Open Letter: Feedback to the CRD on the draft Solid Waste Management Plan
February 12, 2021
Colin Plant, Chair CRD Board, and CRD Board Directors
Feedback to the CRD on the draft Solid Waste Management Plan
Please find feedback to the draft Solid Waste Management Plan (the Plan) from the Mount Work Coalition, a non-profit society that formed as a group of concerned citizens with a mission to provide voice and support for the protection and responsible stewardship of the Mount Work Park area through education, advocacy and research.
1. Expanding the landfill
The Plan includes a proposal to extend the Hartland landfill site and earmarks 73 forested acres of carbon sequestering trees to be removed to prepare the area for blasting and excavating the side of a mountain. This is not a 21st century solution to waste management.
The Plan was written through the lens of a business as usual mindset predicting the landfill will reach capacity and therefore need to be expanded no later than 2045 - rather than through a lens of retaining the size of the existing landfill without expansion by rolling out new aggressive programs to reduce the waste over the next two decades. With less waste being dumped in the landfill, there will be less leachate into the rivers and lakes in the area. The Plan requires concrete waste management actions such as dedicated funding for a public educational campaign and financial incentives to encourage startups and incentivize waste management businesses that reuse waste, such as scrap businesses and plastic and rubber recycling.
This biodiverse forest of 73 acres should be kept intact to provide a natural buffer between the park and landfill, to protect species at risk, to protect the lakes and streams and to protect the human health of those using/living next to Mount Work Park directly beside the landfill. The existing trails should remain for the enjoyment of mountain bikers.
The Coalition is pleased to see that the Board at its February 10, 2021, meeting reiterated that it was prepared to consider a more aggressive approach to waste reduction a year following the submission of the SWMP this summer. We strongly urge the Board not to trigger the expansion of the current footprint of the landfill until the amended plan is completed by 2025. The much more aggressive best practice solutions including Zero Waste, Circular Economy and emerging waste to energy technologies will reduce methane emissions to net zero through a complete transformation.
We firmly believe that the CRD can attain its aspirational target of 125 kg per person per year by 2040 with waste reduction strategies already being contemplated such as Zero Waste Victoria; the proposed waste to energy IRM project in Esquimalt and a change in tipping fees application as we will explain later. This new target should be included in the amended SWMP by 2025.
The current plan does not address the climate emergency and the commitment of the CRD and a number of municipalities to become carbon neutral by 2050, continues dumping of over a fifth of total waste in the form of organic matter though banned in law creates more methane and is in direct conflict with the Province’s stated Climate Action goals and will not enable us to meet our 2030 greenhouse gas emissions targets.
According to the World Meteorological Organization’s bulletin, “Carbon dioxide levels continue at record levels, despite COVID-19 lockdown”, approximately 40 per cent of methane comes from natural sources, such as wetlands and termites, but 60 per cent comes from human activities, including cattle breeding, paddyfields, mines, landfills and biomass burning. Nature is now sending us a message, through wind storms and wildfires, and we must act now to do our part, as we have the ability to curb harmful methane emissions from a landfill.
2. What alternatives to landfilling has the CRD considered?
Landfills are a 19th-century solution to waste disposal. Today there are significant alternative technologies that can generate value from waste products. Furthermore, it is clear that without taking a hard look at how we consume and create waste, we will not be able to address the climate challenge that threatens our environment.
Governments across the globe, supported by their citizens have been installing multi-pronged strategies to reduce waste through promoting circular economies, changing consumer behaviour such as banning single use plastics, and investigating alternative uses for waste to energy projects such as gasification now under consideration in Esquimalt. This multi-pronged approach should be a cornerstone to the region’s solid waste management plan. It can eliminate the need to build a bigger landfill, instead moving us in the appropriate direction of zero waste. The CRD staff must work in partnership with other leaders using best practices:
Esquimalt is looking to be an early adopter of IRM/gasification technology that would see their waste converted to energy.
The Regional District of Nanaimo is promoting the 4Rs by cultivating a circular economy; uses tipping fees to encourage waste diversion rather that waste dumping and plans to divert 90% of its waste by 2027. If RDN can achieve a target of 109 kg/person/ year, so should the CRD.
San Francisco is a global leader in waste reduction, has an effective pricing strategy that uses cost incentives/disincentives between waste and recycling.
Switzerland has 100% waste recovery where they use a combination of material recovery and incineration for energy.
Sweden recovers 99% of its waste, converting it into heat that warms homes, power buses and taxis.
The City of Victoria released its Zero Waste Victoria Plan to reduce current waste to Hartland by 50% by 2040.
3. Traffic Diversion to Willis Point Road
The planned relocation of commercial dump traffic to Willis Point Road is part of the draft SWMP. This decision is premature, given the opposition to expanding a landfill in the 21st century, the movement to Zero Waste, a circular economy, and waste-to-energy technologies.
The CRD staff should revisit this decision based on the premise that the landfill will not be expanded and that other regional municipalities will be implementing new technologies to manage their own waste. With less waste being trucked to the landfill, there will be less traffic, no expansion and no reason to reroute traffic. The CRD should be able to construct internal roads and fill alternate cells closer to the existing entrance off Hartland Avenue.
4. Biosolids
The CRD Board reversed its longstanding ban on the spreading of biosolids on land and will be spreading toxic biosolids within the Hartland perimeter for up to 6-8 weeks a year while the Lower Mainland facility undergoes maintenance. CRD communication describes this as a temporary solution, which is absurd since once spread, biosolid toxins remain in the ground, waterways and air - they are not temporary. CRD characterizes the area around the dump as a rural area, which is incorrect - it is a semi-rural with local residential communities and schools very close to the dump area, and the regional tourist attraction of Butchart Gardens, concerned as they are downstream of the dump and use the water in Todd Creek. The area is also home to many organic farmers in close proximity.
The primary challenge with the decision to spread biosolids at the Hartland dump is the lack of scientific evidence to demonstrate that it is safe for the human and wildlife populations in the area. Biosolids, even treated to Class A standards, contain microplastics. The scientific community is now researching the effects of microplastics in our lakes, rivers and streams. As the basic tenet of good environmental governance is the precautionary principle – given the lack of scientific certainty, the decision should be not to spread the biosolids.
Biosolids contain over 300 chemicals. Some will survive the drying process, and any trace of toxic chemical even at the lowest risk is unacceptable and will do significant damage to the 16 species that are endangered or threatened in the area, including the Western Painted Turtle and the Western Screech-Owl. Biosolids soak into the ground water and the wetlands and the 16 at risk species will digest or absorb the chemicals from the biosolids, destroying these endangered wildlife.
5. End Reliance on Tipping Fees as the Primary Source of Funding for Hartland
Reliance on tipping fees to fund Hartland’s operations is counter-intuitive to zero waste. The tipping fee model provides no material incentive to reduce waste; indeed it is a disincentive as is demonstrated by concerns to keep all waste disposal in the region. Tipping fees must be used to incentivize waste diversion as is being done in the Nanaimo Regional District and if alternate sources of funding are required to maintain the Landfill operation, a general tax levy may be required. This is a small price to pay to meet climate change goals.
6. Strategy to Optimize Landfill Gas Management
The Hartland landfill signed an agreement with FortisBC to collect methane from the landfill. We disagree with this strategy as it relies on a steady stream of decomposing waste being dumped into a landfill to feed the FortisBC system for a small amount of RNG. Expanding the landfill and relying on a small fraction of the resulting methane gas collection is contrary to the mandate for the region to reduce GHGs. The landfill must be sustainable into the future without relying on outdated expansions.
In Summary
Our mission is to protect the Mount Work Park region and ensure science-based decisions are made concerning the Hartland landfill activities that impact the parks. As the CRD has declared a state of climate emergency and a goal for carbon neutrality, we believe that expanding a landfill by removing a biodiverse carbon sequestering forest, moving dump traffic and spreading biosolids is contrary to this goal and will lead to an overall increase in carbon. There are opportunities for emissions reductions using new technologies, zero waste initiatives, and increasing carbon sequestration by not expanding the landfill as trees absorb CO2. Minimizing GHG emissions are critical for meeting the CRD’s goals.
Delay any approval for landfill expansion until an updated and amended plan is adopted in 2025.
The amended SWMP submitted in 2025 must establish a target of 125kg/person/year by 2040.
Notify the Ministry of Environment that the CRD intends to submit an amendment to the plan by 2025 with strategies for attaining this target including an aggressive Zero Waste program, and an independent analysis and testing of alternative technologies such as IRM/gasification/Waste to Energy.
The Plan submitted in 2021 should contain a placeholder for the Esquimalt waste to energy project subject to a business case being completed.
Conduct an independent environmental assessment prior to any plans to expand or alter the design of the landfill, including the spread of biosolids, to protect the natural ecosystem, wildlife, community health and the recreational users of the area.
Strengthen the plan’s Zero Waste initiatives by adding concrete plans such as dedicated funding to create business incentives for entrepreneurs; create a public education campaign to draw awareness to Zero Waste, and use tipping fees to incentivize waste reduction instead of encouraging continued use of landfilling as a source of revenue.
Ensure protection of species at risk in Mount Work Park, we are requesting the BC Ministry of Environment reinstate its longstanding ban (2011 and 2013) on the spreading of biosolids, planned to begin in February 2021.
Delay the decision to reroute landfill traffic to Willis Point Road until decisions are made to have regional municipalities manage their own waste with Zero waste and new waste to energy technologies.
The Amended Plan by 2025 would be subject to full public consultation during its development to ensure the public has ample opportunity to engage in accordance with Ministry policy.
Elaine Klimke, Chair
on behalf of Mount Work Coalition
cc: Russ Smith
Larisa Hutcheson
Barb Dejardins, Chair Environmental Services Committee