EA Comment Deadline approaches for Halifax Harbour Clean-Up

Date: Thu, 9 Jan 2003 22:42:34 -0400 (AST)
From: "David M. Wimberly" <ag487@chebucto.ns.ca>
To: Global Change Game <gcg@solutions.mb.ca>
Precedence: bulk
Return-Path: <sust-mar-mml-owner@chebucto.ns.ca>

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A Media Release went out late this afternoon.  We hope to get coverage
starting tomorrow.  It would help for each of you to call radio, TV and
newspapers and ask them when they will be covering this - to encourage
them to cover it.  You could even voice your opinions if you get a
receptive ear.   

The second part of this is a listing of Coalition concerns.  Please use
this as the basis for your submissions, put into your own words as much as
possible.  The more times these points of concern are mentioned in
submissions the more likely it is we will get some response.  Sometimes it
is a tally process rather than a process of governments being convinced by
brilliant reasoning.  So please mention every point you can. And please do
everything you can to distribute this media release and the attached
points of concern to as many people as you can.  Feel free to photocopy
them and hand them out if you can.  The more that respond and the more
that mention these points the more likely we are for this to make a
positive impression.

Please contact me if the material below needs to be in a different form
for you for it to look its best.  The media release and list of concerns
are also here as an attachment in MSWord. Hopefully that will reach you
looking the very best. It formatting will be better that as pasted in
below, but the content is exactly the same.   We know that there are
redundencies in the list of concerns.

This should be up at the web site any minuite now, so direct people to the
site.
Do everything you can to get a buzz going.

Cheers and good luck,
David Wimberly
826-7846

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Media Release:   For Immediate Release:                         9 January
2003
Halifax Dartmouth Citizens Coalition

DEADLINE LOOMS FOR PUBLIC INPUT ON ENVIRONMENTAL
ASSESSMENT OF HALIFAX HARBOUR CLEANUP

(Halifax) - The Halifax Dartmouth Citizens Coalition, a group concerned
with the serious problems with the Harbour Solutions Project, says the
environmental assessment of the project has been a hollow exercise.

The coalition says few people realize that the public's 'window' for
commenting on the Environmental Assessment closes on Monday, January 13 -
after being quietly scheduled to take place over the holiday period. The
public should not miss this final opportunity to voice their concerns.

Don Chard, the Dartmouth representative on the coalition, says "Public
participation has been woefully inadequate in such areas as treatment
technology, site selection and private sector involvement. We are losing
an irreplaceable opportunity to use innovative treatment technology proven
right here in Nova Scotia to provide vastly superior clean-up, while
avoiding the perils of multi-national involvement."

"These so-called public-private partnerships do not work. When one
partner's bottom line is profit then concern for citizens and the
environment takes second place. Promises of government monitoring only
means catching the errors after the fact. No one should forget the record
of multi-nationals in these PPP arrangements around the world, especially
in the areas of drinking water and waste water.  Almost invariably, PPP
arrangements lead to poor service and higher costs. A Director Suez
Lyonnaise and the Mayor of Grenoble went to jail for their collaboration
in turning Grenoble's drinking water over to Suez Lyonnaise," notes Ron
Stockton of Nova Scotia Union of Public Employees.

Ken Saunders, the Halifax representative on the citizen's coalition says,
"You don't have to be an expert to speak about the negative impact of the
Harbour Solutions Project as HRM council has currently designed it. A
simple written message of concern sent to Ian McKay of Public Works Canada
by January 13th is all that is needed.

"The coalition has prepared a brief, point form list of our major concerns
to help all citizens to comment readily and effectively," says Saunders.

What the Citizens Coalition is calling, "The Ghost of Christmas Past Wish
List for Sewage Treatment Improvements" is available from their contacts
listed below and is soon to be posted on a website called "Be The Change"
(http://bethechange.ca/harboursolutions/).

The official Environmental Assessment documents are available at HRM's
website at:
http://www.region.halifax.ns.ca/harboursol/assessment.html.

Comments on the draft report should be returned to: Mr. Ian McKay, Public
Works & Government Services Canada, 496-5465, ian.mckay@pwgsc.gc.ca.


The Citizens Coalition is particularly disturbed to discover that all of
the relevant documents necessary for the Environmental Assessment were not
at many sites as required and as promised.  In particular, background
documents were not available at public libraries.

For information: Don Chard:     463-5810, dfchard@hotmail.com
				Ron Stockton: 422-6055, stockton@smelaw.ca
				Ken Saunders: 453-6392, thumpper9@hotmail.com


				-30-



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		The Ghost of Christmas Past
	Wish List for Sewage Treatment Improvements

The Halifax Dartmouth Coalition, comprised of concerned citizens of both
Halifax and Dartmouth, has been working assiduously to obtain concrete
answers on the viability of The Halifax Harbour Solutions Project. Members
of the coalition have attended meetings of HRM Council, and several public
meetings to have our concerns addressed. Unfortunately the availability of
information to make an informed decision on the project, has been based on
details obtained from HRM council after decisions were made during  In
Camera Sessions. The current situation relevant to the project proceedings
includes an Environmental Assessment to which public submissions must be
submitted by January 13, 2003. The coalition, and members of impacted
government departments attended a symposium on January 6, 2003, led by Ian
MacKay, of Public Works Canada.

The consensus of this meeting is that there remain too many unanswered
questions, and the lack of current, relevant information adversely affect
the Harbour Solutions Project in the foreseeable future, and the estimated
60 year life cycle of the proposed STP's.

The following are the primary concerns of the Halifax Dartmouth Citizens
Coalition:
(Supporting documents available on request.).

The Public Process - From the approval of the March 1998 Advisory
Committee Report by HRM Council in April 1998 to the present, there has
been no real effective public involvement in this project.

Particularly the fact that the Report Recommendation # 4.6 on Site
Selection and WINBY was totally ignored.

The Halifax Dartmouth Citizens Coalition Petition opposing the Canadian
Coast Guard Base was also totally ignored by the Harbour Solutions Project
Team.

The Health Impact of the proposed Sewage Treatment Plant on our Community
and on our Quality of Life still has not been properly addressed.  HRM has
agreed to use the Canadian Handbook of Health Impact Assessment as part of
this EA.  There is no evidence of the use of this Handbook and its
methodology in these reports.


Socio-Economic Assessment of various alternatives to the project proposed
and the sites proposed is suppose to be part of an EA according to the
CEAA. This has not been done to date.

Missed opportunity of a Sustainable Operation.  The discharge water could
be used for heating and cooling in such an industrial operation as
Imperial Oil Refinery.

Secondary Treatment and Solar Aquatics Technology have not been properly
assessed.

The evaluation of the Request For Proposals are a significant part of this
project yet it is not part of these EA Reports.  The evaluation process is
a critical part of the project and one that caused much controversy.  The
details of how each element was actually evaluated and that detail must be
assessed and added to these reports.

Source Controls proposed by HRM are outdated and inadequate excuses to
continue to allow harmful discharge of pollutants into sewers and waters.
They allow continued degradation of the environment.  The current Best
Practices Model is the No Net Degradation regulatory regime as Zero Toxic
Discharge to the receiving environments which is the only way to truly
protect receiving waters, workers, people in the vicinity of facilities
and people exposed to sludge products. In 2001 HRM Council directed staff
to prepare a report detailing how to develop and implement a Zero Toxic
Discharge Goal and Plan to upgrade the present source controls by-law.  It
is time Council moved aggressively to implement this.  This would be the
single best improvement Council could make to protect the health of humans
and of our environment.

Sludge Management Facility has been overly casually dealt with in Addendum
#1 instead of extensive scientific evaluation of the technology including
alternatives.  This must be added to the EA reports.  The facility should
be examined for permitting under the more strict compost facility
guidelines rather that get an exemption as proposed.

Sludge Management Process is not the best available.  The proposed
heating and liming of sludge is notorious for regrowth of bacteria and
virus.  The resultant material is still basically human fecal material
with bio-available heavy metals, pharmaceuticals and numerous other
toxins. Composting would be a safer process where intensive biological
digestion and stabilization of the sludge and the materials in it over six
months or more results in a far safer material that is no longer human
fecal material but is composted humus that is no longer a suitable medium
for regrown of pathogens. In composting, the beneficial soil flora
actually digest and consume pathogens, pharmaceuticals, and many other
chemicals in sludge. Compost guidelines are more restrictive and
protective as to contaminants and should be used.


Public/Private Operation does not appear to have been assessed, although
many problems with this approach have been well documented, including
outrageous cost over-runs.  Particularly, we need the issue of the Shadow
Bid assessed and documented since this also was of such concern to the
public.

Timing of Review:  It must be noted that having the review and comment
period from December 21st to January 13th, over the Christmas Break, is
very inappropriate and disappointing.  It does not give proper opportunity
to review such a large amount of material nor time to seek appropriate
technical experts to assist  in review.  This is on top of a project which
virtually did not allow any real public input after the Advisory Committee
Report of March 1998 and a project that appears to have done no real
assessment of alternatives means of doing the project.

Other salient points at this juncture include the following:
It is our contention that not enough data has been released to make
informed decisions and that:
1-The process is unfair both process of public input in process of Harbour
Solutions not allowing any significant public input.  And assessment
process being so short and over Christmas.  Both Halifax and Dartmouth
groups have registered complaints of human rights violations.
-All documents are not available to the public
-The time period given to the public to submit proposals to Ian MacKay for
Environmental Assessment was much too short given the Christmas Holidays
2-Source Monitoring has not been addressed. There needs to be a much more
comprehensive Source Control Strategy.  Source Control impacts directly on
health of workers in plants, on neighbors, on receiving environment and on
sludge management.
3-HRM has no fixed guarantee of total funding from either the Federal or
Provincial Governments
Only promises are one million per year from province and 30 mil
immediately from feds.
4-No viable alternatives have been considered, i.e. Solar Aquatic
Technology, or composting options for the sludge, etc.   Going to
secondary is highly likely to be mandated in 2 to 5 years (10 years
maximum) for salt receiving waters.  This will mean our currently proposed
systems will be obsolete and needing very expensive upgrades.  Solar
Aquatics will be the less expensive option overall and treat all the way
to tertiary and produce virtually no sludge. We shouldn't waste the
opportunity.
Sustainable operation - using waste heat from water.  Imperial Oil is
about to expand.  They could include an STP for Dartmouth inside their
expansion and use the waste heat profitably.
5-HRM has held all decision making meetings In Camera contrary to promises
to keep the public informed .  (Except for three public committee of the
whole meetings, but even then no public input was allowed at these
meetings.)  No significant public input was allowed in the review of the
proposals, all contrary to promises.

6-The location of the proposed plants will have detrimental effects on
future developments in the areas as well as on the existing communities.
Also health and safety concerns of the public living in the areas are not
properly addressed Also there will be a negative health and safety impact
on the public living in the areas.  Health Canada's Guidelines for Health
Impacts is not being used but it should be used as promised publically by
Mayor Kelly.
7-No figures are available on the % of both treated and untreated sewage
that will be pumped into the Harbour even with the 3 STP's even given
assurances of a 0 tolerance policy by Peter Kelly and Tony Blouin.
By-passes of the plant are planned.
8-We question the qualifications of personnel responsible for related
studies.
9-The systems proposed are outdated and improvements to secondary
treatment
plants will be required in 5 years to 10 years according to Environment
Canada committee reviewing national standards on sewage treatment for
municipalities.  Secondary treatment is projected to be mandatory within 2
to ten years for discharge to salt waters.
10-Information on the proponents past projects have not been made
available to the public.  Particularly the history of lawsuits against the
proponent.
11-The Sludge Management Facility seems to be casually dealt with in
reports ----Addendum # 1 and # 3 are brief, even cursory.

12 - Source control is even claimed by the proponents to be outside the
scope of the assessment although federal departments maintain it is very
much a part of this process.  We agree it is.

13. - Raw sewage will still be pumped into Halifax Harbour even with the
treatment of the sewage.
14 - Sewage will not just be residential but will also be industrial,
institutional and commercial.  This means much higher level of many
pollutants that the current proposals are just not designed to handle.
Solar Aquatics COULD handle these.

15 - Finally a chance was given last Monday by Public Works Canada to
speak with Environmental Assessment officials and responsible government
agencies about the assessment process and about the negative impact the
sewage treatment plants will have on our quality of life.  But this was
far too late in the process and too little to be of any real help. The
public process continues to stink like ripe sewage.


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