Submission to the Greater Vancouver Regional District (GVRD) Waste Management Committee in the matter of the GVRD’s Liquid Waste Management Plan

September 13, 2006

Georgia Strait Alliance (GSA) is a charitable, non-profit society formed to protect and restore the marine environment and promote the sustainability of Georgia Strait, its adjoining waters and communities.

The goals of GSA are to:

1. Protect biodiversity and wildlife habitat;
2. Restore the region’s water and air quality;
3. Promote the social, cultural, economic and environmental sustainability of the region’s communities;
4. Foster understanding and stewardship of the marine environment; and
5. Raise awareness of the links between the health of ecosystems and human communities.

GSA is active on a range of educational and advocacy efforts aimed at safeguarding the marine environment and the health of the human and non-human inhabitants that make this remarkable inland sea their home. Our programs include intertidal stewardship and monitoring; encouragement of reduced use of toxic household products; promotion of green boating and best practices in marine industries; Marine Protected Areas; improved sewage treatment, and reduction of pollution and habitat impacts from salmon farms. We promote science, collaboration and common sense as tools in the pursuit of sustainability. We also recognize that “sustainability” must encompass not only a healthy environment, but also social factors such as human health and a healthy economy. GSA is made up of over 50 member groups and 1000s of individuals around the region. Our organizational members include environmental, recreational, labour, and community groups, sport and commercial fishing organizations, small businesses, marine industry organizations and many others that together comprise well over 100,000 people

State of the Strait

The Strait of Georgia is among the world’s biologically richest ecosystems. With the input of nutrients and fresh water from the Fraser River and myriad smaller watercourses, this 4,000-square mile system supports thousands of species of plants and animals. In fact, no other site along the west coast of North America or across Canada supports this kind of wildlife and biodiversity. To lose the biological diversity found here would be a tragedy of international proportion. The Fraser delta and Boundary Bay serve as vital stopping points on the Pacific Flyway, where each winter, millions of birds gather from three continents, sustained by the wealth of mudflats, beaches, marshes, sloughs, meadows and eelgrass. The Strait’s diverse marine habitats support a profusion of intertidal and subtidal life, including glass sponges, giant Pacific octopus, rockfish, lingcod, wolf eels, rich annual runs of herring and wild salmon, and the marine mammals that feed upon them, including the southern resident orca. Since almost 70% of British Columbians live around the shores of the Strait, the health of this aquatic environment is central to the economic and social health of the province’s human population. Tourism, one of BC’s largest industries, draws people from all over the world to see the beautiful coastline and majestic wildlife of “Super Natural BC”. The Strait and its waterways provide the foundation as well for our shellfish, fishing, transport and marine commerce industries, and we depend upon these waters that form our “backyard” for our year-round recreation and quality of life. Yet as Parks Canada has reminded us, the southern Strait of Georgia is Canada’s most at-risk natural environment. With almost 7 million people living around the shores of the Strait and adjoining Puget Sound – and this predicted to rise by close to 20% over the next 15 years – the pressures on these waters are intense. Sewage and storm water, toxic discharges and emissions, hydrocarbon pollution, coastal sprawl and development are all taking their toll. Already, 63 marine species in our region are listed as “at risk” by Canadian, US, BC or Washington State agencies (1). In 1998,John Cruickshank, then editor-in-chief of the Vancouver Sun, wrote: “We have less than a lifetime to save the Strait of Georgia. If we can summon the political will and imagination, we can preserve and enhance the global treasure in our backyard.” Eight years later, the urgency is greater than ever. Sadly, the continuing discharge of undertreated sewage is contributing to increasing pressure being placed on this body of water, an inland sea like no other.

Orcas at Risk

The Southern Resident Killer Whale (SRKW), a transboundary species, has been designated as endangered by both the US and Canadian governments, primarily because of concerns regarding its small size, its small numbers of reproductively active adults, its low reproductive rate, and its decline of 17% between 1995 and 2001.  This species joins the 62 other marine species in our region which are listed as “at risk” by Canadian, US, BC or Washington State agencies.  This growing list is an indication that we are putting increased pressure on Georgia Strait, and its adjoining waters of the Strait of Juan de Fuca and Puget Sound, and it is having a measurable negative impact on marine wildlife.  The best available science (which can be found in the SRKW’s Recovery Strategy, Draft – March 2005) indicates that this species is under growing pressure from human activity.  The greatest pressures are a reduction in the availability of prey due to collapsing salmon stocks; high levels of persistent organic pollutants that may be compromising their reproductive and immune systems; a high volume of boat traffic from commercial and recreational sources; and other human-caused stress arising from the geographic location of their range.  We highlight this species because it is our ‘canary in the coalmine’.  The southern orcas are one of the most toxically contaminated marine creatures on the planet.  Being at the top of the food chain, they are the recipients of all the chemicals ingested and absorbed by smaller creatures.  The bioaccumulation of chemicals up the food chain means that the killer whales’ food is contaminated and these contaminants are putting this species at risk.  With municipal wastewater being the largest source of pollution, by volume, discharged to surface water bodies in Canada (2), the inadequate treatment of sewage by the GVRD is contributing to the contamination of Georgia Strait and the species like the orca that call it home.

Monitoring using a trigger system

The staff report in response to comments received by the public during the Bienniel Report review indicates that the province’s approval of the GVRD’s monitoring and trigger process is assurance of environmental protection.  As we’ve learned in Victoria, a trigger approved by the government provides no assurance at all of environmental protection.  On July 12, 2006, a Capital Regional District (CRD) commissioned independent panel (SETAC) indicated “only the CRD and the Greater Vancouver Regional District (GVRD) were identified as relying on an environmental trigger process as the basis for wastewater treatment decisions.”  The panel then went on to highlight that the trigger developed and approved by the province would not protect the environment.  Specifically, “the difficulties associated with designing and implementing a trigger process create considerable uncertainty about the program’s potential effectiveness to protect the ecosystems” in Victoria.  Though Vancouver is not dumping raw sewage from its treatment plants (though does from its CSOs), discharging undertreated sewage into the marine environment, and monitoring the waters with a system that most communities do not use due to its ineffectiveness, should worry this committee. Overall, monitoring of a natural environment without looking at habitat level and long-terms impacts leads to an inaccurate interpretation of effect.  In fact, the impacts could be missed all together.  Again, as we’ve recently learned in Victoria, where the seabed around the 2 outfalls have now had a preliminary designation of “contaminated” after years of the regional government telling the community that everything was fine, monitoring can be in place and be reported on but using a trigger system, the real world impacts can be overlooked.  In the end, “we do not find what we are not looking for”, and until the GVRD’s monitoring is based on ecosystem wide impacts, and includes long-term effects of known substances entering the marine environment, we will remain unaware of the harm we are causing every day by discharging undertreated sewage into our ocean, until it’s too late. The panel should be concerned that it uses a monitoring system of the type harshly criticized in Victoria, and which resulted in a contaminated site, and should acknowledge that these systems are inadequate and should be modified.

Source Control

Municipal wastewater is the largest source of pollution, by volume, discharged to surface water bodies in Canada (3). There are two fundamentally important points in this statement: one is that sewage discharged into the environment is pollution; the other is that the size of the potential negative impact on the environment is quite large.  Both Greater Victoria and Greater Vancouver remain the two largest sources of raw or minimally treated sewage on the BC coast (4). Therefore, it is critical that efforts be made to ensure that the effluent discharged will not harm the receiving environment.  One part of addressing this source of pollution, it to minimize the broad range of chemicals we use daily that end up in our sewage.  Since 1998, GSA has used itsToxicSmart program to demonstrate how easy it is for our communities to reduce the use of chemicals in their homes, gardens and workshops.  This very popular and effective region wide program has now been expanded to include workshops in the Lower Mainland’s South Asian community (with one of our guides now available in Punjabi).  GSA is also partnering with the GVRD on its “Use less. Save more” campaign to encourage residents on the North Shore to reduce their use of laundry soap.  These types of education campaigns must continue as they have proven to be effective in reducing the amount of toxins that make their way into our environment. Our historical involvement in source control education underscores our understanding and support for their effectiveness.  However, there are two aspects of source control that must be made clear:

• Source control must include enforceable codes of practice for business and industry
  • Source control education for GVRD residents is important and effective and we encourage the region to continue expanding this program. However, harmful chemicals are also making their way into our marine environment from industry and business.  Businesses such as restaurants, parking lots, dry cleaners and carpet cleaners, to name a few, use harmful chemicals every day, and their disposal must not be left to voluntary programs.
    • We therefore ask the GVRD to develop a wide range of codes of practice for key industries and businesses in our region.  Enforceable codes of practices are feasible, and if proper monitoring and enforcement is in place, it can be very effective.  Codes of practices are currently in place in communities such as Seattle and Victoria.

• Source control is not sewage treatment
  • Source control education is by its nature voluntary, and therefore can never be a complete substitute for the highest possible level of sewage treatment.  We can encourage individuals to recycle paint and to use less chemicals in their homes, but in the end, the final decision to comply or not is up to the consumer.  Therefore all harmful chemicals will never be eliminated from the effluent stream, as it is impossible to get 100% of the population to comply.
  • Source control’s impact on reducing the chemicals in sewage is limited by the fact that a growing number of the chemicals that make their way into the effluent are not controllable.  These include PCBs, as well as pharmaceuticals.
    • Pharmaceuticals: Source control can be effective in preventing unused pharmaceuticals from entering wastewater, however source control cannot remove excreted pharmaceuticals from wastewater.  The ability of sewage treatment systems to remove pharmaceuticals is low, but not insignificant. Studies to date have looked at pharmaceutical impacts from discharge after a sewage treatment system(5). Further research is needed, but sewage treatment is the most effective tool we have to remove pharmaceuticals from the waste stream.
  • In a 2000 communication with the Capital Regional District of Victoria, Environment Canada stated that “Treatment’s not only more effective in reducing contaminants, it is effective immediately upon implementation and will remove a wide array of contaminants not targeted under source control”(6).

Therefore, source control must be part of a broader approach to dealing with our sewage, as we ask the GVRD not to limit its approach but broaden it to include a minimum of secondary sewage treatment for all its plants.

We therefore ask that the GVRD Waste Management Committee:

1. Consider the long-term impacts that continued pollution is having on our local waters, including Burrard Inlet, Fraser River and Georgia Strait.  Pollution of ‘the most at-risk natural environment in Canada” calls for an immediate upgrade of the Lions Gate and Iona treatment plants to secondary.
2. Include habitat impacts resulting from treatment plant discharges in any monitoring reports, as the current trigger system is acknowledged as flawed and does not effectively protect the environment.
3. Continue to promote source control in our communities, however, no longer use this as a temporary stop gap to the most effective method of reducing contamination of our waters from sewage – secondary treatment or better.

Sincerely,

Christianne Wilhelmson Program Coordinator, Vancouver