Report to the Core Area Liquid Waste Committee
Submitted by committee member Councillor Vic Derman
June 9, 2010
Events that have unfolded since amendment #7 to the Core Area Liquid Waste Management Plan was sent to the province, have added to my concerns about the current sewage treatment project and the processes that created it. On January 27, the CRD Core Area Liquid Waste Committee received two reports from consultants indicating that opportunities for resource recovery at the University of Victoria and in the James Bay area could not be economically realized. This was very surprising since these “opportunities” had been strongly promoted as a “green feature” of the project for a considerable period of time. In the case of UVic, it would appear the fact most UVic buildings are connected by a high temperature natural gas system incompatible with lower temperature sewage heat remained “undiscovered” for a considerable period of time. Similarly, the legislative buildings had been promoted as a prime opportunity in the James Bay area even though the precinct is currently heated by a very high temperature steam system that, if anything, is even less suitable for lower grade sewage heat. Conversion could only come at great expense and considerable disruption.
On April 28, 2010, two concerned citizens presented information from the CRD’s own data to the Core Area Committee demonstrating that system capacity has been designed around out of date flow data that over estimates current and potential future flows by as much as thirty percent. This also came as something of a shock since one would assume that project designers had used the most current flow data available.
Total flows are, of course, one of the critical factors that determine the size of treatment facilities that need to be built. Another critical factor is “organic” load and the subsequent biological oxygen demand (BOD) that treatment facilities must deal with. Recently, the same two citizens suggested that a program aimed to reduce the organic load in the system might, in combination with lower flows, allow a system to be built with considerably reduced capacity. Reducing the capacity of the facility constructed usually results in savings. Since, in the CRD project, available sites for central plants are constricted, savings could be dramatic. Meaningful reductions in capacity could result in one or more expensive satellite plants becoming redundant. Eliminating these plants could result in savings of more than a hundred million dollars.
Cause for concern
These issues are substantive and should be cause for concern. Especially, when they follow other significant issues including:
More logical approach
It would appear that a decision to build the project around the existing “big trunk” architecture was made very early in the planning process. In turn, this decision precluded any opportunities to see if alternative architectures, plant locations and technologies might have been able to provide better environmental and financial outcomes. Of particular concern, the project was planned in isolation with little attention to an Integrated Resource Management (IRM) approach to regional waste streams. In fact, resource recovery seems to have been treated as an “add on” and is hardly realized at all in the current project. A more logical approach might have designed the sewage treatment project around four basic goals:
As detailed above, there is little evidence to suggest that the current project was designed around any of these goals. Not surprisingly, it does not seem to come close to accomplishing any one of them. For this reason, the project, as currently proposed, would appear to be a poor way to spend scarce regional and provincial tax dollars.
Collectively, these issues and concerns must be seen as very significant. The Core Area Committee is poised to carry out a project involving what is likely the largest single expenditure this region has ever undertaken. The project will have huge implications for the future direction of the region as well as its ability to address a myriad of complex and costly additional concerns. It is critical that the Core Area Committee get this project right. It is certainly past time to take “a long sober second” thought at the project as it now exists. With this in mind, I am suggesting the following approach.
Phase One: Evaluation
That as Phase 1 of the project, the Core Area Committee undertake to work with staff, other CRD committees and the province to evaluate the current proposal against the four basic goals described above. Such an evaluation should include an analysis of net environmental benefit as well as a cost benefit analysis. That as a second part of Phase 1, the committee undertake the following specific actions, as soon as possible, to investigate alternative approaches and address at least some issues of concern for receiving waters:
That major capital works that would involve very considerable expenditures and would commit the Core Area irrevocably to a specific project direction be postponed until Phase 2 of the project.
Maximum benefit at minimum cost
Adopting this sort of approach to the project would provide a number of substantial benefits. Firstly, an enhanced source control program, implementation of storage tanks and removal of additional solids could provide almost immediate improvements for the effluent entering receiving waters. It is quite possible that these improvements, by themselves, might allow the effluent to meet emerging federal standards. Furthermore, commitment of resources to dramatically enhance the source control program would likely provide improvements in the area of emerging contaminants beyond those achievable by the project currently proposed.
Secondly, the time period from Phase 1 to Phase 2 would allow the committee to re-evaluate the current project and insure that maximum environmental benefit will be accrued at the lowest net cost to taxpayers. Maximizing achievement of these two goals could go a long way to insuring the region meets its environmental obligations, including response to climate change, while helping to insure that the project fits into a sustainable fiscal framework. Furthermore, the time from Phase 1 to Phase 2 would allow the committee to insure that the project is consistent with development patterns proposed by the RGS and allows for maximum possible flexibility to accommodate emerging changes in technology and system design.
I am not one who believes that the current practice of dumping into the ocean should be continued much longer. However, the sheer scope of this project and its impact on the future of the region demand that we get it right. It is not sufficient to suggest that we “have gone too far down the road” to consider significant change. Instead, it is absolutely imperative to insure that the residents of the region get the due diligence they should expect and wise use of scarce regional, provincial and federal tax dollars.