Dear Comox Valley Resident:

Hopefully, after reading this you will reconsider your support to the Comox Valley Water Treatment Project

Why are we fighting a problem that doesn’t exist?

The Comox Valley Regional District has failed to demonstrate that a new Comox Valley Water Treatment is needed.

We need to work as a community to oppose the CVRD project to filter 147 million liters of water per day from the Comox Lake unnecessarily.

The need for this system has not clearly established because the turbidity of the water is not the reason we are going to get sick from drinking that water. There are not laboratory test results from VIHA’s website that show any evidence of E. coli or fecal coliform contamination in recent years in the water coming out of the water chlorination station, I have reviewed the water test results in the last 8 years and have not found the evidence to justify the $110 million-dollar expenditure in the water treatment plant the CVRD is proposing.

The design capacity of the system is 147,000,000 Liters of water per day when the actual demand @ 481 Liters per person per day in the service area is only 23,569,000 Liters per day (6 times bigger).

The actual capacity of the system is measured at 8,000,000 M3 per year, for 49,000 residents served by the water system; this makes it approx. 22,000 M3/day current demand.

The deep intake is not necessary, turbidity is higher at the deep-water intake than it is at the penstock; it makes no difference once to the turbidity under the current conditions. Intake point is not important, why not maintain the current intake at the penstock if there are no advantages?

We also do not need the extra capacity for drinking water, especially if the water conservation measures proposed in the Comox Valley Sustainability Strategy adopted in 2010 as a Bylaw are implemented, 50% of water consumption reduction by 2030. Also, the implementation of water metering of all households has been proved to be an effective way to reduce water consumption.

The biggest issue with the extra water proposed is that the current capacity of the sewer treatment plant in Comox is only 19.8 ML/day, where are they going to put all the extra water that they will feed to the houses? 75,000 M3 / day going into the houses and only 19,800 M3 capacity to catch and process it. Also, to be considered is that CVRD lacks an appropriate place to deposit the effluent from the wastewater treatment plant.

4-3-2-1-0 Drinking Water Objective

Island Health has adopted the Drinking Water Treatment Objectives (Microbiological) for Surface Water Supplies in BC14 (known as the 4-3-2-1-0 drinking water objective). This means that water suppliers will be required to provide long-term plans to reach the goals of:

  • 4-log inactivation of viruses
  • 3-log removal or inactivation of Giardia and Cryptosporidium
  • 2 refers to two treatment processes for all surface drinking water systems
  • 1 for less than 1 NTU of turbidity with a target of 0.1 NTU (for filtered supplies)
  • 0 total and fecal coliforms and E. coli

as written in the document:

“4 refers to a 4-log reduction in viruses: For every 10,000 viruses in the water, a treatment system should be capable of inactivating 9,999 of them. Most viruses are easily inactivated by the use of chlorine.

We have Chlorination.

3 refers to the 3-log removal or inactivation of parasites: For every 1,000 parasites in the water, a treatment system should can remove or inactivating 999 of them. Two common parasites are Giardia and Cryptosporidium. To remove parasites filtration is required. To inactivate parasites ultraviolet light or ozone or chlorine dioxide will need to be used. Health Canada has developed design guidelines to outline treatment methods which will provide the inactivation desired.

We have UV light treatment

2 refers to two treatment processes for all surface water or unprotected groundwater: There is no single treatment technology that can assure drinking water safety on its own. A minimum of two treatment barriers is required for water that is at risk of containing pathogens and that includes all surface waters and some groundwater sources. Filtration and disinfection will generally be required for most surface water supplies to ensure a safe supply of water. For systems with very high-quality sources and effective and ongoing watershed protection, 2 forms of disinfection may be permitted.

This will generally be chlorination and UV light disinfection.

We have Chlorination and UV light disinfection

1 refers to maintaining a turbidity of less than 1 NTU: Turbidity of less than 1 NTU should be maintained. Raw surface water will need to be filtered if turbidity readings indicate poor results. Turbidity is caused by particulates in the water and can generally be described as cloudiness. The health risk increases as turbidity increases and the health risk will increase before cloudy water is noticed. Particles in water can include clay, silt, finely divided organic and inorganic matter, plankton and other microscopic organisms. These can limit disinfection or treatment and protect disease-causing pathogens. For disinfection and treatment systems to be effective, the water must be less than 1 NTU.

Turbidity in the water has been identified as silt from erosion caused by logging and collapsing of the banks of Perseverance Creek, a particle with an average size of 44 microns, ranging from 20 to 75 microns. A multimedia sand filtration system is sufficient to bring the biggest particle in the water to be 5 microns or less; the cost of that system is substantially less than $3 million dollars or less, all expenses included. This system would be just added to the existing system, just like the UV light disinfection was just added at a cost of about $1 million dollars; which reduced the problem by 80% according to CVRD personnel.

A supplier was contacted and gave the ballpark figure of $3 million dollars or less.

0 refers to Bacterial Indicators: Most of the viral, bacterial and parasitic pathogens that contaminate drinking water are shed from the feces of humans and animals. It’s not practical to test for each possible pathogen so an indicator organism (E. coli) is used to test for the possible presence of disease-causing microbes. There should be “0” indicator organisms present in a treated water sample.

All test results for the last 5 years have been found to show no evidence of system-wide E. coli contamination.

Q: What is the problem?

A: Turbidity at the penstock was greater than 1 NTU’s for two days in November of 2015.

The banks of Perseverance Creek collapsed in the fall of 2014 and caused high turbidity for the entire winter of 2014-2015, forcing water boiling advisory for a period of 45 days, turbidity was well below 1 NTU for the rest of the year except for two days. the data for the years of 2016 and 2017 was not presented by the CVRD during the information sessions or on their website. A multimedia filtration system that will correct the turbidity problem at a cost of $3 million dollars or less.

Instead, ask them to implement a filtration system before the chlorination station to eliminate the turbidity of the water caused by silt that prevents chlorination and UV treatment from eliminating the threat of bacterial contamination. The CVRD is under the incorrect assumption that we need 75 million liters of filtered drinking water by 2019 and 140 million liter per day to cover our needs for the next 50 years.

The most important objection to this project is that the parameter that triggers this requirement from VIHA’s health officer Charmain Enns is that turbidity needs to be brought to less than 1 NTU, which is achievable by the addition of an inline multimedia sand filter system that would cost less than $3,000,000, allowing the chlorination and UV systems to perform the water disinfection required by the regulations. I have checked the test records for the Comox Valley for the last 5 years for E. Coli and fecal coliform and we have not had one single system-wide incident. The 4-3-2-1-0 Drinking Water Objective is not compromised if the suggested filtration method is implemented.

The need for this system has not clearly established because the turbidity of the water is not the reason we are going to get sick from drinking that water. There are not laboratory test results from VIHA’s website that show any evidence of E-Coli or fecal coliform contamination in recent years in the water coming out of the water chlorination station, I have reviewed the water test results and have not found the evidence to justify the $110 million dollar expenditure in the water treatment plant the CVRD is proposing, a filtration system right before the chlorination station will resolve the turbidity issue at a fraction of the cost. No testing has been found to have been done to determine the bacterial quality of the water at the chlorination station during the boiling water advisory periods, which historically have been only a maximum of 48 days per year. The cost of this project is $110,000,000.00 for capital cost and more than $500,000.00 per year in electricity  expenses alone, it is designed to filter 73,500,000 liters of water per day in the beginning and 147,000,000 liters per day in the second stage, when only 100,000 liters per day are needed to supply to 4 liters of water per day to the 49,000 people the water supply system serves, the expected population of the Comox Valley in 2019.

It is obvious that the data has been manipulated to make the Water Treatment Plant’s case, but you cannot make a person understand something if his salary depends on not understanding.

Since water is drawn out of BC Hydro’s penstock, the CVRD also has an agreement with BC Hydro for this use, which includes compensation for lost power sales as well as a maximum withdrawal rate of 79,556m³/day, this assures that the maximum daily demand or 50,000 M3/day can be met with the current system. As such, the CVRD pays compensation to BC Hydro for all water withdrawn from the penstock except for times when BC Hydro conducts controlled releases from the dam due to high lake levels, or when the CVRD is withdrawing water from the pump station below BC Hydro’s generating station. This arrangement will continue to exist even if the CVRD were to develop a deep-water intake in Comox Lake for municipal water supply, as the total amount of available licensed water will not be affected. Along with the rising cost of electricity, the cost of compensation for lost power sales is rising and could become limiting over time.

Adherence to the maximum withdrawal limits is one factor in the design of the CVRD’s WEP.

The design capacity of the system is 147,000,000 Liters of water per day when the actual demand @ 481 Liters per person per day in the service area is only 23,569,000 Liters per day (6 times bigger). The cost per household is $5,526 (19,000 households). For reference, a 5 stage reverse osmosis domestic filtration system with a 175 liter per day capacity costs $324.00 CAD per household ($6,156,000 for 19,000).

To put this in perspective, The cost to reduce the carbon footprint of the Comox Valley and mitigate our effect on Climate Change would be $118,000,000. Replacing all the wood stoves for heat pumps (there are approximately 5,200 wood stoves in the Comox Valley, and it would cost about $31,000,000 to replace all of them @ $6,000 each). There are 29,000 households in the Comox Valley, at $3,000 per solar water heater, $87,000,000. The CVRD Water Filtration system cost plus operating expenses for 20 years: $120,000,000. All this could be made possible by issuing Green Bonds or by Local Improvement Charges.

The big question, how much revenue is the Water Treatment Plant is going to generate for the CVRD? I insist that it is the main reason for this project, the same reason the CVRD is not interested in implementing the Zero Waste Strategy, they cannot afford the reduction of revenue from the landfill to pay for the enormous payroll they have; water supply revenue, garbage revenue, sewer treatment revenue, that a gold mine for the CVRD. 75,000 M3 of water / day, at $0.25 profit / M3 is $6,800,000/year revenue for the CVRD, that is 124 employees @ $55,000 / year salary. I insist that there is revenue for the CVRD as the main reason for this project. Please check the water supply system report to verify how much of the CVRD revenue depends of water supply services. Currently, the CVRD revenue from sales of water services is $4,539,692 for 7,800,000 M3 /year; it will be 27,375,000 M3 / year bringing approximately $20,000,000 / year revenue; what a nice pay raise, isn’t it?

The actual capacity of the system is measured at 8,000,000 M3 per year, for 49,000 residents served by the water system; this makes it approx. 22,000 M3/day current demand and an average of 447 liters per person per day average. The new filtration system has a phase one production capacity of 75,000 M3 per day, with phase two to 140,000 M3 per day. Where is that demand?

The deep intake is not necessary, turbidity is higher at the deep-water intake than it is at the penstock; it makes no difference once to the turbidity under the current conditions. Intake point is not important, why not maintain the current intake at the penstock if there are no advantages? Check turbidity comparison report published by the CVRD.

The pumping station using vertical turbine pumps requires the pumps to be immersed in the water to work; in my opinion, this method is too complicated and difficult to implement, let alone maintain and very expensive to run. Now, there is no pumping required to supply the water we need at the penstock.

We also do not need the extra capacity for drinking water, especially if the water conservation measures proposed in the Comox Valley Sustainability Strategy adopted in 2010 as a Bylaw are implemented, 50% of water consumption reduction by 2030. Also, the implementation of water metering of all households has been proved to be an effective way to reduce water consumption.

The biggest issue with the extra water proposed is that the current capacity of the sewer treatment plant in Comox is only 19.8 ML/day, where are they going to put all the extra water that they will feed to the houses? 75,000 M3 / day going in with only 19,800 M3 capacity to catch and process it. Also to be considered is that CVRD lacks an appropriate place to deposit the effluent from the water treatment plant.

All the engineers that I have contacted for their opinion have said that this project is a waste of public money, and totally unnecessary, I would share their contact information if this declaration goes public.

I have a degree in Chemical Engineering and have worked with filtration systems and pumps. Intellectual, ethnic or social discrimination by the CVRD will not be tolerated, I have the credentials to be a critic.

  • This project lacks an ethical decision process, it fails to select the best ethical alternative and it is immoral.
  • It is not sustainable
  • it could not be operated for the 50 years it pretends according to the designers
  • fails to meet our own needs
  • compromises the ability of future generations to meet their own needs
  • It is socially irresponsible
  • Doesn’t fulfill the obligation to benefit society at large
  • Does do not have the necessary science to support its necessity
  • The complexity of the technology is not required
  • Shows doubtful engineering evaluation.
  • Based on inaccurate mathematics calculations to justify the proposed demand.

Are we going to allow this trumpery? (Trumpery: defined as “useless nonsense” in the dictionary since the 1,500’s)

Sincerely,

Eduardo Uranga

250-898-4874

uranga@shaw.ca