What is the problem that the CVRD is trying to solve? Should this become an election issue on October 20, 2018?
The project has not broken ground, so there is time to stop this insanity and take the right steps in the right direction.
All calculations and assumptions are ready to be scrutinized.

Facts:
• At two open houses the CVRD had, I asked: what is the problem that requires $112 million dollars to solve? Both times they said that the problem is turbidity.
• They insist that VIHA and specifically Charmaine Enns, the Regional Health Officer, requires that turbidity be less than 1 NTU
• Turbidity greater than 1 NTU happens very rarely
• 2.5 million NTU data readings were provided by the CVRD and were analyzed to infer this conclusion
• There has been no evidence of E. Coli or Fecal Coliform present in the drinking water supply in the Valley found in the test records kept by VIHA for the last 5 years at least.
• Daily water demand decreases substantially the moment water restrictions are implemented.
• The Comox Valley Regional District has failed to demonstrate that a new Comox Valley Water Treatment is needed.
• The solution to turbidity greater 1 NTU rarely happens, and when it does the installation of a multimedia filtration system, capable if retaining particles larger than 5 microns, in line with the current supply pipes before the chlorination equipment will solve the problem. Such filtration system will guarantee that the other two methods of disinfection, chlorination, and UV will eliminate the threats that may be present if the turbidity is higher than 1 NTU. This approach would satisfy 100% of the requirements of the act that regulates drinking water safety.
• The cost of the inline 5-micron multimedia filtration system has been established to be well below $10 million dollars.
• All the information for this evaluation was provided by the CVRD Staff.
• A reporter from the Comox Valley Record was present during the first meeting with Kris La Rose (Scott Strasser) no longer working for this newspaper), the information gathered by him during this meeting was ever published.
• During the course of the meetings with Kris La Rose, the ultimate reason for this project kept changing.
o First, Turbidity
o Amount of water available at the penstock from BC Hydro,
o Deepwater intake became unnecessary
o It is difficult to determine the amount of water needed in the valley because of misuse and leaks
o Water security from the lake, pretending that we don’t get enough rain, even after I pointed out that the Comox Lake watershed gets more than 1,100 mm of rain every year
o Population increase
o More water for lawns
• it was obvious that they don’t have a clear picture of why we are doing this
• Faith and trust were brought up as a reason to leave them alone and stop my questioning; that was a laugh!
• Turbidity has been eliminated as the reason for the project.
• There is no need for the deep-water intake; words spoken by Kris La Rose.
• The origin of turbidity in the water has been determined to be from Perseverance Creek; VIHA, through Germain Enns, has issued mandate orders to the CVRD, the Village of Cumberland and TimberWest to fix the problem. A study was done in 2015, and the issue was dropped, it has been ignored ever since and nothing has been done.
• I brought up the issue of accountability to Kris La Rose, as being responsible for wasting $100 million dollars of our money; his response: I don’t care, I just work here.
• In the recent past, Kris La Rose, was in charge of the South Sewer Project, he failed to justify spending $56.2 million dollars to serve 950 homes ($59,000/household), this could have been done for about $4 million dollars or less; fortunately, it was rejected at the referendum. Kris La Rose needed a job, and this is where he landed, unfortunately for us.
Let’s determine the size of the insanity:
• Fails the basic environmental scrutiny, destroys the surrounding ecosystem at a completely unnecessary level.
• It has no evidence of stewardship of the land and water.
• Today’s demand is 22 million liters per day average throughout the year, it is supposed to be reduced, not increased, according to the Official Community Plan and the Sustainability Strategy that was put in place in the Comox Valley as a bylaw as far back as 2010.
• No water meters and no water conservation measures have been implemented due to fear of unpopularity
• Why are we solving a problem that belongs to a future generation?
o Projected water production at startup in 2019 63.5 million liters per day (2.64 times)
o Projected water production at startup in 2029 80 million liters per day (3.33 times)
o Projected water production at startup in 2069 140 million liters per day (5.83 times)
• Average daily use of water per capita in the Comox Valley drinking water service area today is 482 liters per day per person, almost double the national average.
• Even at double the size of the current population, they say that each person will use 888 liters per person per day in 2030, the hell with water conservation and metering.
• Average daily use of water per capita in Canada is 250 liters, Cumberland is 330 liters per day with meters
• The approved budget for the project is now 112 million dollars, money that we don’t have.
• A solution to the turbidity problem that triggers this project could be resolved with a 10-million-dollar investment, or less, Three different filtration systems quotes have been obtained from worldwide known Filtration Companies, Amiad, Yardney, and Orival, these quotes are available upon request.
• This project lacks an ethical decision-making process, it fails to select an 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 on Kris La Rose side.
• Based on purposely inaccurate mathematic calculations to justify the proposed demand.
• There is no capacity at the current sewer plant, the maximum capacity is 19,400,000 liters per day,
• There will be no need to increase the capacity of the sewer plant for a long time if water conservation measures are implemented; the sewer plant upgrade is expected to cost $67 million dollars.

Known elected officials behind the project:
• CVRD Board of Directors
• Bob Wells
• Edwin Grieve
• Larry Jangula
Employees at the CVRD that are behind this project, who I have met with and have no interest in changing directions:
• Russell Dyson, Chief Administrative Officer
• Marc Rutten, General Manager of Engineering Services Branch
• Kris La Rose, Senior manager of water & wastewater services
Meetings with the CVRD staff in charge of the project have established the following:
• The need for a new filtration system is a matter of faith says Kris La Rose, all other arguments lack substance.
• Max capacity of the existing system is far higher than we use, we are permitted to use: 9.1 million m3/year
• There are two main pipes at the chlorination facility, each one capable of carrying more than 98,000 m3/day
• The deep-water intake has been deemed unnecessary since the turbidity level does not improve from the quality obtained at the penstock, the current intake
• A multimedia filtration system with a retention rate of 5 microns is the appropriate measure that is necessary to reduce turbidity at the required levels of less than 1 NTU
• The increased demand during the summer months is due to the irresponsible use of water to water lawns
• CVRD staff declare that the proposed water saving strategies established in the Bylaw of Sustainability Strategy are unrealistic, irrational and utterly impossible to achieve
• Universal water metering in Courtenay and Comox is not likely to be implemented soon
• We were told that the initiative to implement water restriction levels 2 and 3 were rejected by the CVRD board, but, the bylaw was amended so water restrictions 2 and 3 can be implemented when deemed necessary, such as low water levels at the Comox Lake, low flow of the Puntedge river, etc. (section 7)
• Water restrictions measures were implemented, and lower demand is expected; actual flow measurements will be requested.
• According to Kris La Rose, for BC Hydro, manager of the river flow, fish, and electricity production take priority over drinking water.
• We need the CVRD to concentrate on reduction of water use, not increase production so it can be wasted.

At the end of my last meeting with Kris La Rose, he asked me the strangest thing; he requested for me to have faith in him by trusting that he was doing the right thing. I could only smile; I told him that faith and trust had nothing to do with the CVRD decisions or his failure to justify spending 112 million dollars of our money on the Water Filtration System that we don’t need.
The argument presented by the CVRD represented by Kris La Rose, after all the other arguments were debunked is that the new system is a matter of water security.

Again, solving a problem that doesn’t exist. Because the CVRD says there is one? and that we should trust that they know what is best for us?

An important fact that needs to be established once and for all is that there has been no system-wide evidence of E. Coli or Fecal Coliform in the Valley in the last 5 years according to VIHA test records. It is also evident that daily demand decreases substantially immediately after water restrictions are implemented.

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 been established, 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 $112 million-dollar expenditure in the water treatment plant the CVRD is proposing.

Kris La Rose provided the raw data, and of the 2,629,440 (yes, 2.5 million readings) turbidity readings for the period of 2013 to 2018, that were analyzed, only 229,054 were greater than 1 NTU, and after a careful statistical analysis, has become evident that the evidence of turbidity to justify the water treatment system that is proposed has been manipulated to make the situation worse than it actually is. High turbidity readings are not consistent to require the number of days that the CVRD has issued water boiling advisories.

To illustrate this situation, 1,440 readings per day over 1 NTU are needed to call it a high turbidity day; only 144 days out of 1,826 days (5 years) where such, and 51 of them were at the time the big rain event at Perseverance Creek between December 9th, 2014 and January 12th, 2015, and no evidence of E. Coli or Fecal Coliform were reported during any of the 51 days.
The design capacity of the system is 147,000,000 Liters of water per day when the actual demand @ 482 Liters per person per day in the service area is only 23,569,000 Liters per day (6 times bigger), this is insane.

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 Water License CVRD holds is conditional water license, issued by the Ministry of Environment, permitting a maximum annual diversion of 9,092,180 cubic meters (m³)/year and a maximum daily diversion of up to 70,464 m³ from the Puntledge River. This equates annually to only approximately 0.84% of the available allocated water with the rest being allocated to BC Hydro (82.54 %) and DFO (16.62 %).

According to this, fish and electricity production takes priority over drinking water, interesting enough, we don’t need more than that for flushing toilets, water our lawns, wash our cars, rinse our driveways, fill up our pools, fill up our hot tubs, wash our clothes, shower, wash our dishes, clean our teeth, wash our hands, and oh! Yes, drink water (about 4 liters a day out of the 482 liters/day we demand from the CVRD water system)

CVRD has previously applied for an increase to its licensed allocation; however, the Ministry of Environment has closed this application. It is expected that CVRD will be required to meet the provincial target set out in the Living Water Smart Plan stipulating that 50 % of new municipal water needs are to be met through conservation. The Province of BC has also indicated quite strongly, as further evidenced by recent water license agreements in other BC jurisdictions, that any increase to the licensed amount for the CVRD would require significant demand measures be put in place, such as water meters. In 2008, the Village of Cumberland had their water license increased; however, it was contingent on the installation of universal water meters.

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.

This is my humble contribution to fighting the irresponsible manner our public officials waste the resources placed in their hands, knowing too well that nobody is going to make them accountable for their bad decisions and like in this case, a dubious reason to spend $112 million dollars.

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.

Increase in turbidity in the winter of 2014 was a one-time event; it was never like that before or after.
A multimedia direct filtration system that will correct the turbidity problem at a cost of $10 million dollars or less. This filtration system before the chlorination station will 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 liters per day to cover our needs for the next 50 years. What gives the CVRD to decide how to take care of the water needs in 20, 30, 40 or 50 years? Have they ever heard of Gamma Irradiation for water purification? Reverse osmosis? Thermal disinfection? Disinfection using the domestic hot water tank that is heated by a CO2 heat pump, 80 C minimum?
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 $10,000,000, 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.

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.

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.

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 $112,000,000.00 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 performs 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 is revenue, 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, assuming $0.25 profit / M3 is $6,800,000/year revenue for the CVRD, that is 124 employees @ $55,000 / year salary. 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 482 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 and/or social discrimination at the CVRD is rampant, but will not be tolerated, I have the credentials to be a critic.

Discrimination Issues:
• Kris La Rose believes that I don’t know much about the issue because my Chemical Engineering Degree was not obtained in Canada; that is intellectual discrimination at its best
• Kris La Rose implied that because I am from Mexico I don’t understand that we are in Canada, and there are rules, implying that I am from a country that has no rules. Ethnic Discrimination
• Kris La Rose feels irritated talking to me like I am not supposed to question his information or opinion? That is Social discrimination or plain bullying.

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

Eduardo Uranga