Dear Minister Heyman,
We’re contacting you today on behalf of members of the Peninsula Biosolid Coalition (PBC), a community-based organization made up of regional environmental groups (Friends of Tod Creek, Creatively United for the Planet, Biosolid Free BC…), local businesses (Butchart Gardens), and residents who have come together to oppose the land application of biosolids, as well as the ongoing landfilling of biosolids at Hartland landfill.
The PBC’s goals are to: 1) inform and educate residents about this complex environmental and public health issue; 2) ensure the CRD Board is adequately informed and empowered to make balanced decisions on the future of our region; 3) assist the CRD (and by default the region’s taxpayers) in avoiding any of the many potential legal liabilities associated the land application of biosolids. We carry this heavy torch reluctantly on behalf of our friends, families, local businesses, and the farming and food production community, and our only bias is towards evidence-based discussions about how to safely and sustainably dispose of the region’s biosolids, informed by the current state of academic knowledge regarding potential harms and benefits.
This open letter is to share concerns about the CRD and the Ministry of the Environment’s current handling of biosolids, and the associated environmental and public health risks and legal liability. In this letter, we will address the following issues: 1) the CRD’s inadequate consultation with the public in regards to the land application of biosolids; 2) the CRD’s inadequate consultation with local Indigenous communities in regards to the land application of biosolids, which violates the CRD’s own “First Nations Relations” policy and “Statement of Reconciliation”, as well the legal requirements under modern treaty obligations and UNDRIP; 3) the ever-increasing evidence of legal liability for government regulators, municipal organizations, and biosolid producers resulting from the inevitable environmental and public health harms of land application of biosolids.
But first a bit of background on the CRD ban on the land application of biosolids:
In 2011, after hearing from numerous local residents, South Island farmers and food producers, Indigenous Bands and environmental groups, the CRD passed a popular and long-standing ban on the land application of biosolids. In doing so, the CRD joined other progressive jurisdictions and environmental leaders such as Germany, the Netherlands, Slovakia, Austria and Japan, and even the State of Maine, all of which have opted to end land application of biosolids in order to protect their environment and public health, and to instead promote waste-to-energy options for the safer disposal of biosolids.
Minister Heyman, you may in fact recall the initial CRD ban on land application, since on April 11th, 2011 as ED of the Sierra Club of BC you sent a letter of support for the CRD ban in which you stated “At a time when the public is more and more supportive of, and aware of, the importance of local food production, the land application of bio-solids seems to directly contradict the responsibility of the CRD to protect the region’s farmland, natural environment and public health” (the letter is attached for your records/review).
We strongly agree with your assertion from 2011 that the land application of biosolids completely contradicts the CRD’s responsibility to protect the region’s farmland, natural environment and public health. As do the region’s food producers, since the Peninsula and Area Agricultural Commission (PAAC), which represents many of the region’s farmers, recently sent a letter to the CRD Board stating their unanimous support for the ban on land application of biosolids on the region’s farms and throughout the CRD.
Moreover, it appears the CRD Board also agrees with your assertions from 2011, because despite ongoing pressure from CRD staff and the Ministry of the Environment – which includes a long history of misleading the CRD Board and public about the potential risks of land application and the associated legal liability – the CRD Board has wisely adopted an evidence-based approach and has upheld the ban on the land application of biosolids to this very day.
Now we’d like to provide some detail about the following concerns:
- The CRD’s Public Consultation Process
As you are likely aware, BC’s Environmental Management Act, Part 3, Section 27 (a) and (b) on public consultation states:
Public consultation process
27 (1) A municipality must provide for a process for comprehensive review and consultation with the public respecting all aspects of the development, amendment and final content of a waste management plan that applies to that municipality.
(2) The minister may not approve a waste management plan unless the minister is satisfied that there has been adequate public review and consultation with respect to the development, amendment and final content of the waste management plan.
Clearly, the CRD has not met the threshold of “comprehensive review and consultation with the public” in the development of its short and long-term waste management plan and has in fact acted derisively towards residents and local businesses rightfully concerned about the harms associated with the land application of biosolids.
First, the CRD website designed to inform the consultation process on biosolids, titled “Long Term Biosolids Management Plan” and found at: https://getinvolved.crd.bc.ca/biosolids, was found to be so grossly inaccurate and biased that, following extensive outcry from the general public, the CRD Board felt compelled to call a special meeting to address the site’s shortcomings. At that meeting, staff were directed by the CRD Board to add relevant details about the long history of the CRD ban, and to provide evidence-based, up-to-date information on the potential harms associated with the land application of biosolids and a more balanced review of the options presented to the public, 5 of 7 of which involved land application, despite the CRD’s longstanding ban. When queried, staff shared they were compelled to include the 5 land application options at the urging of your Ministry, which has consistently pressured the CRD to consider options that ignore or contradict the CRD’s longstanding ban.
Despite modest improvements to the information provided, the FAQs and background material still fail to factually reflect 1) the history of the CRD ban on land application; 2) the current state of regulations around the globe; and 3) the contemporary scientific understanding of the harms associated with land application. A more detailed critique of the information provided, which was sent to the CRD Board and staff on February 9th, is included below as an addendum to this letter. This letter also included the primary findings of an academic scoping review by Pozzebon and Seifert titled “Emerging environmental health risks associated with the land application of biosolids: a scoping review”, in which the authors reviewed, assessed and compiled the findings of 172 top-tier studies examining potential environmental and health impacts associated with the REGULATED application of biosolids on land, finding significant public health and environmental risks associated with microplastics, PFAS, and pharmaceuticals/personal care products that we hope you and your staff will take a moment to review (please see attached).
The CRD’s heavily biased and inaccurate website and associated public feedback survey was followed by an Open House on the topic, which took place on Feb. 20th. In light of the importance of the issue and the associated impacts on our region, many residents and environmental organizations pleaded with the CRD to hold an in-person Open House; however, the CRD opted to proceed with an online-only event. This unfortunately disregarded requests by residents for a more inclusive, accessible and comprehensive consultation process, and omitted participation from a large percent of the population that may have disabilities or lack the technical know-how or resources to take part in this consultation.
However, the most egregious damage done to public confidence in the CRD consultation process was the decision made by the CRD staff organizing the Open House to disable attendee cameras, microphones, and even the “chat” function in the right margin of the meeting website. This is quite literally the equivalent of inviting residents to attend an Open House, and then gagging and putting a bag over their heads upon entry, and then speaking at them for 2 hours, with no opportunity for actual dialogue. While there was a Q&A box available, transcripts from the meeting will show it was mostly used by frustrated attendees to critique the process, while the few questions that were answered were cherry-picked by the CRD staff.
Needless to say, this is absolutely unacceptable and represents a highly cynical and inadequate consultation process, and it obviously falls far short of the “comprehensive review and consultation with the public” mandated by Environmental Management Act.
Since the act also requires further public consultation on the “final content of the waste management plan”, we sincerely hope that the Ministry will ensure that future public outreach on this important environmental and public health issue is fair, free of bias, and includes opportunities for in-person engagement with the CRD. There are established best practices for public engagement used around the world, and it is incumbent on BC legislators to ensure our province’s public process can withstand independent review. The CRD’s recent engagement would not even satisfy a local zoning change, let alone a region-wide consultation that has serious environmental and public health implications.
- The CRD’s Indigenous Consultation Process
We’d like to begin by stating that we do not in any way claim to speak for the Indigenous Bands in the CRD, all of whom are very capable of representing themselves. However, in our group’s engagement with local Bands, it has become apparent that there is growing frustration with the CRD Indigenous engagement process, both on this issue and other issues of importance to regional First Nations.
The CRD’s Statement of Reconciliation includes a recognition of the importance of land and water to Indigenous communities:
Relationship with the Land and Water
The CRD recognizes the integral relationship First Nations have with the land; often the names for the people of the land and the land itself were one and the same. The CRD will work with First Nations on taking care of the land while providing space for cultural and ceremonial use, food and medicine harvesting, traditional management practices and reclaiming Indigenous place names.
However, the inadequate, poorly considered consultation with any Indigenous Bands to date regarding the land application of biosolids tells quite a different story, particularly in light of past opposition to land application by First Nations when the ban was initially considered and passed by the Board in 2011.
It is apparent that any land application of biosolids in the CRD would take place on the unceded territory of local Bands, and academic research suggests that this could significantly impact water quality and wildcrafting in regions where land application takes place. It is therefore incumbent that Indigenous Bands be presented with accurate and unbiased data about the harms and benefits of land application of biosolids, and that these Bands all explicitly agree to permit it BEFORE the CRD considers any land application options.
While the CRD has hired a consultant to engage with local Bands on this issue, the short timeline of 2-3 weeks for this consultation to take place, along with the inaccurate and biased background material the CRD has used in its public consultation process raise significant red flags and suggests that the CRD is not meeting its legal and ethical obligations for respectful nation-to-nation engagement. In our work on this issue, the PBC has met with a number of local Indigenous Bands, and those discussions indicate that the CRD’s Indigenous outreach on this issue has fallen far short.
Out of respect for the Indigenous Bands on who’s ancestral, unceded territory we all live and work, and for the CRD’s acknowledged obligations under UNDRIP, the Douglas Treaty and modern treaty obligations, we strongly recommend that the CRD cease all discussions and considerations of land application options in the CRD until they properly engage with local Indigenous Bands, and only proceed with such considerations once the CRD receives explicit permission to so from any and all impacted Bands.
- Legal liability for government regulators, municipal organizations, and biosolid producers resulting from the inevitable harms resulting from the land application of biosolids.
In 2011, at the request of community members and CRD Directors, the UVic Environmental Law Society provided a legal analysis of potential liabilities associated with the land application of biosolids. This analysis was then updated in 2013, and the latest version is summarized below and attached for your consideration.
Under a section labelled “Provincial Oversight”, this review cites the following:
“In British Columbia, in one case so far, the Environmental Appeal Board found that a permit issued by the province of BC allowing the use of biosolids as fertilizer did not ensure protection of the environment as per the necessary requirements under BC’s Waste Management Act (WMA).
(Organic Producers Assn. of Cawston & Keremeos v. British Columbia, Assistant Regional Waste Manager).
This case illustrates the potential for omissions by the province in its regulation of biosolids. It also illustrates how various administrative bodies might come to different conclusions about the environmental safety of biosolids application to land.”
In regards to Indigenous rights, the review advises of the following:
If there was a First Nation that had valid health concerns about eating wildlife that had come into contact with biosolids, it is possible that a court could find that the application of biosolids effectively eliminated the aboriginal right to hunt for food or other purposes. It therefore may be that the constitutional duty to consult and accommodate aboriginal rights is triggered in relation to governments’ decisions to allow the application of biosolids in areas that provide habitat to wildlife that may be eaten.
And in conclusion, the review states:
Approving the land application of biosolids may open up various parties to legal liability if it results in public health or environmental problems.
A recent meeting with CRD leadership has confirmed this is the only existing review of potential legal liabilities of land application of biosolids, and it continues to inform Board decision-making on this issue at the CRD to this day. However, when this review was initially commissioned, the threat of actual legal liability still seemed largely theoretical, and in response to repeated pressure from the Ministry of the Environment and CRD staff to explore alternatives to the landfilling of biosolids, the Board amended the CRD ban to enable actual land application at Hartland Landfill, and the shipping of biosolids to Nanaimo for land application by Lafarge in mine reclamation efforts, the latter against the express wishes of the Regional District of Nanaimo, which has repeatedly urged the CRD to stop dumping South Island biosolids in the RDN, and to the find other disposal options or locations.
In March, news of a criminal investigation and civil lawsuits against Synagro surfaced from Texas, where the company is accused by a county and local farmers of impacting human and animal health and the environment for selling biosolid-based fertilizer to farmers that was high in PFAS, often known as “forever chemicals” due to their slow breakdown in the environment, thereby rendering the farm land worthless.
Minister Heyman, you might recall that Synagro is also the majority equity holder of the Hartland Research Management Group and has a 20 year contract to produce dried biosolids for CRD. Moreover, it turns out that Synagro has been mired in controversy and accused of poor practices leading to impacts on environmental and public health for decades now.
Here’s a quick look at some press coverage of the Synagro track record, both here in Canada and in the US:
San Diego lawyers sue Synagro, Goldman Sachs over noxious Hinkley waste-pit fire
https://www.vvdailypress.com/story/news/2022/08/09/san-diego-lawyers-sue-synagro-wall-street-titan-goldman-sachs-foul-hinkley-california-waste-fire/10272574002/
– this is quite literally the “Erin Brockovich” town…
Hamilton sends province plan to fix odour-causing biosolids facility
https://globalnews.ca/news/8370311/hamilton-plan-fix-sewage-drying-plant/amp/
– this is from Hamilton, ON.
Investigation reveals cause of fiery explosion at Back River Waste Water plant
https://www.wmar2news.com/local/investigation-reveals-cause-of-fiery-explosion-at-back-river-waste-water-plant
Federal Class Action Lawsuit Filed Against Operators of Woonsocket Sewage Plant
https://www.golocalprov.com/news/federal-class-action-lawsuit-filed-against-operators-of-woonsocket-sewage-p
Lawsuit: ‘Abnormally dangerous activities’ to blame for 2019 plant explosion in Stamford
https://www.stamfordadvocate.com/policereports/article/Lawsuit-Abnormally-dangerous-activities-to-16142697.php
In fact, Synagro has even been sued by the EPA:
UNITED STATES OF AMERICA v. CITY OF WOONSOCKET and SYNAGRO NORTHEAST, LLC
https://www.justice.gov/enrd/consent-decree/file/1457911/dl
As residents and local businesses, we rightfully expect the CRD to live up to its legal and ethical obligation to both protect our public health and make good use of our tax dollars, and the lack of follow up regarding the criminal and civil cases being brought against Synagro in Texas is unacceptable and gives us great concern.
In light of the well-documented potential for the thousands of toxic chemicals found in biosolids – which include PFAS/PFOS, PAHs, microplastics, dioxins, and pharmaceuticals – to cause serious and irreparable environmental and public health impacts, Biosolid Free BC, a PBC member, is calling for a total CRD moratorium on land application in the CRD/Hartland as well as in Cassidy/Nanaimo until the CRD provides answers to some very basic questions. These include finding out if the biosolid processing technology Synagro uses in Texas is materially different than the technology employed at Hartland landfill, and whether the chemical composition of the biosolids in Texas is significantly different than the biosolids produced by Synagro here in the CRD.
Additionally, we urge the CRD to immediately address whatever operational issues are impeding the use of CRD biosolids at Lafarge cement plant on the mainland, and to explore other short-term waste-to-energy options at local cement plants here on Vancouver Island, as well as throughout BC and in neighbouring Provinces and regions. We also share our support for a pilot thermal conversion project at Hartland commissioned by the CRD Board and hope the Province can provide funding for this sustainable solution, and accelerate the necessary permitting for this regional facility, which could ultimately address many of the concerns we raise above.
Lastly, we’d like to share our concern that the Ministry of the Environment is exposed to significant legal liability on this matter. During the 13 years the CRD ban on the land application of biosolids has been in place, your Ministry sent countless letters insisting that the CRD include land application options in its ongoing considerations for the short and long term disposal of biosolids, thereby ignoring growing academic evidence of associated harms to the environment and public health. Additionally, you have repeatedly provided false assurances that land application can be done safely if it proceeds in accordance with the Organic Matter Recycling Regulations (OMRR), despite the fact that OMRR only regulates biological contamination and a handful of heavy metals, and does not in any way address or limit PFAS/PFOS, PAHs, microplastics, dioxins, pharmaceuticals and other chemicals of concern, all of which studies have shown can cause significant impacts to the environment and public health in even minute parts per billion concentrations.
In consideration of the Province’s recent announcement that communities across the province will receive significant improvements to their drinking water and wastewater infrastructure resulting from $98 million in investment from the federal and provincial governments, we urge the Ministry of Health to immediately cease and desist its insistence that the CRD consider land application strategies that are certain to negatively impact local water quality and public health.
Instead, we repeat our request that you work with the CRD on the rapid deployment of pilot thermal conversion plant at Hartland landfill that can serve as a model for waste processing throughout the province, and which can better protect our watershed, farms and forests from PFAS, microplastics and other contaminants found in biosolids. We also urge the CRD and Province to work with the federal government to improve the regulation of emerging chemicals of concern.
As a result of the longstanding and popular ban on the land application of biosolids, the CRD is unquestionably a regional and global leader in a growing movement to protect our natural environment and the public health of residents from the toxic chemicals found in sewage sludge. The PBC’s goal is to work cooperatively with the CRD and Province to resolve this pressing issue — which is the most important environmental and public health issue currently facing our region — in a manner that reflects the current state of academic evidence as well as the wishes and concerns of our community.
Minister Heyman, we appreciate the opportunity to share our concerns with you and the Ministry of Health. We would be happy to discuss these concerns further with the Ministry of the Environment any time, and look forward to your response.
Best regards,
Philippe Lucas PhD
Biosolid Free BC
Winona Pugh
Friends of Tod Creek
Frances Litman
Creatively United for the Planet
Dave Cowen
CEO, The Butchart Gardens
Francois Brassard
Esquimalt Climate Organizers
John MacDonald
Peninsula Streams Society
===
The following is an open letter from Philippe Lucas PhD, founder of Biosolid Free BC, titled “Addressing inaccuracies and improving transparency in the CRD Consultation on Biosolids”. It was sent to the CRD Chair, Board and staff on February 9th, 2024.
Dr. Harris, Chair Plant, CRD Board, and the PBC and other key stakeholders,
I’m reaching out today on behalf of Biosolid Free BC with a note of thanks for the updates that have been made to the ancillary material informing the CRD consultation on the long-term management of biosolids, and to request a few additional related updates.
Despite modest improvements to the information provided, the FAQs and background material still fail to factually reflect 1) the history of the CRD ban on land application; 2) the current state of regulations around the globe; or 3) the contemporary scientific understanding of the harms associated with land application, so we’d like to request that the associated material be updated for the sake of accuracy and to promote informed decision making for those interested in this issue and participating in the consultation and survey.
- As it stands, under the heading “Why is the CRD the only regional district in BC to ban land application?”, the response is: “In 2011, prior to introducing wastewater treatment in the core area, the CRD Board of Directors passed a biosolids land application ban based on the concerns of members of the public.”
Unfortunately, that is entirely inaccurate. As one of the CRD Director that collaborated on the drafting of the original motion, I can share that the initial CRD Board motion in 2011 and follow up Board motion that maintained the ban in 2013 were not the result of “concerns of members of the public”, but rather through the efforts, lobbying and support of local, regional and provincial environmental and agricultural organizations such as the Dogwood Initiative, the Georgia Strait Alliance, the Sierra Club of BC, the Island Organic Producers Association, the Island Chef’s Collaborative, the Farmlands’ Trust, and the Peninsula and Area Agricultural Commission, all of whom submitted written letters of support and strongly advocated for the ban on land application.
Of course, the minutes from those meetings would confirm those assertions, and would also highlight significant opposition to land application by Indigenous Bands like the Dididaht Nation as communicated at the time by Director Mike Hicks, as well as the legal analysis provided to the CRD by the UVic Environmental Law Society (attached) that definitively found that there was significant risk of legal liability for the CRD and any farmers and home-owners that might apply biosolids resulting from harm to the environment, animal and human health, and negative impacts on property value.
All of which I’m sure you would already know, Dr. Harris, since you, Mrs. Hutchinson and some of the current Directors were also involved in those early discussions as well. If the goal is to be transparent, accurate and informative on this issue, it would also be worth mentioning that despite dozens of committee and Board votes on this matter over the past 10 plus years, the Board has ALWAYS voted to maintain the ban on land application, with modest amendments to allow disposal at Hartland and shipping to Cassidy for land application there.
Could you please ensure that this section is updated accordingly? Thanks.
- Under the heading “How are biosolids used by others?”, the response given is: “Biosolids are commonly used within communities across Canada, and the globe; mostly land-applied to add nutrients and organic material back to the land, but also thermally processed and some landfilling.
All other large communities in BC (e.g. Kelowna(External link), Kamloops(External link), Comox(External link) and Metro Vancouver(External link) primarily utilize their biosolids as fertilizer or in compost.
There are currently no full scale advanced thermal facilities processing biosolids in Canada. The CRD is advancing a pilot project utilizing thermal technologies to process biosolids; however, if it proves successful, it will be several years before it can be utilized fully as a permanent facility in the capital region.”
This unfortunately is inaccurate, and fails to tell the full story. Within North America, there are many large and small municipalities that have banned the land application of biosolids, including the entire state of Maine, which banned the spread of any biosolids that contained PFAS due to contamination of milk and animals, and impacts on the environment and farm industry. In fact, the State has allocated $100 million dollars to assist farmers that have had to destroy their livestock due to PFAS contamination. Additionally, New Hampshire, Massachusetts and New York have all severely restricted land application due to concerns over PFAS contamination of drinking water, and in the US trends are moving away from land application and towards thermal destruction.
Finally, as the attached EU report from 2023 makes clear on p. 13, Germany, the Netherlands, Slovakia, Belgium and Austria have banned the land application of biosolids due to concerns of environmental contamination, preferring waste-to-energy projects instead. Japan has also opted for the same strategy in order to protect its agricultural base and environment.
Rather than portraying the CRD ban as a stand-alone out of sync with the rest of the world, isn’t it more accurate to share that we’re at the forefront of an ever-increasing trend moving away from land application due to proven environmental and public health impacts, and towards waste-to-energy along with some of the world’s most environmentally progressive countries and regions?
We look forward to seeing this section updated to more accurately reflect current trends in North America and around the world.
- Recent staff presentations at the CRD and the information provided in the FAQs seem to suggest the potential harms of land application of biosolids are somehow debatable or non-existent, stating “Biosolids do not pose a risk to human health or the environment when they are produced, distributed, stored, sold or used in accordance with all of the requirements in the Organic Matter Recycling Regulation“, and that the only risk would be through mismanagement.
As I have noted on a number of occasions, there are literally thousands of peer-reviewed publications highlighting the risks of land application due to the presence and dispersal of microplastic, PFAS, pharmaceuticals and other toxic compounds. However, I know that it is challenging for staff and Board members to wade through dozens of academic studies, and staff have unfortunately resisted calls for an independent evaluation of the current state of knowledge. Therefore, I’d like to call attention to a recent scoping review specific to the hams of land application of biosolids published in the peer-reviewed journal of Environmental Health in 2023 (attached).
For those who may not know, a scoping review is a scan of the biggest and best studies and academic publications sources, with the goal of determining the current state of the science. In this publication by Pozzebon and Seifert titled “Emerging environmental health risks associated with the land application of biosolids: a scoping review”, the authors reviewed, assessed and compiled the findings of 172 top-tier studies examining potential environmental and health impacts associated with the REGULATED application of biosolids on land, and here’s what they found (please note that these quotes are taken directly from the publication and are unaltered, and all the data is fully referenced in the attached publication as well):
Microplastics:
- …microplastic concentrations were significantly correlated with biosolids applications.
- …studies have repeatedly detected microplastics at significant distances from their source of origin and at higher elevations, indicating their susceptibility to becoming airborne.
- Inhalation of microplastics is associated with oxidative stress in lung tissues, along with general inflammatory responses in airways and bronchi and chronic exposure can lead to death.
PFAS:
- A more recent study investigating the impact of land applying biosolids on the occurrence, concentration, and distribution of PFAS in soils and groundwater detected PFAS in all near surface soil samples (< 30 cm below ground surface), in more than 83% of soils between 30 and 90 cm below ground surface, and in the immediately underlying groundwater.
- PFAS can cause adverse health impacts even at ultra-low concentrations, and have been found to bioaccumulate in animals and humans in lung, kidney, liver, brain, and bone tissue.
- PFAS exposure is associated with reproductive and developmental, liver and kidney, and immunological effects, as well as tumors in laboratory animals. In addition, inhalation of PFAS can cause acute lung toxicity and inhibit lung surfactant function.
Pharmaceuticals and personal care products
- Studies investigating the occurrence and distribution of pharmaceuticals in biosolids following wastewater treatment indicate that pharmaceuticals find their way into the environment mainly through the land spreading of biosolids.
- Preliminary evidence has suggested potential risks that are similar to those observed in aquatic species and these compounds have been implicated as potential contributors to diabetes, cancer, fertility decline, and a host of other environmental and public health issues.
- Ultra-low nanogram per liter (ng/L) concentrations have exhibited impacts to both humans and aquatic organisms, including hormonal interference in fishes, genotoxicity, carcinogenicity in lab animals, endocrine disruption, and immune toxicity.
Conclusions
- The authors indicate that the precautionary principle needs to be applied consistently to ensure a clean and healthy environment for future generations, which is also why further studies on the risks induced by emerging pollutants, due to their specific environmental behavior, toxicity, and impacts on the environment and human health become essential.
- Biosolids, in their current form, have often been referred to as an organic waste to be recovered and recycled. But given the presence of contaminants that originate from both domestic and industrial wastewater sources, is that really the appropriate designation in law or regulation?
- As a society, if we fail to take definite policy actions to modernize environmental standards that pertain to the land application of biosolids, and continue to land apply layer upon layer of these complex mixtures of pollutants to our soil without adequate public health protections in place, and without regard to the long-term environmental consequences, we may potentially cause irreversible damage to the very soils we use to grow our food and to our surface and ground water that sustain life.
Since time is of the essence re. this consultation and the associated discussions and debate regarding how to best handle the region’s biosolids, the CRD and public should certainly use the latest and best available science where available to inform our decision-making about both short and long-term plans.
Thankfully, as an alternative to an independent review of the available data, we can access and cite the findings of this comprehensive academic scoping review to ensure we’re sharing accurate and unbiased information with the region’s elected officials, policy-makers, residents and farmers, and we look forward to seeing the CRD consultation website quickly updated with this “state of the science”, which represents society’s best and most up-to-date understanding of the potential harms associated with the land application of biosolids.
Thanks for your time in quickly correcting/addressing these outstanding issues in order to improve the accuracy of the current consultation materials, Dr. Harris; I hope this will help improve the transparency and academic integrity of this CRD community outreach process.
Wishing you all a good weekend,
Philippe Lucas, PhD
Biosolid Free BC/Peninsula Biosolid Coalition