Dear CRD Chair and Board,
Let me begin by thanking you all for your continued support for the popular and longstanding ban on the land application of biosolids in the CRD.
This is just a quick note to share a news story from the Guardian about a community group suing regulators for spreading biosolids they knew were contaminated with PFAS, a situation that mirrors the CRD’s current policy on biosolids, which despite a long-standing ban on land application in the CRD, is still actively spreading biosolids at Hartland landfill and near Cassidy:
https://www.theguardian.com/
“New legal action could put an end to the practice of spreading toxic sewage sludge on US cropland as a cheap alternative to fertilizer, and force America to rethink how it disposes of its industrial and human waste.
A notice of intent to sue federal regulators charges they have failed to address dangerous levels of PFAS “forever chemicals” known to be in virtually all sludge.
The action comes as sludge has contaminated farmland across the country, sickening farmers, killing livestock, polluting drinking water, contaminating meat sold to the public, tainting crops and destroying farmers’ livelihoods.
The practice “doesn’t pass the straight face test”, said Kyla Bennett, policy director for the Public Employees for Environmental Responsibility (Peer) nonprofit, which filed the notice.
“EPA has known for years that there is PFAS in biosolids but they are sitting on their hands, and I can think of no better ways to contaminate America than PFAS in pesticides and PFAS-laden biosolids,” she said. “We’re going to get the EPA to start regulating this shit, literally.”
And just a reminder that the State of California set the stage for this most recent legal action in it’s successful +$10 Billion lawsuit against 3M:
https://www.cbc.ca/news/world/
“Chemical manufacturer 3M Co. will pay at least $10.3 billion to settle lawsuits over contamination of many U.S. public drinking water systems with potentially harmful compounds used in firefighting foam and a host of consumer products, the company said Thursday.”
Finally, attached is a 2023 scoping review clearly outlining the known threats to the environment and public health from land application of biosolids, along with the UVic Enviro Law Society’s review of the potential legal liability the CRD faces as a result of the land application of biosolids. While the legal review is from 2013, our knowledge of the harms of PFAS, microplastics, PAHs, dioxins has only increased since then, thereby also increasing liability for knowingly introducing these chemicals into the natural environment.
It’s apparent that the CRD is completely liable for any harms associated with land application, which range from impacts on the environment and public health, to potential reductions in property value for land owners directly or indirectly impacted by land application at Hartland, Cassidy and throughout the CRD’s green belt which is at risk of contamination via wind and rain erosion.
Safe containment or use in waste-to-energy applications are really the only solution to this dilemma, and the PBC strongly supports the CRDs RFP for a gasification pilot project at Hartland, but urge all involved to accelerate the pace of this project and to immediately find safe storage solutions or use as alternatives to fossil fuels in the interim.
Best regards,
Philippe
Philippe Lucas PhD