FOCUS

WHEN SENIOR GOVERNMENTS IMPOSE unreasonable regulations that have no useful outcome other than to
create vast profits for engineering and construction companies, what are communities to do? Should they huff and
puff and fall all over themselves in order to meet an unreasonable regulation by some artificially-important date?
risk of causing harm to the public or to the environment, in the absence
of scientific consensus that the action or policy isn’t harmful, the burden
of proof that it’s not harmful falls on those taking the action.
There is actually strong scientific consensus that the current method
of marine treatment is not causing harm. Regardless, shouldn’t the
precautionary principle also be applied to the action being demanded
by the Province and Environment Canada? Shouldn’t the proponents
of treatment bear the burden of proof that what they propose will not
cause harm? There are reasons to be concerned that what the CRD
hopes to build will cause harm to both the environment and humans.
Let me give you one example.
In last month’s edition I wrote about a peer-reviewed study prepared
by local DFO research scientists Sophie Johannessen, Rob Macdonald,
and others. Their study looked at the impact secondary sewage treatment
would have on environmental conditions in our waters. The
study’s authors stated: “Secondary treatment…will reduce fluxes of
some contaminants, but will have negligible effect on regional budgets
for organic carbon, nitrogen, oxygen, metals and PCBs. Removal of
PBDEs from wastewater will affect regional budgets, depending on
how the sludge is sequestered.”
Johannessen’s and Macdonald’s study indicated, then, that the
only substantial difference that secondary treatment could make
would be removal of some contaminants, especially polybrominated
diphenyl ethers, which are used as flame retardants in a variety of
household objects.
As I mentioned last month, PBDEs are persistent organic pollutants
and are thought to be endocrine disruptors. They may produce adverse
reproductive, developmental, neurological, and immune effects in
both humans and wildlife. There is broad concern that PBDEs, like
PCBs, bioaccumulate. (See the 2014 US EPA fact sheet for more information
on the language scientists are using regarding these effects.)
Environment Canada and Health Canada have stated it’s their objective
to reduce the concentration of PBDEs in the Canadian environment
“to the lowest level possible.” Consequently, the manufacture and use
of PBDEs have recently been banned in Canada.
According to scientists, the three main pathways for PBDEs to enter
marine waters are atmospheric deposition (44-56 percent), sewage
(25-38 percent), and surface runoff (18 percent). Here’s how PBDEs
get into sewage effluent: First they are released from something in our
home that contains them—like a foam mattress—and attach to particles
of dust, some of which settle on our clothing. Finally, when we
wash our clothes the PBDEs head to the Strait of Juan de Fuca through
the sewers. Secondary sewage treatment could remove as much as 80
percent of the estimated 8.3 kilograms of PBDEs currently discharged
through Victoria’s outfalls each year. Diverting 80 percent of that—
just under seven kilograms a year—was the only potential environmental
benefit Johannessen et al identified that could be obtained from spending
a billion dollars on secondary sewage treatment.
But even obtaining that small benefit would depend on what happens
to the end product of sewage treatment—the biosolids. As I wrote
last month, none of the current avenues available to the CRD for
disposing of these contaminated biosolids would safely isolate or
destroy the PBDEs.
Anaerobic biodigestion doesn’t affect PBDEs. Landfilling the
biosolids would result in ever-increasing levels of PBDEs in the
landfill’s leachate. A study by BC scientists of the level of PBDEs in
Comparative cost estimates: McLoughlin Point, Rock Bay, Option 10
Development cost* McLoughlin Point** Rock Bay*** Option 10****
Liquid Treatment Plant(s) $351 M $416 M $25 M
Outfall(s) $38 M $43 M $120 M
Conveyance and pumping $176 M $246 M $35 M
Land $13 M $67 M $0
Biosolids Treatment $347 M $258 M $0
2015 Subtotal $925 M $1030 M $180 M
2020-2030 I&I reduction $420 M $420 M $0
2030 Additional Treatment Capacity $253 M***** $253 M***** $0
Total out to 2030 $1598 M $1703 M $180 M
Notes
* Includes all contingencies, engineering, project management, CRD administration, inflation to mid-point of construction, etc
** Based on independent study by Ernst & Young, 2010, plus 11.5 percent inflation since
*** Lowest cost option, one-plant secondary treatment, biosolids treatment at Rock Bay
**** Based on comparisons with similar project estimates
***** The need for additional treatment capacity is expected as soon as 2030. This estimate if from the Rock Bay estimates by Urban Systems/Carollo
www.focusonline.ca • February 2016
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