Monday, March 04, 2019 - 2:30 PM

Understanding the Secondary Wastewater Issue

In 2014, the federal government introduced new wastewater regulations under the Federal Fisheries Act. The regulations are designed to reduce harmful solids and chemicals in effluent from wastewater treatment facilities. At that time, the City was deemed to be high risk.

This risk rating has to do with a measure of Total Suspended Solids (TSS) and Chemical Biological Oxygen Demand (CBOD) in our effluent at the final discharge point. In basic terms, the Department of Environment and Climate Change placed Riverhead in a high‐risk category based on the review of testing results from Riverhead prior to June 30, 2014. Testing, at that time, indicated that the final discharge point was allocated 70 or more points: the higher the score the sooner the municipality must develop secondary treatment for its wastewater.

So, in 2014, the City was issued a transitional authorization giving us permission to continue with only our primary treatment – the City’s primary treatment from Riverhead – until December 31, 2020. In less than two years, that transitional authority will expire and the federal government legislates that we must be offering secondary treatment by then or face significant fines and penalties.

So, why not go ahead and create a secondary treatment facility?
1. Cost
2. We do not feel it is fair for the City to still be considered in the high risk category, given improvements in operation at our primary treatment plant.

We cannot afford to build this facility at this time
A secondary treatment facility, with an initial regional capital investment of $84.9M, will have significant financial implications for the City of St. John’s and its’ regional partners – the City of Mount Pearl and the Town of Paradise. The City of St. John’s alone will see its operating budget increase by an estimated $10.3M dollars once debt service and operating costs are factored in.

Projecting out to 2026, we already anticipate increases in water taxes; due to things such as general inflation; adding the cost to operate a secondary treatment facility will drive costs to rise by an additional increase of $105 per household. Commercial property owners will not escape the increase either and will see an increase in water usage rates as well – in the realm of 20%.

Unquestionably, secondary treatment will place a significant burden on the taxpayers of the region directly in the midst of uncertain economic times.

We do not need to build this facility at this time
At the time when the testing was carried out Riverhead Wastewater Treatment Facility was relatively new, having only been operational since September of 2009. Initially, Riverhead experienced significant operational issues with the digesters. We discovered that they had been installed incorrectly, and over the course of the first few years, the two digesters were frequently operating at a reduced capacity – in fact, at times only one was operational. This had a direct negative impact on the City’s allocated points by increasing the Total Suspended Solids (TSS) and Chemical Biological Oxygen Demand (CBOD) in our effluent at the final discharge point.

Issues were corrected by 2015, and we saw a continual decrease in our numbers from that time until now. In fact, over the last 12 months, testing demonstrates that the final discharge point allocation overall is below 70 points.

We believe we no longer are in a high-risk category and that results from the testing period four years ago are not reflecting our current operations. Based on today’s readings, we should not have to consider secondary treatment until 2030.

The regulations set out an administrative process that does not appear to provide for any meaningful review, reconsideration, or appeal and considering the serious impact these Regulations have on environmental protection and financial stability, municipalities should be provided a fair process to review decisions.

The Mayor wrote to the Ministers of Environment and Climate, Infrastructure and Communities and Intergovernmental Affairs to ask for consideration; the Act provides the Minister with power to request further testing and to set procedures to be followed, notwithstanding the Regulations. Here is a copy of that letter.