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Minority Report - March 2014

Minority Report – 19 March 2014.

To: Vernon City Council
By: Huguette Allen, representative of SENS (Sustainable Environment Network Society)
Re:The Final Report - Environmental Impact Study” (EIS) produced by Urban Systems, June 2013 / 1085.0034.01

SENS was appointed to the LWMP to represent the environmental concerns of the population. We have attended meetings and discussed the issue of liquid waste management with our membership. We have also shared our concerns with, and proposed alternative solutions to, Urban Systems and the City of Vernon, via verbal feedbacks, emails and reports that are publicly available on our website.

The concerns and alternative solutions proposed to Urban Systems throughout the LWMP process are not adequately addressed in the reports presented to Vernon Council. Therefore we are issuing this 'Minority Report' hoping it will bring clarity to the difficult decision facing Council.

Urban Systems is recommending that council allow the discharge of all or part of the treated liquid effluent to Okanagan Lake, a solution that the people of Vernon have clearly refused in the past.

We at SENS disagree with this recommendation because of the known1 health risks and environmental degradation caused by discharging effluent that admittedly inevitably will contain pharmaceuticals, pesticides and endocrine disruptors to a body of water, particularly one that retains its water for as long as Okanagan lake does (80 to 90 years).

We feel that the reason the Stage 2 and 3 Report can state that the “Overwhelming majority agree (somewhat or strongly) that lake discharge is acceptable so long as reclaimed water (treated effluent) meets Provincial standards” is due to the fact that the impacts of EDCs and pharmaceuticals were not fully addressed during meetings. When these were brought up, people were given the impression that the minute quantities involved were so innocuous as to not warrant any further discussion.

Science tells a very different story. About 50% of all pharmaceuticals ingested by people are eliminated via urine and feces. Therefore are impossible to eliminate at source. Educating the public about not dumping them down the toilet, as recommended in the EIS, will do very little to stop the problem. In fact, it is practically impossible to even fully test for what pharmaceuticals may be present at treatment time because the varieties of toxic compounds found in treated wastewater interact to produce wholly new toxic compounds.

Science also tells us that Endocrine Disrupting Substances found in everyday personal and home- care products, as well as in insecticides, fumigants, fungicides, plastics, etc. are never all removed by sewage treatment systems and scientists are clear that these compounds, particularly in extremely minute quantities, pose significant health risks to the population.

The EIS report produced by Urban Systems does not deal with the problem adequately. It leads us to believe that 2dilution is the solution to pollution, an hypothesis that is now proven to be entirely wrong. On the contrary, science now shows that Hormone-disrupting chemicals challenge a fundamental tenet of toxicology which contends that the greater the dose, the greater the effect. Hormone-disrupting chemicals cause significant health impacts at low rather than high doses and scientists tell us that extremely small3 amounts of endocrine disruptor compounds have remarkably strong effects that can affect second and even third generations.

We have often and clearly expressed our concerns to Urban Systems as well as to the LWMP committee and have written Dr. Harkness subsequent to the publication of the Draft EIS asking: “In particular, was advice or input sought from experts in human and aquatic toxicology related to endocrine disrupters; if yes, which experts and how was their input incorporated into the study? If this science is not addressed, I would ask you to notify the city that the study did not examine that science, and to suggest next steps to evaluate whether the Liquid Waste Management Plan appropriately handles EDCs and/or to modify the Plan to address EDCs.”

Dr. Harkness informed us that since addressing EDCs was not part of the terms of references, the issue can be shouldered by the federal government. “Professional responsibility exercises the balance of judgement with the best available technical information for decisions to be made. This approach is being taken with the City’s LWMP, of which the environmental impact study is a part. The terms of reference for the environmental impact study were developed based on existing guidelines and standards, and were discussed with the City and Ministry of Environment prior to finalization of the scope. A copy of this terms of reference is available as part of the information published on the City’s LWMP process, and is posted on the City’s website. The issue of endocrine disrupting substances is both emerging and complex. As with any emerging issue, there are often more questions than answers. The need for direction on endocrine disrupting substances is required from higher levels, such as the Federal government rather than a local government, given the complexities, gaps in understanding and the world-wide concern.”

We disagree, and feel that since Urban Systems is aware of the grave health dangers that discharging effluent to the lake would carry, such a recommendation should not be made, and that since the City is now aware of same, the City should reject such recommendation, and demand a complete list of alternative solutions.

Okanagan Lake is widely used for recreation, and EDCs and pharmaceuticals are absorbed through the skin as well as through ingestion. Allowing the discharge of these substances to the lake is to knowingly degrade the health of the lake, to reduce aquatic organism population density and biodiversity, as well as to negatively affect public health for generations to come.

This is a complex issue that will not go away. As a matter of fact, most poisons and pathogens present in raw sewage end up either in the effluent or the sludge. There is No “Away” produced by the Canadian Institute for Environmental Law and Policy makes the point that the better the liquid waste treatment system, the worse the solids will be and vice versa.

Innovative solutions exist, solutions that require the same kind of clear innovative thinking that Vernon has demonstrated with so many of the decisions taken in the past.


Footnotes

1. Endocrine Disrupting Compounds cause neurodevelopmental disorders such as learning disabilities, autism, tumours, diabetes, cancers, genital changes in males, reduced fertility, as publicized by CBC's: "The Disappearing Male".

2. According to new research, prescription drugs are contaminating Lake Michigan two miles from Milwaukee’s sewage outfalls, suggesting that the lake is not diluting the compounds as most scientists expected.

3. Urban System's EIS (page 58) clearly states that endocrine disruptors and pharmaceuticals will not all be removed by even a high level treatment system but the EIS deals with this problem by saying that dilution is the problem to pollution: “Given the volume of effluent which is discharged to Okanagan Lake and the size of the lake, there is the potential for significant dilution and dispersion to occur, in addition to the potential for endocrine disrupting substances to also undergo further transformations (e.g. adsorption and biodegradation) after release to the lake" when in fact science tells us that exposure to low doses of EDCs are much worse than exposure to high doses and can have multi-generational effects.

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