Our Key Concerns
Massive LANDFILL EXPANSION AT HARTLAND:
With a lack of consultation, lack of research of more climate-accountable alternatives, and lack of a formal Environmental Impact Assessment, the CRD draft Solid Waste Management Plan outlines plans for massive expansions to the Hartland landfill despite the CRD claiming a climate emergency and despite evidence that the Hartland watershed cannot manage further development.
These are the key issues that arise out of the CRD plans for Hartland Landfill expansion:
the failure to consider sustainable 21st Century alternatives to dumping garbage into a big hole:
Emissions from Canadian landfills account for 20% of national methane emissions and Canada's Greenhouse Gas Inventory notes approximately 30 Megatonnes (Mt) of carbon dioxide equivalent (eCO2) were generated at Canadian landfills in one year (2015). Landfills are a significant contributor of GHG emissions.
The CRD, through landfill of solid waste, produces 96, 386 metric tonnes of GHG (eCO2) per year (Stantec: GHG Reporting Year Results, August 11, 2020).
The solid waste deposited at Hartland Landfill in 2019 totalled 148487.4 tonnes and this is projected to increase over then next 20 years by 20% in relation to the population projections (Stats Can April 2019 report to CRD).
Other municipalities and regional districts have implemented more environmentally sound and technological solutions to help significantly reduce waste to landfill. These alternatives include:
Zero-Waste-to-Landfill
Integrated Resource Management
Gasification
Waste-to-energy
Circular Economy
As well as simple community initiatives to encourage residents and businesses to avoid placing compostable and reusable items in the landfill.
Unfortunately, the CRD management has developed a draft Solid Waste Management Plan that proposes a massive expansion of the Hartland Landfill and has failed to research and present more progressive and sustainable alternatives - ones already employed around the world that reduce waste to landfill (sometimes to zero) and reduce GHG emissions.
CRD is Making long-term Commitments Without Provincial Approval:
While we must commend the CRD on looking at ways to reduce GHG emissions, the proposed contract with Fortis BC to buy RNG from the CRD comes with a long-term commitment. With no provincial approval on the CRD's proposed landfill expansion plan at Hartland, this contractual agreement provides a commitment past the current lifespan of the landfill.
It also comes with a financial commitment from the CRD to invest and build the RNG facility ultimately putting the CRD in a position to move forward with the landfill expansion prior to an Environmental Assessment under the BC Environmental Assessment Act (and the Federal Act).
In addition to this, significant infrastructure will be required in order for Fortis BC to tie in their natural gas lines to the Hartland infrastructure creating further construction at Hartland itself and along Willis Point Road leading to the facility.
CRD Expansion Plan Lacks Environmental Considerations and GHG Reduction
With the exponential growth occurring in the Westshore consideration must be taken to providing a landfill facility closer to the source of raw waste materials. The city of Langford is expected to see the largest gains in terms of its weight in the CRD, representing up to 13.2% of the CRD population in 2038, up from 9.4% in 2019.
This will have an impact on an already overburdened commuter corridor (Malahat, Helmcken Road, Wilkinson Road) and increase delays for residential, commuter and emergency vehicle access to the hospital.
Construction efforts in Langford and the Malahat area have recently exploded. This means all refuse is being inefficiently trucked to the Hartland landfill as it is the only landfill site on the South Island and this distance could potentially increase if a change to primary access to the landfill is approved. With limited opportunity for expansion in the already densely populated peninsula there is relatively low industrial waste produced near the landfill site.
The proposed expansion plan includes:
removal of 73 acres of forest, including the last stands of old growth Douglas Fir on the Peninsula.
blasting and aggregate quarrying right up to the boundary between Hartland Landfill and Mount Work Park, as well as Durrance Lake regional park.
These areas are known habitat for sixteen endangered species, in particular, the Western Screech-Owl.
Location:
Proper siting of a landfill site is one of the most important aspects of environmental protection and is of the most important consideration when it comes to Provincial planning guidelines.
From an environmental perspective, the principal objective of landfill site selection is to identify a suitable location for a landfill:
to safeguard public health
to have minimal impact on the environment.
The location of the Hartland landfill is no longer considered appropriate in terms of its proximity to the public recreation, environmentally sensitive areas such wetlands, and other natural resources such as surface water and aquifers.
The lack of meaningful community consultation and A Formal Environmental Assessment of new projects:
Due to the substantial change in operations planned at Hartland, including treatment of sewage, application of biosolids, quarrying of rock, a dramatic expansion and reorientation of the traffic to the landfill, and the lack of appropriate consultation thus far, it would be appropriate for the project to receive formal review under the Environmental Assessment Act.
Given the significant project changes and undertaking involved with the CRD’s expansion plans, there is likely to be cumulative damage caused - specifically relating to mining and the new Renewable Natural Gas facility.
If the CRD skirts having a proper Environmental Assessment completed, the likely result could be serious environmental, social, and economic harm to CRD citizens, First Nations and businesses.
Given that the CRD has, thus far, failed to undergo meaningful and fully transparent community and stakeholder consultation (rather than vague info-sessions that fail to highlight the full extent of the plans), undergoing an Environmental Assessment would ensure meaningful consultation with stake-holders, particularly of First Nations.
New Access to Landfill VIA Willis Point Road increases GHG emissions, Disrupts Habitat of At-Risk Species, Puts public at risk
The CRD wants to change the primary access for public and commercial refuse drop-off from Hartland Avenue to Willis Point Road.
Key considerations being overlooked by the CRD:
This will not only double the driving distance to access the landfill increasing GHG emissions but it could potentially increase the risk to users as Willis Point Road has much higher traffic and volume of cyclists when compared to Hartland Ave.
Over the past 10 years, Willis Point Road has seen a growth in traffic that is 10 times that of Hartland Ave. It can only be presumed that with regional growth and limited access to greenspace, Willis Point Road will see more recreational and commuter traffic in the near future.
The CRD as been unable to provide clear information to the public as to why a change of access is required yet, this change will significantly affect recreational users from all over the CRD who hike, bike and swim at Mount Work, Gowlland Tod Provincial Park, McKenzie Bight and Durrance Lake putting public safety at risk as they share the road with heavy haulers and large vehicles.
Safe Management of Toxic Biosolid Waste:
The Capital Regional District plans to spread toxic biosolid waste on the land and in the forests surrounding the Hartland landfill. Evidence from around the world demonstrates significant risks to people, ground water, farms, food and animals immediately and into the future.
Furthermore, on October 13, 2020, 130,000 litres of sewage sludge - containing raw sewage, bacteria, Covid-19 and many contaminants - destined to CRD’s new biosolids plant (RTF) leaked across Willis Point Road and into Mount Work Park and Durrance Lake Park, which now requires ongoing contamination monitoring for the coming years.
Learn More about why Class-A biosolid sewage waste is not as safe as the CRD and Minister of Environment claim:
Read: Five Reasons CRD Spreading Toxic Biosolids is a Bad Idea
Read: The Conflict Between Commerce and Human Health: CRD Residents Beware (what the scientific research tells us).
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