Dear CRD Board, Senior CRD staff, and Minister Heyman,
I’m sure many of you saw the following article on CBC this weekend highlighting a lawsuit launched by the BC government against the manufacturers of PFAS chemicals for contaminating drinking water and endangering human health: https://www.cbc.ca/amp/1.7243226
While we strongly applaud these attempts to protect our environment and public health, the hypocrisy of this action – coming from a provincial government that has repeatedly forced the consideration of land application of biosolids in the CRD (and throughout the Province) despite the CRD’s longstanding ban on this practice specifically to avoid contamination of our waterways, farms and fields with PFAS and other chemicals of emerging concern (CECs)such as microplastics, pharmaceutical and PAHS – is not lost on us and is of great concern.
The article states that:
“…the defendants knew that when their products were used as directed, “toxic PFAS chemicals would be released, would contaminate the environment for centuries, and would pose significant threats to human health.”
“The defendants did not warn the Canadian public of the dangers posed by their PFAS-containing products or take any steps to modify or remove their products to avoid these harms — instead, they concealed and affirmatively contradicted the known dangers in public statements and marketing campaigns designed to enrich themselves at the public’s expense,” says the lawsuit, filed Friday in the Supreme Court of B.C. in Vancouver.
Unfortunately, the exact same accusation can be made of the Ministry of the Environment and CRD, who both continue to endorse policies that result in the widespread distribution of biosolids laden with PFAS and other CEC’s throughout the region, despite being well aware of the impacts and risks to the environment and public health.
Indeed, despite the CRD having test results showing its biosolids contain PFAS and other chemicals of concern, and organizations including the Peninsula Biosolids Coalition and Biosolid Free BC repeatedly providing peer-reviewed academic data to the CRD and Ministry of the Enviroment showing that PFAS dispersal into our environment is largely due to the spread of biosolids, and that PFAS and other CECs can have significant impacts on health in even minute quantities, the Ministry of the Environment has consistently insisted via direct communication to the Board and staff that land application is “beneficial” and has to be a consideration in the CRD, and in response the CRD has proceeded with land application at Hartland – and now in Cassidy beside the Nanaimo River – thereby knowingly exposing the public and environment to PFAS and other potential toxic contaminants.
In light of this pending lawsuit against the manufacturers of PFAS and the obvious/unquestionable legal liability associated with the status quo, the only responsible approach would be to immediately halt all CRD strategies that would involve land application, and instead store the biosolids in a biocell until the demonstration thermal conversion plant is up and running, at which point the stored biosolids could be mined as feedstock and be converted into energy.
The Province and CRD cannot continue to be complicit in the dispersal of PFAS via so-called “beneficial” land application strategies; this policy knowingly poisons our environment and endangers our public health, and – as this lawsuit makes clear – it also puts CRD tax payers at significant risk of liability and effectively undermines lawsuits against the chemical companies that started this problem in the first place.
Shouldn’t our region’s environmental policies be informed by science and common sense? In light of the ever-growing evidence of inevitable harms and associated legal liabilities associated with PFAS and other CECs when biosolids are land applied, isn’t it time to stop…completely stop…the CRD from spreading biosolids on land, whether it’s here in our backyard, up island or anywhere else?
Philippe Lucas PhD
Bisolid Free BC
Peninsula Biosolids Coalition