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methodology i ========================================================================= 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 ============================================================================ ====== 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- ============================================================================ ====== 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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