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It seems reasonable to maintain that treatment should not be provided, beyond the existing fine screening, unless it can be shown that its absence would lead to significant damage to man or the environment or that theory indicates such damage may be occurring, whether detected or not. Additionally, if one does have a pollution problem, its significance must be compared with that from other discharges to determine where one should spend the tax-payer's money to achieve the greatest environmental benefit. In our case, the evidence has revealed no such damage and theory does not suggest that there should be any.

Such a position accords with the Waste Management Act. It also accords with guidelines set following the public enquiry that has been referred to previously.

There are many environmental problems where the application of such a criterion has entailed providing treatment. As mentioned, engineers have recommended and built over 100 plants providing secondary quality effluent in B.C. and some providing tertiary treated effluent. The reduction in the discharge of toxicants and of carbon dioxide from the the use of oil based fuels is a glaring example of such a case for the future.

It is not possible to do a cost benefit study to compare the adverse effects of the long outfall discharges with others because we know of no adverse effect. Indeed, there is a disbenefit in providing land treatment. For this reason, there is little mention of cost in this book. Land treatment should not be provided even if it were free.

This chapter compares such a criterion with the position of so-called environmentalists and whether the problems that motivate them exist.

Some argue that the public deserve to have their wishes respected in a democracy and most want treatment; at least the politicians obviously believe they do. A more constructive view is that the public deserve to be given the facts and that to seek their views without having done that is a perversion of democracy.

The CRD has not given the facts to the public and there is no evidence what the public would choose to do if they were. Extensive information was available in their offices to explain the basis for the long outfall design. The results of many years monitoring was available, specifically carried out to confirm for the public that the design was adequate, all of which indeed bore that out.

Some refer to other places that have problems, such as reportedly in parts of Puget Sound, and deduce that therefore we must have them. That is odd! It is the application of the same scientific principles, backed by monitoring, that show treatment is needed for those cases that show we do not need it for ours. On the other hand, where conditions are comparable to our own, the results of monitoring bear out the conclusions reached for Victoria, namely that treatment is not needed. However, few places have conditions as ideal as ours.

Some have suggested that in order to control pollution it may be necessary to set a standard which every discharger has to meet. This philosophy is the one applied, for example, to car exhaust emissions in some jurisdictions. It is no use protesting that one only drives one thousand kilometres per annum and never comes into town. In such cases there are millions of discharges each under the control of an individual and it is not possible to control them without imposing a general standard.

The letter from the Minister of the Environment referred to earlier stated that a policy of 'best available technology had been adopted'. This is a similar idea to the one that every discharger must meet the same standard. Seemingly there was no public debate about that decision. It makes redundant the 'objectives' which were derived using the best expertise available and with substantial input from the public as well as all interested agencies. It reads as a last ditch attempt to find justification for political commitments.

The debate about imposing such general requirements for sewage discharges is not new. Steel and McGhee refer in their book Water Supply and Sewerage to a notion some 100 years ago that all treatment plants should produce effluent comparable with drinking water (impossible then and nearly so now). It was decided then that it was not sensible and since then treatment has been based on local conditions.

In the case of sewage disposal, experience has shown that it is perfectly practical to control pollution without such general criteria and thus the basic argument for applying them breaks down. In practice such an idea imposes huge costs on the public to achieve nothing of benefit to the environment or to man. It is hard to understand such a viewpoint. In our case it would even mean some environmental harm.

Some deduce from various pieces of physical evidence that there is a pollution problem, most particularly from the 'pollution' signs around our shores. Not one would be removed as a consequence of treating the sewage that now discharges down our long outfalls because they are not causing the pollution in the first place, as made clear in other chapters. Some refer to smells but none of these arise from the long outfalls 200 feet deep and about a mile from shore, although some might arise on occasion from a land-based sewage treatment plant.

Some refer to tampon holders on the shore line but none come from the long outfalls since the installation of fine screens.

Some refer to the possibility of toxic waste in our sewage. Where such wastes are significant they normally arise from industry. These are minimal in Victoria and steps to better control the few that exist have already been taken and will continue to be taken.

It is doubtful if household waste generates anything like the toxic waste that discharges down the storm sewers when it rains. These do not discharge one mile offshore and at two hundred feet depth but at the shoreline. Even so, problems from our storm sewers must be kept in focus. They remain a small problem in comparison with storm water discharges to streams and rivers and these in turn are tiny compared with the real problems mankind faces to overcome pollution. We kill or injure more people every day with motor cars than have ever been made ill from our storm sewers and the existence of the 'pollution 'signs prevents even that. As for the impact on the sea, that is only degraded for a small area and for a short time around the storm sewer outfalls,with minimal impact on sea-life.

Apart from these theoretical factors, monitoring has not shown that we have a problem of any significance and it is probable that it would do so if it existed. Furthermore, monitoring will detect any adverse change in the future if programs to monitor are carried out from time to time. The evidence should be re-examined every five to ten years.

Some appear to regard the discharge of sewage that has only been screened as a 'moral' question; as though it were a matter of right or wrong, good or bad, pure or impure. Let us examine that view.

1. It should be noted that fine screening, as applied at our long outfalls, is the technique used at some secondary plants to remove readily settled matter, so it is a confusion in semantics to think of screening on the one hand versus treatment on the other. Screening is a degree of treatment and reduces every adverse parameter to some extent. It is not a question of treatment versus no treatment but of appropriate treatment versus inappropriate. To give an example, the discharge of secondary treated effluent to lake Okanagan would cause serious pollution.

2. The vertical column of sea water through which the sewage from our long outfalls rises is no different in principle to the horizontal tank of water that provides secondary treatment at a plant. It is bounded by the physical conditions that apply as effectively as the tanks of the land-based plant are bounded by concrete walls.

3. It ignores the way nature operates. Receiving waters, including the sea, are designed to convert wastes. It is one of their primary roles as explained in the chapter How Nature Works. How do the advocates of the immorality of discharging screened sewage explain how it was ever alright for the country's salmon and other fish to exist. They perform all their bodily functions, as do humans, suffer their fishy diseases and finally die and putrify on the beds of rivers. Meanwhile, numerous other creatures drink the water.

4. How is it 'moral' to grow our vegetables in the excrement from horses but deny sea life the nutrients available from the excrement from humans, hugely diluted?

5. Lastly, is it really 'moral' to spend a hundred million dollars (much more if one allows for operation) to bring about a small environmental disbenefit when one considers the social or other benefits such a sum could realize for the citizens of Greater Victoria? Some of course might prefer to use the money to help feed the 14 million children in the world who die annually from preventable diseases (Times-Colonist Sep.29 '90).

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