FOCUS

WE ARE IN A CRAZY-MAKING SITUATION: The community’s political leaders are being stampeded to
meet funding deadlines for a billion-dollar construction project—one that has been justified by the technocrats
entirely on environmental grounds—without having any plan for how to isolate or destroy the toxins
a treatment plant will produce.
treatment facilities. At both locations three large axial-flow saltwater
pumps would draw water from the ocean and swirl that a couple of
times around the tank, mixing it thoroughly with a smaller stream
of effluent coming from the existing screening and settling facilities.
The mixture of seawater and effluent would then drain by gravity
through a kilometre-long outfall.
The ratio of seawater to effluent would be carefully controlled by
continuous sampling of the concentration of suspended solids in the
super effluent being discharged through the outfall. Each of the new
outfalls would need to have significantly greater hydraulic capacity
than the existing outfalls; that’s because the effluent discharged by the
outfall’s diffuser (think of a giant underwater lawn sprinkler) would
contain up to 90 percent seawater. With such a system, the Fisheries
Act regulations that are currently holding Victorians hostage for a
billion-dollar ransom could be met.
The Fisheries Act regulations don’t prohibit the discharge of effluent
from sanitary sewers, they simply specify the allowable levels of four
different characteristics common to all sewage. Victoria’s sewage effluent
exceeds the allowed value for only two of those characteristics: suspended
solids and carbonaceous biochemical oxygen demand. All the community
needs to do is dilute its effluent to meet the Fisheries Act regulations.
During drier weather, the effluent that flows out of the outfalls at
both Macaulay Point and Clover Point exceeds the regulatory limit
on suspended solids by a factor of about 10. By adding 9 litres of
seawater to every litre of effluent, the concentration of suspended
solids in the resulting super effluent would meet the technical requirements
of the Fisheries Act regulations. By meeting the regulations’
limit on suspended solids, the regulatory limit on biochemical oxygen
demand would also be met.
This strategy would also meet the intention of the Fisheries Act
regulations, which is to ensure that water is not “deleterious to fish or
fish habitat or to the use by man of fish that frequent that water.” In
the case of sewage effluent, the “water” the Act measures and regulates
is the water inside the sewage outfall.
The Fisheries Act regulations are intended, in effect, to protect a
hypothetical fish that is swimming inside an outfall. Although there
is no evidence that fish are swimming inside either of Victoria’s outfalls,
according to the regulations that doesn’t matter. Perversely, the regulations
have nothing to say at all about the condition of the water
immediately outside the outfall, where actual fish can be found.
As a tool for environmental protection, then, the Act’s wastewater
systems effluent regulations are exceedingly blunt. Those 10 local
marine scientists were being too polite when they characterized the
regulations as “one size fits all.” They’re unreasonable.
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?
In such a situation, protecting the economic integrity of a community
by simply diluting the effluent inside the outfalls so that it conforms
with the Act and goes no further seems a reasonable response. The
Act doesn’t prescribe how to conform to the regulations—that’s left
entirely to the affected community.
Let me whet your appetite for this idea with a cash bonus that would
completely pay for Option 10. Both Mayor Jensen’s and Mayor Helps’
options would cost in excess of $1 billion. But with both there would
be significant additional cost just down the road. Both options would
require the City of Victoria, Saanich, Esquimalt and Oak Bay to spend
hundreds of millions on reducing the amount of rainfall and groundwater
that is leaking into sewers. Capital and operating costs for sewage
treatment increase with the volume treated, so eliminating rainwater
saves money. The CRD has estimated that would cost $420 million for
the municipalities participating in the treatment project, but that cost is
not included in the billion-dollar price tags. The City of Victoria’s engineering
department has estimated $330 million for the City of Victoria
alone to eliminate its inflow and infiltration “problem.”
With Option 10, though, inflow and infiltration aren’t a problem.
Instead, they’re a natural benefit—a gift from the sky—that helps to
dilute the effluent and reduce the concentration of suspended solids
closer to the Fisheries Act regulations’ limit. That extra water would
reduce the amount of seawater that needs to be pumped and thus
would lower the operating costs of Option 10. Under Option 10, the
region would save not only the $800 million difference in capital cost
for treatment compared to the CRD’s options, but also the $420 million
cost of waterproofing sewers. (The Uplands’ combined sewer/storm
drains is a special case that does need to be fixed.)
Option 10 shouldn’t be the CRD’s starting position, though. It
ought to be its fallback position. To start with, our regional, provincial
and federal representatives should be going to the federal and
provincial governments and presenting Option 9.
In exercising Option 9, our leaders try to negotiate an annual voluntary
payment to allow the community to continue to use the giant
tidal-powered treatment system off Clover Point and Macaulay Point
until such time as either the federal or provincial government provides
scientific proof that the current system is doing harm. If the feds or
the Province can’t provide that proof within four years, the community
gets its money back and stops payments.
Under the Fisheries Act, fines levelled against polluters often go to
the Environmental Damages Fund. According to Environment Canada,
the fund provides “a mechanism for directing funds received as a
result of fines, court orders, and voluntary payments to priority
projects that will benefit our natural environment.”
What might be an appropriate voluntary payment to offer the federal
government in the negotiation? CRD taxpayers are currently paying
about $10 million each year for the never-ending sewage treatment
planning process. That’s only enriching already mega-rich consultants
like Stantec. Instead, why not offer the feds the $10 million per year
we would otherwise pay to Stantec or the consultant de jour? If the
feds say “No,” then we go to Option 10.
David Broadland is the publisher of Focus Magazine.
www.focusonline.ca • February 2016
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