An Open Letter to the CRD: A Sewage Plan for the People
Over the months and years much has been debated about the CRD sewage project: its merits, the regulations, the environmental impact and the cost.
When we take stock of the project today and look to the economic benefits, there are definite shortcomings to acknowledge. Environmental benefits are minimal with great concern in the community around the land application of biosolids. Social impacts will be equally great with as yet unknown costs and ability to fully mitigate them.
These three criteria comprise the famous triple bottom line yet for those keeping score and seeing room for improvement in all areas, it is still the overall cost that is the most pressing item because to date, the front end of this project has proven very expensive having exceed all financial expectations.
Costs out of control
Back in 2009, Mr. Kalynchuk in his former role as sewage project lead told the press, "How much Stantec is paid...will likely be around one per cent of the project's total cost".
During that period, the project was estimated as costing $1.2b, or $12m for Stantec and that estimate was quote, "to take the project through the design, procurement, construction and then post-construction (phases)".
The Stantec bill to date is already over that amount by $2m and the 1% budget estimate by $6m even though construction has yet to begin. What will the final bill be for this one advisor?
At the last CRD Commission meeting on August 23rd, staff reported that the fees for procurement advisors had gone beyond expectation because the scope of the effort had been underestimated.
Just these two examples demonstrate that estimates are just that: they provide little security that costs can be contained for which local taxpayers are going to find themselves liable.
So what can be done to help contain costs? Is there an approach that can help ensure this?
Lessons from CREST
It is valuable to look back to the Capital Region Emergency Service Telecommunications radio system (CREST) to help understand the dilemma facing us with the regional sewage project.
CREST had an initial budget of $15 but the final bill exceeded $30m in order to build a system that worked. Who was at fault? The estimators.
The directors for that project were left with few options when presented with the plan that fit their budget:
1) See what the vendor could build for $18m and hope for the best
2) Authorize a larger loan from the get-go and build in contractual commitments
3) Seek out an alternative approach
What if we were to evaluate the sewage project, in its present state, using these three options?
Option 1) Cross our fingers and put our faith in the vendors.
As with CREST, we have all the same uncertainty building region-wide infrastructure for the first time, except the complexity of this project is one, perhaps two orders of magnitude greater (at least using cost as a guide). Any overruns will similarly be great.
The RFP bids have not yet come back from the vendors but no matter how the conditions of Esquimalt's 2806 bylaw get bargained down by the CRD, if at all, there is a high level of certainty that this project is going to cost far more that the estimators predicted for two important reasons:
First, because the estimators "bet the farm" that the Minister would invoke Section 37 of the Environmental Management Act and second, there was a failure to anticipate Esquimalt introducing its own bylaw. Sitting in the council chambers at Esquimalt Town Hall on June 24th, I witnessed the reaction by CRD staff at its introduction and it was one of total surprise.
So that's option #1 and like CREST, the approach taken would be one that hopes that everything works out with a plan to deal with expenses as they arise but can anyone predict the final tally?
Option 2) Borrow more money up front and build security into the contract.
The province and feds have capped their contributions so the CRD will have to make up the difference with a loan authorization but instead of another $12m as was required with CREST, will it be another $120m? A project of this size, based on a 2010 design and cost estimate is a likely candidate to incur additional costs.
For a project where the local funding contribution begins at $280m, that is an unacceptable increase for local taxpayers. Even an additional $60m would amount to a 20% increase right from the start. A political backlash would surely follow.
Option 3) Seek out an alternative.
This is the hardest decision to make of the three because it involves unknowns and second guesses everything that has come before but sometimes it is the best decision to make when all options are weighed.
The idea is not to "start from scratch" or "go back to the drawing board" but to use the benefit of hindsight to develop an alternative approach. This is possible because at the stage we are at, the project is still just an idea and there is no monopoly on great ideas.
However, this wasn't pursued with CREST. That project went over budget by almost 100% but from it we have now gained the benefit of hindsight and we should apply it judiciously.
It's never too late
Recent events offer some assurances that we would not be alone in our thinking.
Washington and Oregon only just recently re-evaluated the Columbia River Crossing Project (CRC). Capital costs were estimated in the billions and $170m was spent in preparation.
One of the reasons attributed to its failure was that the CRC went through multiple bridge designs, multiple delays and multiple project directors over the years.
Could that sound any more familiar to us and our own project? We have yet to sign any major contracts but the sewage project has only just recently hired program director number three.
What technical difficulties contributed to the CRC decision? Designing the bridge too low. Planners initially drew up a fixed span with just 95 feet of clearance over the Columbia River — a height roundly dismissed by the U.S. Coast Guard and others as inadequate for the navigation and economic needs of river users.
Instead of a bridge too low, we have a site too small: McLoughlin Pt. at the harbour entrance, that the peer review team cautioned against and we all recognize as highly constrained and prominent.
And what about delays? We have certainly had our share of those over the past 7 years.
So, in light of these similarities, how likely it is that our sewage project will defy the odds and come in on budget while meeting all the technical challenges inherent in the design?
I think most would agree that it is highly unlikely which is why we need to take the time we have available to make sure we are doing the best that we can, before we commit to a project and costs that will be with us for the next 50-years.
The value of a second opinion
A first step to take would be to open up the process to considering alternatives from which to draw comparisons.
One such alternative is to develop the cost to deploy membrane bioreactor technology (MBR) using a decentralized approach.
I suggest that it be examined because it meets the criteria of proven technology: it is not brand new and has been operating successfully for several years at Dockside Green and elsewhere within the region providing tertiary level treatment.
It is not the only suitable technology and vendors will no doubt have other suggestions but as it is easily studied, it should be included in any comparative evaluation.
This technology is exciting because of its ability to purify water for re-use at a previously unachievable cost. Given the watering restrictions we live with and future uncertainties around the availability and cost of providing water in sufficient quantities for all our future needs, the promise of recycling water is more than simply alluring: it would be a prudent investment.
While generating biogas or small amounts of electricity for homes or even heating 500 homes are "nice to haves", the recovery of precious water is a "need to have". Easily forgotten, is the fact that it is the water that is the greatest resource in the sewage, not the solids.
Sewage effluent begins as drinking water; it quickly becomes "black water" and the current project proposes partially treating it at a sewage plant located at McLoughlin Point and then flushing this precious resource out to sea.
This is a project designed to meet today's regulatory requirement only and while it provides little for future needs isn't flushing treated effluent out to sea an outmoded concept in this modern day?
When viewed in those terms, it seems not only incredibly wasteful but perhaps negligent because we have a duty not to limit the options for future generations which this project as presently designed will do because of the site chosen, selected technology and construction of a third marine outfall.
A step in the right direction
So, how could we go about evaluating an alternative? One approach would be through a pilot project:
- Pick a suitable site, perhaps ideally an existing pumping station
- Equip it, test it, operate it
- Measure the result
The knowledge garnered from Dockside Green would allow the project to get up to speed quickly.
At that point, we would know the following:
1) Capital and initial operating costs
2) If there are overruns, how much and why they occurred, and
3) Whether or not the overrun costs would repeat on per installation basis.
For the effort and expense, a lot learned would be gained with a desirable result: a functional tertiary treatment facility, no less than what exists at Dockside Green or elsewhere and the know-how to build more and an understanding of the regional cost for deployment.
This would be promoted as a pilot project and my reading of the public is that this would go a long way towards satisfying their needs and demonstrating that due diligence has been followed.
At this scale and cost, overruns could easily be absorbed. Because the construction cost is low (look to Dockside's $4m outlay as one example), the ability to pay for overrun costs is within means and so the risk is manageable.
Where buildings will be required elsewhere, recent examples like the new Craigflower Pump Station would serve to improve the accuracy of forecasting the regional costs.
Without a doubt, there will be challenges involved: nothing comes for free or in an instant but at that point we would have an option in front of us to choose from, perhaps several alternatives with an operational facility to show for the expense.
Inflow and Infiltration (I&I)
What about inflow and infiltration of the existing sewage pipes? How will this affect the cost?
$421m of largely unfunded infrastructure repairs loom on the horizon and while treating rainwater entering the sewage system is undesirable it is a reality and must be factored into the design of any sewage system.
In the same way that Dockside Green's treatment plant was designed to be easily expanded to treat more sewage at a very low cost, an optimal design would also allow for the scaling back of treatment capacity at individual treatment plant locations as I&I repairs were effected.
Over time, treatment costs would decrease as equipment due for replacement would simply be eliminated or this excess capacity would be reutilized to accommodate population growth. This common sense approach is just one approach towards reducing the long term costs.
Getting water to the suburbs
What would we do with the tertiary treated water that would now be suitable for re-use without the distribution network to deliver it to homes for irrigation and other uses?
Initially, water that is treated to this level can be safely discharged to places other than the ocean. This is occurring at Dockside Green, at the Sooke Harbour House and elsewhere. Look to Vernon for another example and discharging into the ocean would be more than acceptable at the start with the process producing effluent 10x cleaner than the regulatory limit. Of course, new developments would be natural candidates for early connection.
While it would be expensive to run piping to existing homes on its own, the inevitable I&I and road repairs provide an opportunity to deploy a network through minimal expenditure. This is the silver lining to these expensive I&I repairs but only a treatment system designed with this in mind, can these benefits be practically realised.
Water storage and redistribution would need to become part of regional planning and in the same way that natural gas was run to the suburbs, so would a plan need to be created for treated water but do attempt to do this without a rigorous analysis would have little value. Opinions must not be used in place of a quantitative peer reviewed analysis as the basis for making decisions.
A proper study must take place otherwise we would just be guessing.
The window of opportunity
Today, there is no clear alternative to choose from but there is ample time to develop one using the above example or any suitable approach.
In the event that the pilot project doesn't meet expectations, for whatever reason, the original project would proceed and could still be completed within the timeframe set by the federal government.
In addition to the public confidence that this endeavour would instil, we have the following assurances to guarantee that the risks of taking this approach remain acceptable:
- Both Minster Polak and Minister Oakes have stated flexibility on many fronts.
- There is an almost 3 year window of opportunity from the planned March 2018 project completion date until the Dec, 31 2020 federal deadline to improve the situation.
- Deferred annual operating cost estimates negate or compensate for perceived inflationary construction costs.
Why go to this effort? To ensure that we get the best value for our money and the best environmental and social outcome: to fulfill the criteria and promise of the triple bottom line. To fail to achieve this would amount to a loss for the region as a whole.
Guiding criteria
I have coined the term, "the RITE Plan" as a guide for meeting all expectations. A sewage plan that meets this criteria will garner public acceptance, justify the expense and I believe meet the needs of future regulations that will require tertiary treatment.
R - Respectful of communities
I - Innovative technologies
T - Taxpayer friendly
E - Environmentally sound
The sewage plan at present, only rates zero out of four in the same way that the plan only meets one of the six objectives as set by former Environment Minister Barry Penner in 2007 and reiterated in 2009:
http://wastewatermadeclear.ca/media/reference-library/letters_/dec14letter/dec14letter.pdf
http://wastewatermadeclear.ca/media/reference-library/letters_/letterfromministerfe/letter-from-minister-feb-09.pdf
We must return to those goals if we are to be satisfied with the outcome.
A modern day relic
Environmental groups warned in 2012 of the sewage plan becoming outdated and unfortunately it appears that we have reached this stage already.
As it stands now, if we build a 2014 project, based on a 2010 plan using 2007 technology what pride will we take in the result? Will we be the last city to build a treatment plant using the technology of the last century of which we will become dependent for the next 50 years?
What will we have to show for the expense and the effort if we are only meeting the bare minimum that the regulations require? With the inevitable overruns, will anyone be able to say the cost was worth it given the limited environmental gains from secondary treatment and anaerobic digestion?
How will the environmental groups react? At first, there will be celebration but I predict that it will be short lived as secondary treatment will not adequately deal with the chemicals left soluble in the effluent.
To stay relevant they may return within a few years pushing for tertiary treatment long before the regulations require it and any failure to observe the expected environmental improvement will indicate that the system as built isn't effective. Will they re-initiate lobbying of the federal and provincial governments to achieve a higher standard of effluent quality?
Even with that level of treatment in place some day at a future expense, the benefit of that higher level process, re-usable water will still be flushed away.
Summary
The front end of this project has already incurred unexpected expenses and while the experience will benefit the next city that builds a plant, it will offer little comfort for local taxpayers.
Is it for all these reasons cited and more that we need to evaluate readily available alternatives before the opportunity vanishes and before we are saddled with the ever increasing costs of the current plan that offers the bare minimum, meeting only that which is required by the regulations: removal of solids and not the chemicals that are the real concern.
The removal of solids is yesterday's problem and if we are not to rely on the ocean for dispersal we must build a system that does a better job of capturing them and this requires tertiary level treatment from the beginning, not 25 years from now.
Greater Victoria is not burdened with treatment plant infrastructure that other cities are dependent on and still paying for. In contrast, we have an almost blank slate from which to build a system but as the last 7 years has shown, the technologies of the past cannot accomplish this. There are few sites with the footprint that can accommodate the selected technology.
What we are proposing to build has been called "the end of an era": the old way of doing sewage treatment. We require a paradigm shift in thinking if we are to avoid becoming stuck with the same limitations imposed on other cities by their existing infrastructure.
It is my wish that in the deliberations to follow, in weighing the outcomes, in discussions that you may have and in exploring the possibilities (including some of the ideas and reasoning that I have shared in this letter), that you can be influential in helping to develop a sewage plan that is beneficial, has the support of residents and provides for the future.
We have much to gain and little to lose from trying. Let us start this process today while we can. The opportunity and the time to act is now.
Sincerely,
Richard Atwell
Campaign Organizer
http://stopabadplan.ca/
