1. An essential failure to follow an “open process” of investigating all possible system architectures (basic design)

As confirmed by staff and consultants in December 2008, sewage treatment planning has been based on an initial assumption that the existing collection system and its Clover and Macaulay end points would form the project’s backbone. In other words, a decision was made right at the start of the project to build on top of the existing collection system. This led to “The Path Forward” which has remained the essential system architecture to present day and provides for one large central plant and three or four smaller plants  in a mildly, decentralized design.

It is difficult to understand why this assumption was made. A more open design process would have allowed the “best and the brightest” to bring forward alternate design possibilities. Unfortunately, that never happened and key questions remain unanswered:

a. Could a system designed around integrated resource management (IRM) of the entire waste stream and unfettered by existing infrastructure assumptions provide a better financial outcome? Would initial capital costs be less? Would net costs, inclusive of operating costs, return on resource recovery and possible avoidance of deferred maintenance, be less?

b. Could such a system provide a better environmental outcome? In particular, could it result in greater greenhouse gas reductions and  a better response to climate change concerns? (It should be noted that GHG reduction has financial as well as environmental implications since the region will likely face increasing “carbon costs” in the near future)

These questions cannot be answered because no opportunity to consider competing design approaches was ever allowed. The core area committee has been presented with hybrid 1, hybrid 2 and hybrid 3 of The Path Forward. It is no surprise that proposals to build additional plants on top of the basic design with option 2 and 3 have proven to be more expensive. A system designed around integrated waste management and resource recovery might have produced a solution providing both lower costs and greater environmental benefits.

 Since alternate designs were not solicited, committee members can have no certainty that the present design represents the best environmental or financial outcome. This is unacceptable when committee members are being asked to commit to spending a billion dollars or more of public money.  Clearly, “due diligence” has not been carried out.

2. A failure to establish how the proposed project fits into a framework of fiscal sustainability for the region

Even with the “mild phasing” suggested recently, the sewage treatment project will cost about a billion dollars plus. This will have a huge tax impact for core area residents. In many cases, homeowners will see tax increases of five hundred dollars a year or more by 2016 for this project alone. This would likely have the effect of “emptying the regional pocket book”. It’s hard to see how other issues of pressing concern including transportation, health care, affordable housing, homelessness, parks, stormwater  and other municipal infrastructure could be financed under such a scenario. Surely, the sewage treatment project should be put through a lens of regional financial sustainability to see how it can be implemented without constraining the region’s ability to address other critical issues. It is simply unacceptable to plan this project independent of the region’s ability to pay for all the other things it must do. (In this respect the sewage project should be of concern to residents of the region who live outside the core area. The tremendous financial drain it creates will likely impact important projects they wish to see accomplished.)

3. The divisive nature of the project and the possible threat to regional governance

Failure to properly address the concerns presented in “#1” and “2” have made planning the treatment project a very divisive process. There is a substantial likelihood that some municipalities within the Core Area will find it desirable to “opt out” of the proposed project or, potentially, even the CRD itself. Opting out by one or more municipalities has to be seen as a blow to the effectiveness of regional government. It is the last thing we need in a time when many issues cry out for more effective regional cooperation. In addition, having one or more municipalities opt out would likely have very serious implications for the viability of the project itself.

4. A lack of flexibility that could limit opportunities for implementation of new technology and opportunities for future development to contribute its share of costs

Present plans would see a large central plant, the most expensive piece of the current design, built in phase 1. Doing so, would establish a clear commitment to a largely centralized system built on top of the existing collection system and would immediately mandate a very large investment. There is good reason to believe, however, that the sewage treatment industry is moving towards decentralized treatment with smaller plants built around resource recovery and  provided on a “just in time” basis where needed. Such an approach could be desirable for individual development projects, for new “complete communities” or for all or part of a municipality. In our region, we already have a “cutting edge” example of such an approach at Dockside Green.

A system design allowing for smaller localized treatment plants built “piece by piece” where and when needed offers several potential advantages. To begin with, it is likely that such plants could be more ideally located for resource recovery. This would be especially true for new complete communities and “centres” anticipated by the Regional Growth Strategy.  Secondly, this approach would offer better opportunities to incorporate emerging new technologies.

Thirdly, new capacity could be built and paid for by new development as it took place. That would allow the development process to absorb some of the costs of providing treatment and would have the effect of reducing the cost to existing taxpayers both through development taking a share and by spreading construction of capacity over a longer period. This is a particularly important given the projected tax impact of the current project.  It’s irrational, however, to expect such an approach if a large investment for a central plant has already been made. Simply put, nobody wants to pay twice, once for the central plant and once more for a localized resource recovery system.

 Finally, a decentralized system could make it much easier to adapt to local or regional changes in capacity needs. It’s possible, for example, that the region will become much more aggressive with water conservation programs. If that happens, demands for treatment of sewage, which is primarily water, could be substantially reduced. Having a number of smaller plants or, even better, smaller plants yet to be built would make it much easier to adapt to such capacity changes. In a similar vein, future technologies changes making localized treatment and resource recovery more attractive could be more easily handled with a decentralized system. Big centralized plants are expensive and have to be built to handle substantial capacity. What happens if localized treatment becomes more attractive?  Will those who “opt out” for localized treatment still want to pay for the big plant? It’s hard to see why they would and, if they didn’t, the viability of the big plant comes into question.

The current project planners have, very recently, introduced some mild phasing which would delay the construction of some of the smaller pieces of the project. This is a positive step but the big plant would still be built very early. If the system is to be built in pieces, there are many good reasons, including impact on taxes, to delay the big plant and the very large expense that comes with it.  

5. The lack of a clear commitment to funding from senior levels of government

Presently, after more than two years of planning and considerable expense, the core area committee has no guarantee of funding from senior levels of government. Staff have indicated on several occasions that senior governments are “on side” and have made verbal commitments but despite numerous concerns expressed by committee members nothing exists in writing. It makes no sense to continue along the current path without firm federal and provincial commitments. What happens, for example, if the province, the federal government or both decide that they are not happy with the current approach and, at best, will fund only part of what is proposed? Such an outcome would only add to the burden anticipated for local taxpayers or would render current proposals unachievable. It is unreasonable to allocate any additional time and money to the current project without firm commitments in writing from senior levels of government.

6. A failure to provide for an adequate public consultation process

There can be little doubt that the consultation process with core area residents has been “too little too late”. Appropriate consultation, which is mandated by the province, should have started much earlier in the process in order to adequately consider public concerns.  The fact, however, that the committee was supposed to make a critical choice on future directions the same day that it received the report on the public consultation process boggles the mind. The report, stemming from well over a month of public consultation, was scheduled as item 8 on the agenda. Item 9 required the committee to decide which of the three options presented they would choose. The public had raised numerous questions and concerns detailed in the consultation report. Nevertheless, after a very abbreviated period of debate, the committee moved on to item 9 and made the critical decision that consultation was supposedly centered around. How can the public have any confidence that their concerns have been considered if this is how they are treated? Clearly, what the committee ended up doing treats public consultation as “window dressing”. That is absolutely unacceptable and is an insult to our citizens.

7. The lack of a cost/benefit analysis that considers the “net environmental gain” presented by the project

The core area of the CRD was mandated to undertake sewage treatment due to environmental concerns. It should be logical, therefore, to expect a cost/benefit analysis designed to determine what environmental benefit will be accomplished by spending a billion dollars or more. I approached this topic at the Core Area Committee by asking if an analysis of the net environmental benefit of the project had been carried out. The answer was “No”. That is unacceptable. Clearly, if the public is going to invest a huge amount of money in this project, and potentially cripple other important initiatives in the region, they should have a very clear explanation of what gains they will get for their investment. In addition, beyond vague descriptions of being “carbon neutral”, there has been no analysis of how this project addresses climate change concerns and there certainly has been no investigation as to whether or not a different system design might respond far better to global warming imperatives.

8. Concerns about the flow of information to the committee

There appear to be good reasons for committee members to be concerned about the manner in which information has been allowed to flow to them. As an example, Dr. Bruce Jank was presented to committee members early in the project as an internationally recognized expert who would provide a “second set of eyes” for the committee. In spite of this, after a period of time, Dr. Janks stopped appearing and no reference was made to him.

Like other committee members, I suspect, I was surprised to see a newspaper article this year that indicated Dr. Jank had been released from his involvement with the project. According to the article, Dr. Jank’s contract was not renewed because he had begun to express concerns about the direction in which the project was proceeding. One has to wonder: “On whose authority did this happen?” Certainly, the committee as a group did not ask to have Dr. Jank removed. In fact, it would appear that committee members did not even know that the removal had taken place.

The newspaper article suggests Dr. Jank was removed because he had become convinced that a resource recovery approach integrating other parts of the waste stream was a better direction to follow than The Path Forward.  If this is true, his views should have been presented to the committee. After all, he had been hired for expressly that purpose. More worrisomely, the whole episode suggests a control of information flow to the committee that is not acceptable.

Another source of information for the core committee should have been the Technical and Community Advisory Committee (TCAC). It would seem logical to assume that creation of this citizen and expert group was for the purpose of providing input and expert review for the core committee. If so, no such input took place. The core committee has received virtually no input from the advisory committee: no reports, no motions and, until recently, not even advisory committee minutes. This begs the question of who this advisory committee was supposed to advise and suggests again a less than optimal flow of information to the core committee.

On a personal level, I spoke to several members of the advisory committee who were very disappointed with how they had been utilized.  

9. Concerns about the process used to evaluate the three options that have been put forward

As expressed in “#1” earlier, the three options, 1A, 1B and 1C put forward by staff and consultants suffer from limitations of a design process that prevented alternatives coming forward to which they could be compared. However, even the process of “internally” comparing the options gives cause for concern. The three options were subjected to a matrix which ranked them from 1 to 5 on a variety of factors with 1 being the lowest score and 5 being the highest. In this ranking, option 2 finished barely behind option 1 which was the highest ranked option. One category in the analysis compared the green house gas (GHG) reductions for the three options. Option 1 provided a reduction of about 450,000 tons and was given a ranking of 3. Option 2 provided a reduction of about 2,450,000 tons and was given a ranking of 4. Thus, only one point separated the two options even though Option 2 produced over 5 times as much reduction. While there was not much context given for these figures, it appeared that Option 2 was significantly better and much more appropriate for meeting provincial climate change goals.

I asked why Option 1 was not given a ranking of 1 or 2 in this category since it was clearly inferior to Option 2. The consultant presenting the information said that I made a good point but no change was made to the ranking. I then asked if the likely future cost of carbon for the region had been factored into the equation and the consultant answered that it had been. Further probing, established that a figure “at the low end of current carbon cost markets” had been used as a basis for comparing costs and benefits of the three options. There can be little doubt that the figure used is not an accurate estimate of future carbon costs for the region. Given these kinds of irregularities, it is interesting that Option 1 was clearly preferred over Option 2 which finished barely behind it in the analysis.

10. Updates as of February 2010

This document was originally written in March of 2009. Section “10” has been added to review additional concerns:

The Process of Site Selection has been an ongoing issue. Initially, “The Path Forward” was presented to the Core Area Committee with DND Land at Macaulay Point in Esquimalt as the central plant location. Several members of the committee asked repeatedly whether or not the DND land was available. Assurances were given that negotiations were going well and that the site would likely be available. This, in spite of the fact that at least one committee member had received information Macaulay would not be available. Well into the process, it was suddenly announced to the committee that Macaulay would not be available and that McGlocklin Point would be the new site. This latter site has size limitations which raised concerns later for the peer review committee. To date, McGlocklin remains the site for the central plant although it is not large enough to include bio-solid processing as well as effluent treatment.

Selection of a site for the Saanich East/North Oak Bay treatment plant (SENOB) has been even more problematic. The original selection process narrowed choices to three sites, one in Haro Woods, a valued community greenspace, and two on the University of Victoria grounds. A fairly extensive public consultation process and evaluation of the three sites was then launched. However, part way through the process, several committee members asked if availability of the University sites had been confirmed. The answer was “No”. It seems rather bizarre to have launched the next step of the process and spent considerable effort and public money prior to confirming that either of the UVic sites was a realistic candidate. Furthermore, before the selection process had concluded, a member of the consultant team stated in a public meeting that the SENOB site would have a big heat pump “down at the plant” and that there would be a loop of over one kilometer to carry heat up to UVic. This description could only fit the Haro Woods site and served to rouse suspicion that Haro Woods had been pre-selected prior to conclusion of the consultation and evaluation process. This did not go down well with some committee members and the local community.

The report on SENOB site selection that eventually reached the Core Area Committee concluded there was no statistically significant difference in the merits of the three sites. Nevertheless, the recommendation was to select Haro Woods, the valued community greenspace. This added further fuel to beliefs that Haro Woods had been the preferred site all along and did much to create mistrust about the site selection process.

Selection of Bio-solid Treatment Technology is another area of concern. The consultant team brought a report to the Core Area Committee indicating that bio-digesters were the preferred option. Other technologies such as that offered by Nexterra Systems, an innovative company based in British Columbia, were dismissed as being too unproven. This was in spite of the fact that Nexterra has several successful plants in place and has been awarded contracts for additional projects.  Interestingly, well before the consultants’ report came before the committee, I was approached by a representative from Nexterra with concerns that his company had not been given adequate opportunity to present their technology.

There is no question that bio-digesters are a viable technology. However, the plan presented would require a site of at least two hectares to house the digesters. In comparison, a Nexterra plant or something similar would require a much smaller site. This should be of concern when the central plant is already on a confined site and property values for any site selected will probably be high. Furthermore, to make bio-digestion viable, it is proposed that sewage sludge will be mixed in with “clean” organic wastes collected throughout the region. There is growing, though not necessarily substantiated belief, that this makes remnant compost material from the digestion process unsuitable for land application. In fact, the Core Area Committee has passed a motion that would forbid the compost material from being applied to the land. This removes a “natural market” from consideration and leaves the whole process dependent on markets such as cement kiln incineration. If those markets do not materialize or disappear, the current back-up option is the Hartland Landfill. That is not an appropriate solution.

It would seem that a more sensible approach might have been to handle bio-solids with a technology such as that presented by Nexterra. This would require much less site area, would allow greater flexibility for the location of bio-solids treatment and would produce considerably less residual product after gasification. The bio-digestion then could have been targeted to the “clean” organic waste stream. Such an option would also allow greater flexibility for bio-digester location and, more importantly, would produce a compost product seen as entirely suitable for land application. There seems no reason to doubt that an ongoing market would be available for such a product.

The Ability of the Current Option to Optimize Resource Recovery has been an ongoing concern for several members of the Core Area Committee. As pointed out earlier, it appears that from the very beginning of this project an assumption was made that the existing system, designed to collect sewage from all around the Core Area and pump it to two points on the ocean, would make sense as the basic architecture or design for a new project intended to maximize resource recovery. Furthermore, there appears to have been little willingness to “open up” the project at any point for consideration of other design possibilities.  

Current directions in the industry seem to suggest that resource recovery is best optimized by designing a system around that goal. Also, it is generally accepted that resource recovery technologies should be located as close as possible to where the resource is going to be utilized. Finally, on a larger scale, there is growing belief that energy and other resource recovery can best be accomplished as part of an Integrated Resource Management or IRM approach to the entire waste stream. The current project, designed around The Path Forward and the existing system architecture, appears to have taken none of these things into consideration. When resource recovery was eventually looked at it was only as an “add on” to The Path Forward. This process created three options that were all essentially variations of the Path Forward design.

Not surprisingly, fears about the appropriateness of the system proposed for optimizing resource recovery appear to have been well founded. A recent report to the Core Area Committee from project consultants concludes that there are limited opportunities for resource recovery. The SENOB plant, for example, has been promoted as an opportunity to provide waste heat to the University of Victoria. Unfortunately, it turns out that the existing heat distribution systems at UVic, to which most buildings are connected, burns natural gas and operates at a higher temperature than sewage heat can economically reach. While there is some opportunity to use sewage heat, it is likely not economic to do so. In addition, the report concludes that there is little opportunity to economically reuse water reclaimed from sewage.

These conclusions bring into question the whole idea of a SENOB plant. There are likely only two reasons to undertake construction of this rather expensive plant: to accomplish resource recovery and to handle flows during wet weather events. If resource recovery opportunities at SENOB are limited, that leaves only control of wet weather flows as a rationale. In all likelihood, such control could be much less expensively accomplished by finding a site for one or more large underground storage tanks that would hold water during storm events and release it slowly when flows were less.

The consultant’s report cites similar problems for resource recovery in the City of Victoria. For some time, the suggestion has been promoted that sewage heat could be used to replace boilers providing heat in existing city buildings. It turns out that many of those buildings, like UVic, have high temperature systems that cannot be easily or economically adapted to use sewage heat. The Legislative buildings, for example, use a steam system. Even if the existing boiler was due to be replaced, the entire system of pipes carrying the heat has been sized according to the temperature of the heat provided. This would appear to make even the future use of sewage heat problematic.

In the end, only pre-heating for bio-digesters and potential re-development in the North Harbour area of the City of Victoria were cited as realistic resource recovery opportunities. There are some resource recovery opportunities when dealing with bio-solids but, as discussed earlier, even this aspect of the project may involve a less than optimal solution.

It is unfortunate that this project appears to be ill suited for resource recovery. The Regional Growth Strategy (RGS) identifies many opportunities for re-development around the region that are expected to be realized in coming years. Had re-development been a central consideration in system design, there might well have been more substantial resource recovery opportunities available. Also, the solid waste function at the CRD is rapidly moving towards “zero waste” and “waste to energy” projects. Clearly, an opportunity exists to create a visionary approach to integrated waste management (IRM) for the entire region. It would be most unfortunate if this opportunity is not fully realized.

The unsuitability of the current sewage project for resource recovery brings to the fore many of the questions and concerns dealt with earlier. With far less than optimal resource recovery, for example, it is unlikely, that environmental benefits will come even close to being optimized. Admittedly, there may be some improvements in the marine environment but other potential gains such as contributions to provincial climate change goals will be realized to a far lesser degree than might be accomplished by another design. This could be of particular concern to provincial authorities. Secondly, if little revenue is realized from resource recovery will this project provide local provincial and federal taxpayers with best value for money spent? It is quite possible that a system designed around resource recovery, utilizing an IRM approach could provide considerably greater environmental benefit at lower net cost to taxpayers. Unfortunately, the failure to consider such design possibilities has meant that they remain in the area of reasonable conjecture. Given these concerns, the “closed” nature of the design process has to be seen as a failure of due diligence and leaves the validity of current project under a cloud of more than reasonable doubt.

Lack of flexibility to incorporate future innovation remains another concern with the current proposal. If a better answer to approaching sewage treatment within the regional waste stream does not exist now, it will likely exist in the near future. There is a very good possibility that such a system would be built around IRM concepts and feature decentralized resource recovery located “where you need it, when you need it”. The current project may stifle such innovative approaches. With its large centralized plant and old system architecture, it would not easily adapt to more advanced design concepts likely to emerge. Furthermore, its very considerable cost and long life span would make adoption of newer system design financially less attractive. To emphasize an earlier point, taxpayers will be paying for this project for a considerable period of time. Would they be willing to “pay twice” in order to implement a better approach. It is unreasonable to expect them to do so.

It is easy to see how this project will likely stifle innovation. The CRD does not “own” the sewage until it hits the main interceptors operated by the region. What would happen if, for example, the Municipality of Saanich decided to implement distributed resource recovery plants in future RGS centres at Tillicum Mall, Uptown, Royal Oak, University Heights and at UVic. Such plants might logically be designed to collect sewage not just from their own site but also from the surrounding area. Under such a scenario, Saanich could end up delivering far less sewage to CRD interceptors then is currently provided. What then? Would taxpayers no longer making use of CRD infrastructure and the large central plant be required to continue paying for it? If not, would those still connected be expected to pay that much more? Neither option can be seen as desirable. In the end, the only way to insure that all taxpayers in the core area continue to pay for the proposed project would be to have each municipality “buy” a certain amount of central plant capacity. That approach, of course, would be a huge constraint to future technological innovation since taxpayers would be required to continue paying for the project currently proposed even if it was no longer in their best interests to do so.

Regional Divisiveness and the West Shore  -  Since this document was originally written in May of 2009, two municipalities in the Western Communities, Langford and Colwood have been given permission to plan sewage treatment in their areas somewhat independently from the processes carried out by the Core Area Committee. While this has addressed some of the divisive feelings, described in section #3, that were emerging from the joint process, it appears to have allowed for only a very limited planning process for the western communities.

At a recent meeting of the Core Area Committee, a report on outcomes from the Western Communities Sub-Committee was tabled. This report recommended a single plant in the western communities with shared treatment of bio-solids at the Core Area bio-digester plant. I asked if: the extra value from resource recovery from a multi-plant scenario had been considered, any solution for bio-solids other than bio-digestion had been considered and if an IRM approach had been considered in any way. The answer was “No” to all questions. Some members expressed the need to get on with site decisions and select some sort of option in order that provincial and federal funding would not be “lost”. This sentiment has been expressed at earlier core area meetings. However, it would seem that a poorly designed solution to the sewage treatment issue is still a poor use of taxpayer dollars regardless of whether they come from local, provincial or federal taxpayers.

The points discussed in this document cover most of my concerns with the process of planning sewage treatment as well as the product that process has produced. Several other members of the Core Area Committee have shared most, if not all, of these concerns. In summary, the process involved has started from a questionable premise to build with the existing system as a foundation and has remained “closed” to other design possibilities. The project resulting from this process has limited potential for resource recovery, will likely provide only limited environmental benefit at great cost to taxpayers and is arguably a poor way to spend local, provincial and federal tax dollars. The project will do little to meet local and provincial environmental goals including the particularly pressing problem of climate change.  In addition, construction 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.

Vic Derman

Member - Core Area Liquid Waste Committee

This page contains a very long document expressing my concerns with the sewage treatment project and the processes that created it. The document was written in 2009 and updated in early 2010.

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