January 12, 2009
City of Pickering
One the Esplanade,
Pickering, ON, L1V 6K7
Mayor@cityofPickering.com
Re: York Region Plans to Send more Raw Sewage through Pickering to Lake Ontario
SE Collector Environmental Assessment (EA)
Dear Mayor Ryan and Pickering Council:
Below please find several concerns and recommendations regarding York Region’s plans to send
several hundred million litres/day of additional sewage to Pickering and Lake Ontario by
twinning (tunneling) the Southeast Collector sewer beneath Bob Hunter Memorial Park, Rouge
Park, the Greenbelt and Pickering.
1) Property De-valuation and Reduced Tax Assessment
Property values and tax assessments are harmed by facilities such as the YDSS and Duffins STP
which generate odours, air pollution and water pollution. York Region already sends most of its
raw sewage to Pickering and it wants to twin the SE Collector to significantly increase sewage
flows into Pickering. York Region is also planning to send its solid waste to Durham Region for
incineration. Is it any wonder that Pickering and Durham communities have lower property
values, lower tax assessments and lower business development rates than comparable
communities in Markham and York Region. Pickering and Durham will continue to suffer
through depressed property values and business opportunities, if they continue to act as York
Region’s waste receptacle.
2) Sewage Effluent Threatens Lake Ontario Water Quality – Public Health at Risk
Pickering and Ajax residents cannot fully enjoy their Lake Ontario waterfront because of E. Coli
bacterial pollution, nuisance algal blooms, closed beaches and foul odours from the Duffins STP
and sewage sludge incineration. In 2007, a Pickering Nuclear Reactor had to be shut-down
because algal growth had partially clogged the water intake pipe for a reactor cooling system.
Despite these existing pollution problems, York Region plans to grow from 950,000 to 1.5+
million people over the next 25 years by piping its raw sewage from East Gwillumbury,
Newmarket, Aurora, King City, Richmond Hill and Markham through Oak Ridges Moraine
drinking water aquifers, Bob Hunter Memorial Park, Rouge Park and the Golden Horseshoe
Greenbelt (DRAP) to Pickering and Lake Ontario.
Many people, including Ontario’s Environmental Commissioner and respected scientists question
whether Lake Ontario can assimilate the sewage from an over-grown GTA population without
adverse effects to human and ecosystem health and greatly increased sewage and water treatment
costs. Scientific studies have found disturbing levels of carcinogenic chemicals and human
hormones in Lake Ontario, the drinking water source for millions of Ontario residents.
1
Some studies have found ovary development in male fish in areas with high levels of chemicals
which mimic female hormones. Such biologically active chemicals can promote cancer and harm
reproduction and human health.
3) Sewage Sludge Incineration – Releasing Health-Damaging Air Pollution
The proposed YDSS twinning (SE Collector) will increase the incineration of sewage sludge and
the release of dangerous pollutants in Pickering. Sewage sludge incineration at the Duffins STP
releases Mercury, dioxins, furans and other health-damaging chemicals. These chemicals:
a)
b)
c)
- are neuro-toxic and /or cancer causing or promoting, even at very low levels;
- bio-magnify and bio-accumulate in plants, fish, birds, wildlife and people;
- are particularly harmful to pregnant women and children.
4) Effects of a Tunnel Collapse, Soil Settling or Pipe Break
YDSS sewer construction has already triggered a tunnel collapse beneath Langstaff Road, soil
settling along 16th Avenue and associated infra-structure damage. For the YDSS SE Collector,
York Region proposes to tunnel beneath high-tension, high-voltage, hydro lines beside Pickering
residential communities. If tunneling triggers soil settling under the hydro tower footings, high
voltage wires could fall on adjacent homes and properties, creating a risk of fire or electrocution.
The proposed SE Collector route in Pickering is near an active bedrock fault. If an earthquake
triggers movement, the “Big Pipe” could break and cause massive sewage spillage.
5) York Region’s Record of Failure to Reasonably Predict and Disclose Impacts
During the 9th Line, 16th Avenue and other YDSS sewer projects, York Region repeatedly and
grossly under-estimated (misrepresented) the environmental, social and economic impacts. A
TRCA letter to the Region (May 26, 2003), states: “lateral dewatering impacts are greater than
predicted by about a factor of 10” [up to 10 km groundwater [well] impact radius, not 1 km]
After a thorough audit of the 9th Line/16thAvenue YDSS sewer projects, Gary Hunter, a
respected groundwater expert, concludes:
“The Region’s Master Planning and Environmental Assessment and Route Investigation studies,
as clearly demonstrated by the adverse environmental outcome of the project, did not include
appropriate and responsible investigations and grossly under-predicted the adverse
groundwater conditions encountered.”
“The Region sent out a misleading Notice to Residents on February 3, 2003 that (groundwater)
interference would be limited to 2 to 3 km when the Region knew full well that complaints had
already been received from 19th Ave and Dicksons Hill (6 km to the north) to Steeles Ave (6 km
to the south) and the Region was mobilizing to replace a drawndown shallow well at Elgin Mills
(4 km away) for the Town of Markham.”
2
6) Lack of Legal Notification of Pickering Residents During YDSS Mater Plan Class EA
In 1997 and 2002, York Region completed and updated a Class Environmental Assessment (EA)
which selected twinning of the York Sewer System (YDSS) and discharge to the Duffins STP
and Lake Ontario as the preferred way to handle the increased sewage flows associated with York
Region’s explosive growth. This Class EA was described as involving a “cursory” assessment of
environmental and social impacts and it did not involve Ministry of the Environment approval.
Contrary to the requirement of the EA Act and established law, Pickering residents were not given
legal notice of, or a fair opportunity to participate in, the YDSS Class EA before the preferred
alternative (Big Pipe twinning) was chosen. Ontario’s Environment Minister tried to remedy
this fatal flaw by granting a bump-up of the SE Collector from a Class EA to a full individual
EA. However, the process had already been prejudiced and the rights of Pickering residents had
already been violated because York Region had already twinned the “Big Pipe” in Markham, the
section of the YDSS just northeast of Pickering. Ontario’s Environmental Commissioner,
environmental lawyers and engineers, and a former EA Board Vice Chair, have publicly stated
that York Region violated the EA Act by piece-mealing the YDSS into a number of cursory Class
EAs (pipe segments) and by failing to notify Pickering residents during the original Class EA.
7) YDSS SE Collector (Big Pipe) Alternatives
a) Within-Region Treatment
York Region should implement within-Region sewage treatment and water recycling. California
is building a $250 Million Advanced Water Purification Facility (AWPF) to yield 280 million
litres per day of drinking quality water from sewage using microfiltration, reverse osmosis,
ultraviolet light and an advanced oxidation treatment.
York Region could build such an AWP facility, store the treated water in man-made wetlands and
mined-out quarries and then use the purified water for irrigating golf courses, farms and regional
forests, and / or recharge of selected streams and aquifers during winter.
Two AWP facilities could treat all of York Region’s sewage for a $500 million capital
investment. This is less than the $600 million price tag for the proposed SE Collector and much
less than the 2 $Billion price tag for the overall YDSS twinning.
b) Fix Sewer Leaks
Fifty percent of York’s existing sewer capacity is consumed (wasted) by groundwater and surface
water leakage into sanitary sewers. This daily “wasting” of hundreds of millions of litres of
precious fresh water is equivalent to diverting the entire summer flows of the Rouge River and
Duffins Creek.
c) Improve Water-Use Efficiency
York Region’s per capita water use (280 L/day) is much higher than the average (176 L/day) for
developed countries. Sewage flows could be reduced by 36% by taking stronger steps to lower
water use to the average for developed countries.
3
Conclusion and Requested Motion / Actions by Pickering Council:
1)
Pickering Council should ask the Minister of the Environment to refuse EA approval for
the YDSS Southeast Collector (Big Pipe) or refer the EA to the Ontario
Environmental Review Tribunal for a public hearing.
2)
If the Minister and Pickering are inclined to approve the YDSS Southeast Collector (Big
Pipe) with conditions, then the Minister should be asked to require a number of
conditions, including:
a) within 5 years, York Region be required to upgrade the Duffins STP to remove
biologically active compounds, hormones, toxins and phosphorus by utilizing
technologies equivalent to, or better than, those proposed for California’s Advanced
Water Purification Facility and achieve or surpass provincial water quality objectives
(PWQOs) within the sewage plant effluent;
b) with ten years, York Region be required to build an Advanced Water Purification
Facility to handle at least 50% of its sewage within York Region and thereby reduce
odours, sewage sludge incineration and the release of effluent to Lake Ontario from the
Duffins STP;
c) within ten years, York Region be required to retrofit, repair and replace old sewer pipes
to fix leaks (e.g. slip-line old pipes, disconnect weeping tiles and downspouts from
sanitary sewers; etc) to remove at least 50% of the groundwater and surface water leakage
into the YDSS and avoid the wasting of this precious water which belongs in aquifers,
streams, wetlands, lakes and the hydrological cycle;
d) starting immediately, York Region be required to pay 1 cent ($0.01) towards the
funding of a Rouge, Petticoat, Duffins Land Trust for each 1000 litres of precious
groundwater and surface water which leaks into the YDSS and is exported and lost
(wasted) from local aquifers and watersheds; and
e) York Region be required to provide, immediately upon EA Approval, an environmental
enhancement fund of 10% of the YDSS SE Collector cost (60 million X 10% = $60
million) to establish (seed) the Rouge, Petticoat, Duffins Land Trust.
We trust you will adopt these recommendations to protect and improve water quality, air quality,
public health, Greenbelt lands and property values in Pickering.
Sincerely,
Jim Robb,
Rouge Duffins Greenspace Coalition
2259 Meadowvale Road, Scarborough, ON, M1X 1R2
Phone: 647-891-9550
Email: jim.robb@rogers.com
4