The following submission was sent to the Canadian and BC Health and Environment Ministers.
An email included a 25-page submission that is a synthesis of 77 [up to date] scientific references showing how, if built, the Regional District of Nanaimo ‘Board approved’ conventional sewage treatment plant with disposal of minimally treated effluent into the Strait of Gerogia at Bowser British Columbia on the Eastern side of Vancouver Island, will with cumulative effect, add to the documented decline of the Salish Sea marine ecosystem; presents an unacceptable risk to Canada’s premier Aquaculture Industry in the Baynes Sound area; and is a high risk activity for environment and human health from pathogenic organisms and a slew of emerging pollutants remaining in municipal effluent.
The Submission is now available for download at:
On October 4, 2018 in a PQB News election advertisement, Regional District of Nanaimo Area H Director (and Board Chair) Bill Veenhof, made certain claims regarding treated effluent disposal into the Salish Sea, from a proposed Bowser Sewage Plant, that minimize ecosystem health risks associated with ever expanding RDN wastewater hubs.
Now a 25 page report authored by experts provides proof that there continues to be significant cumulative health and ecosystem risks associated with low level treated sewage disposal into Salish Sea recreational and shellfish waters near Bowser BC (Carlow et al. 2018 at www.SOSBowser.ca). The attached rebuttal draws on science-based facts and online research to show why most of the claims made by Mr. Veenhof are simply not true.
It is almost time for Area H to have their say on who and what will shape our way of living for the next 4 years. This past year has been agonizing, attending meetings, speaking out but not being heard. Our quality of life is at stake. There is an agenda, that much is clear but whose interests are being represented? Apparently not ours! Development will come to Area H and it's worth it to wait and get it right. Do your research, know the facts and on October 20th get out and VOTE FOR CHANGE!
The Victoria Scenario
Polluting the Salish Sea is Wrong!
Matthew McDonald was in conversation with Malcolm MacColl last Jul 25, 2018, in a chat about pollutants in the Strait of Juan de Fuca from the City of Victoria, almost 400,000 people using the ocean as a sewer:
McDonald says the pollutants are being dumped into the ocean, in, "Untold amounts. Try 80 billion metric meters squared of raw sewage a year. Fish in Juan de Fuca Strait are testing positive for about 80 harmful chemicals. parabens, anti-psychotics and anti-depressants, opium, heroin, cocaine, cleaning agents, and many more. "
He continues, "It should bother people that even hospitals don't sanitize their outflow.
" Imagine catching HIV, herpes, or flesh-eating disease from eating crab, oysters, or salmon. That day will not be long away."
IMPORTANT ACTION UPDATE
Sep 30, 2018
It's not the tourist sight you might expect to see when driving up the scenic oceanside route of Vancouver Island. STOP OCEAN SEWAGE appears on roadside signs from Qualicum Bay all the way to Union Bay. There are a lot of these signs, and a lot of concerned people behind them.
Nor is the sight at Qualicum Beach what you would expect when summer temperatures exceed 30 degrees celsius, and beaches are empty of people swimming. The water looks perfect, the sand is inviting, but disease is prevalent and locals know this all too well. You swim at risk of becoming extremely ill.
What happened, and why are signs telling the story? "Our goal is stated on the website: Stop sewage from being dumped into our ocean (www.sosbowser.ca) Polluting the Salish Sea is just Wrong!"
Thomas Gates is Campaign Director at the head of a group of concerned citizens from Nanaimo all the way to the Bowser B.C. area, including some of the most beautiful beachside optics anywhere in the province.
Their campaign is about the following three things:
1. We are OPPOSED TO SEWAGE EFFLUENT GOING INTO THE OCEAN, such as that proposed by the Bowser Village Centre Wastewater Project which will begin to dispose of minimally treated sewage effluent through a marine outfall at the Noonday Rd. 'Public' beach access.
2. We are IN FAVOUR of sustainable development in Area H.
3. We are IN FAVOUR of an up-to-date sewage system that uses modern technology and disposes of clean effluent on dry land.
Gates says, "We have a group of medical doctors and scientists and qualified professionals working on an evidenced-based approach to improving effluent management with the new proposed Bowser plant as the focus.
"We of the SOSBOWSER AND AHRPRA groups are considering a third party independent review to provide to B.C. Ministry of the Environment with our concerns in permitting sewage discharge. We are very concerned a full options analysis by Stantec was bypassed as they ignored land-based disposal as per Chatwin 2011's recommended areas."
That being said, as Gates explains, there are technologies such as membrane bioreactor (MBR) -- a combination of a membrane process microfiltration or ultrafiltration with a biological wastewater treatment process, "followed by efficient disinfection , microfiltration and granulated activated carbon (GAC) that remove/kill toxins, pharmaceuticals, pathogens, and some portion of nutrients."
The Bowser group does its homework. "Europe is moving to highly efficient multi-stage designs, since the trick is the multiple layers of treatment to allow purer effluents with low Environmental and Health impacts and high recycleability."
Their argument is for a well-sited (by hydrogeologist) land-based disposal system with a combination of layered pre-treatment to completely avoid ocean pollution, "and if done right this system can recharge aquifers or even help with low summer base flows in streams," or add water to threatened drying wetlands.
"Unfortunately these environmental studies take time and the Regional District of Nanaimo (RDN) is running against the clock to get this built in consideration of a Clean Water and Wastewater Funds (CWWF) grant allocation," for Shared Costs provincial and federal.
The Sechelt plant (on the opposite side of the Salish Sea) added a green house with aquatic hydroponic plant uptake of toxins and nutrients with Microfiltration to remove pathogens (to polish the conventional plant effluent). In Sechelt, a community of similar proportions beside the ocean, they call it a water resource centre. Effluent is suitable for multiple reuses and can be safely marine discharged since it has been highly treated for low long term cumulative impact.
Gates says, "I hope for the end of days of managing our effluents by diluting them in natural waterbodies (the ocean) and an end to wishful hoping for satisfactory pathogen time based die-off based on computer dispersion models."
It's not a functional system when the method of protecting the public is with beach closures and sanitary shellfish area closures, which is happening constantly if not frequently on the Inside Passage in countless communities and areas.
"For this ending to take place a well-consulted and informed public is necessary for governments to be pressured into cleaning up their act. Our democratic process was talked about recently in Nanaimo by Director McClean and it needs to be respected if we are to avoid dictatorial governance."
The Bowser group is very concerned about the degrading Salish Sea Ecosystem, especially in the face of recent high levels of development. These proposals are going ahead without a wider waste management plan and regional cumulative environmental assessment. Development is coming with a serious threat to the marine ecosystem with ever-expanding marine disposal of sewage effluent meeting minimum and somewhat outdated government standards.
The reason people are becoming ill with cases of Norovirus and serious stomach ailments from swimming or drinking local water, "There is no standard for example for wastewater virus levels nor for pathogenic protozoans. Typically wastewater must meet BOD5, TSS and Fecal coliform standards." The group has said, "Fecal coliform (enterococci) are not correlated with virus levels so are not a good proxy for the more expensive virus testing that should be done to protect multiple marine uses (shellfish, contact recreation, First Nation country type foods, winter surfing and summer swimming, pink salmon beach fly fishing," an ever expanding list of no-go activities.
Nor is the principle of one person one vote being respected in regards to these fundamental issues. "Last year the RDN did a petition to get a sewer system bylaw passed but allowed only 100 or so landholders in a small area at Bowser to participate in the vote," says Gates. "There was no consultation with the wider impact on community and we heard about the proposed effluent pipeline and outfall planned to go through our community outside of Bowser only via the grapevine with less than two weeks notice."
Sure sounds like a case of NIMBY (Not in My Back Yard) being circumvented by local area politicians, who seem to be saying, "Let’s put it down the road away from our tourist beaches." Somebody should tell those politicians those beaches are unswimmable even if nobody is willing to admit this. Instead they are proposing to put a sewage outfall near one of the biggest scallop farms in Canada, and the Bayne Sound oyster growing area is a huge economic input to local economy.
Gates says, "We approached the MAH Minister saying this was not fair, contravened the LG Act etc., but hit a wall. We even went to the Canadian Infrastructure Minister but didn’t get action on what amounted to a manipulated boundary and vote for the petition to get the grant. We received no help at all with no oversight committee action."
Frustration mounts, "We contacted the Environmental Minister multiple times but our Associations will not be part of formal consultation, even while Aboriginal groups must now be included."
He continues, "We contacted the MOTI (infrastructure) Minister about contraventions of the MOTI Utility policy and were told staff would be looking at that when they get an application for a permit. It is important to note, among other things, the planned sewage effluent pipeline crosses sensitive endangered coho salmon streams."
What the Bowser group has discovered is basically responsibility for this sewage boondoggle has been fully devolved to the RDN. "Our Area H (within the RDN) Director Bill Veenhof (also chair of the board) votes against his own broader community's wishes for a land-based disposal system with water recycle to avoid marine pollution."
The proponents for sewage dumping say there is no suitable land for disposal, "even though the Chatwin 2011 engineering report found many areas of suitable land. These areas were completely ignored by Stantec in their 2017 'study' into the latest feasibility.
"We don’t believe the other directors on the board are fully informed about the issues, nevertheless they also vote against us and refuse a pause to review alternate green technologies."
The 'approved' process is funded by a provincial/federal Canadian ‘Clean water’ and Wastewater fund grant of $7.6 million, "and we believe in the rush to get the grant and to spend the money, choices for the system design have been to maximize the system size at the expense of environmental protection, and maximize development and economic gain."
The problem with this short-sighted approach by a relatively distant political body in Nanaimo (60 kilometres away down a twisty provincial highway, "That is not the sustainable development growth strategy policy that is espoused by RDN. The RDN has already had two one-year extensions on this project to meet the construction/funding deadline and is now projecting to go over the latest one year extension." The quality of the project management is coming into question here.
And here is the crux of the issue: The proposed SBR treatment system involves an open pit (circa 1915) conventional technology. "Ultra Violet (UV) disinfection is rather poor choice since it will not be able to sterilize the effluent. There are better choices for disinfection perhaps such as Peracetic acid (PAA) used in Vancouver," furthermore, "there is no filtration of microplastics from laundry (as is done in Sechelt). Domestic toxics, pharma products and nutrients remain in the effluent. Sechelt has activated carbon filtration.
Even worse, the system is designed to expand, allowing more ocean sewage. Gates says, "A 2018 Simon Fraser University toxicology group paper shows high levels of micro-plastics pollution in Baynes Sound and around the tip of Denman Island across from the Comox plant."
Is Canada’s premier oyster ground at risk? Will the large Kensignton development starting at Union Bay add to cumulative environmental health effects? Deep Bay (beside Bowser) will be looking at new facilities in the near future, and what are those plans?
Gates says, "In recent history we have seen close to 500 cases (North American) of Norovirus infections from Baynes Sound oysters and a limited outbreak of cholera on herring eggs eaten by First Nations people.
"The recent CBC article with the shellfish growers association points to human sewage as the source of the Norovirus. They are very concerned that their industry is threatened."
It is important to understand how the Salish Sea acts more like a lake with very long flushing times (thought to be over a year). This means pollutants accumulate. "We don’t know what the assimilative capacities for all these pollutants are so a precautionary approach would say stop, do best available technology, or avoid pollution altogether with on-land disposal and water recycling."
More details and letters to the Bowser group's membership and to Government Ministers are available with responses, and a fact sheet on the website is downloadable for readers; use.
This group's message is resonating all the way to Nanaimo, and they welcome the public to join in the 21st century where environmental protection needs to matter!
MORE ESSENTIAL READING
Why conventional activated sludge treatment (CAS treatment) without multilayers is not effective in removing viruses etc see this VG article (long but very educational). Note the SBR (sequential batch reactor) proposed for Bowser is a 4 h cycle open pit design CAS system with UV disinfection. Maybe 2 log removal. Not good enough!
Vibrios and global sea warming http://www.pnas.org/content/early/2016/08/02/1609157113
Useful European info: http://watersecurity.info/wp-content/uploads/2017/08/presentation-MBR_roegener-publication.pdf
Calgary wastewater study http://www.esaa.org/wp-content/uploads/2018/04/ET18Judy-Qiu.pdf
Parasitic protozoans survive https://www.sciencedaily.com/releases/2011/02/110223071304.htm
Municipal wastewater discharges and pollution of the marine environment http://www.oag-bvg.gc.ca/internet/English/pet_112_e_28834.html
An add on for 3 log reduction with PAA but 3000 PPM needed for spores. Much better than UV as per poor performance of UV in Calgary study…
https://www.ncbi.nlm.nih.gov/pubmed/24642428 3 log reduction with PAA but 3000 PPM needed for spores.
Sent by email to Mr Gates:
"This is going to get more frequent with global warming. More cases are being reported. This is the third I have seen in the last week. Most oysters have Vibrio in them. While it is not particularly a wastewater problem, when humans get infected Vibrio (and there are many types) is excreted in faeces and adds to the contamination. One of the unknowns with UV light exposure is the degree to which the organisms can recover from DNA damage and how they can evolve DNA repair mechanisms. With so many unknowns and even with minor environmental changes no one can accurately predict what might happen. Caution should be the order of the day. "