with problems of Inflow and Infiltration and that they be supported in efforts to do so.

8. That as an interim solution, the CRD investigate how additional suspended solids might be removed from effluent with the resulting bio-solids being treated in an appropriate resource recovery facility.


It is unfortunate, that this type of program has not already been implemented in the CRD. However, in this case, the old adage of “better late than never” would certainly seem to apply. I believe that moving to “sewage treatment” provides an incredible opportunity for the CRD to develop a visionary, world leading approach to dealing with its “waste streams”. Such an approach could do much to insure the region’s financial stability while making very significant contributions to provincial and regional environmental goals and serving as a “shining example” to other jurisdictions in our province and country. I hope that a chance to accomplish this opportunity will be allowed to develop.  I have attached as an appendix a paper that details more completely my concerns about the project currently in front of you.


     Respectfully,



     Vic Derman, member, Core Area Liquid Waste Committee


CC:

The Right Honourable Gordon Campbell, Premier, Province of British Columbia

The Honourable Bill Bennett, Minister of Community and Rural Development

Mr. Doug Konkin, Deputy Minister of the Environment

Mr. Dale Wall, Deputy Minister of Community and Rural Development





Below is a letter I wrote to then Minister of the Environment, Barry Penner, early in 2010 expressing my concerns with the direction the sewage treatment project had taken.

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