Why should voters be wary of the CVRD and the Sewer Commission’s proposals on sewerage infrastructure projects?
Because there’s a history of bad decisions. How do we know they were bad? In some cases, because citizens have sued the regional district over the effect of those decisions. In other cases, the CVRD has created a legacy of unnecessary ongoing costs for taxpayers.
Here’s some history.
1960s Sewage lagoon
In the mid-1960s, the City of Courtenay treated its sewage in a lagoon near the Courtenay Airpark. Design flaws miscalculated how high the Courtenay River might rise. Eventually, it rose over the lagoon and flooded raw sewage into the K’omoks estuary.
1980s current system
Two decades later, in the mid-1980s, the city of Courtenay and the Town of Comox, with the CVRD, constructed the present day system.
They had several options at the time about where to place the sewer pipe that would move effluent from the Courtenay pump station #1 to the treatment plant at the end of Brent Road, near Point Holmes. Along the way it would pick up sewage from the K’omocks First Nation and Comox.
One option placed the force-main sewer pipe on a completely overland route. Instead, the CVRD choose to run the pipe almost exclusively through our marine environment — because it cost less — even though many citizens and groups advised against it.
Almost immediately after the pipeline was constructed, the erosion of the Willemar Bluffs began to accelerate. Property owners on top of the bluff, fearful for their homes, filed a class action lawsuit. The regional district denied responsibility for the increased erosion and fought the residents for years.
But eventually the court ruled against the CVRD, saying its actions caused the added erosion. But the regional district refused to accept the ruling. The residents complained to the B.C. Ombudsman, who also ruled against the CVRD.
Caught by the B.C. judicial system and the provincial ombudsman, the CVRD was ordered to fix the problem. Their solution to halt the erosion: spend nearly $1 million to place rip-rap (large rocks) at the base of the bluffs.
After the rip-rap slowed the bluffs’ erosion, the sand along Goose Spit began to disappear, eroding that shoreline. This is not a coincidence or an unrelated event.
The sand cliffs within the Strait of Georgia — Quadra Island, Savory Island, Willemar Bluffs, the Komas Bluff on Denman — were created by the glacial retreat some 22,000 years ago. They are all one oceanological feature, the Quadra Sands Formation, commonly referred to as feeder cliffs. They are always eroding.
Protecting Goose Spit from erosion
The Goose Spit is a sandbar created by shoreline drift, the natural erosion of the Willemar Bluffs, and it extends to Denman Island via what’s known as the Comox Bar. Once the Willemar Bluffs stopped feeding sand to Goose Spit, it began to wash away.
So now, the CVRD had to spend about $500,000 more to dig in large driftwood logs along the windward side of Goose Spit to protect it from diminishing. In addition to the capital cost, Valley taxpayers pay tens of thousands of dollars annually — probably forever — to reinforce and maintain these protections of Goose Spit Park.
But after the construction of the sewer pipe and placement of rip-rap below the Willemar Bluffs, other beaches began to erode.
Homeowners to the north of the bluffs began to lose shoreline, too, and parts of their front yards in some cases. So residents installed rip-rap, at their own expense, to save their property.
And that moved the accelerated erosion action further up the shoreline. Parts of the popular tourist beach at Point Holmes started to wash away. Every year, large chunks of land disappear with the winter storms.
To fix that problem, the Town of Comox will spend another $1.6 million to add rip-rap from where the homeowners stopped to the Point Holmes boat launch.
There’s a pattern to all this, and it looks like one continuous chain reaction from the initial routing of a sewer pipe along the Willemar Bluffs. A routing people advised was wrong, but a warning the CVRD ignored.
The result has already cost Valley taxpayers millions of dollars, and thousands in ongoing annual maintenance expense.
But, wait, there’s more.
Based on experience, it’s probable the Point Holmes rip-rap project will shift erosion further up the beach, and may even accelerate the erosion of the bluffs at the end of the CFB Comox runway, which stand near the sewer outfall into the Strait of Georgia.
It’s also possible that increased winter storms will eventually threaten the sewer pipe buried beneath the Point Holmes beach from the treatment plant to the outfall, and that this pipe will also have to be abandoned.
2011 Sewerage Master Plan
An engineering firm in a early 2000s report recommended the CVRD abandon the pipe on the beach below the Willemar Bluffs. The report said the pipe had been exposed and was vulnerable to winter storms.
This is the same pipe that should have been placed overland, the pipe that caused accelerated erosion of the bluffs and the diminishing of Goose Spit. Still, the CVRD did not act until it adopted a Sewerage Master Plan in 2011.
Unfortunately, that plan only addresses the Willemar Bluffs section of sewer pipe. It doesn’t address pipe on the beach along Point Holmes to the outfall, which is equally vulnerable to winter storms. It does not address the pipe along Comox Bay or in the K’omoks estuary. It doesn’t deal with shoreline erosion and the loss of private property, and the continuing costs of fixing the next problem created by resolving the last one.
The plan has led to the South Sewer System referendum on June 18 that will add miles of new sewer pipe into Baynes Sound and the estuary. A proposal that the Project Watershed Estuary Working Group opposes.
Nor is the CVRD sewage commission following its plan. They have not engaged a coastal engineering specialist to determine the remaining life of the Willemar Bluffs pipe. It did not update its plan in 2014. It has not started an initiative to incorporate resource recovery — reclaimed water, energy reuse — into the master plan. It has not created a governance structure for areas outside of the existing mandate for the City of Courtenay and Town of Comox.
Old technology at the treatment plant
The CVRD also failed to equip the Brent Road treatment plant with the necessary technology to reduce odors to the degree required in a residential neighborhood. Angry nearby homeowners sued the CVRD and won.
As a result of the lawsuit, trucks now haul sewage solids multiple times every day from the Point Holmes area to Cumberland for composting. It could and should have been an odorless, carbon neutral operation.
The CVRD sewer commission proposes to spend millions of dollars more on projects that will lock the sewerage system into existing and new infrastructure in our estuary and other marine environments for years to come.
And taxpayers will bear the burden again when changing weather patterns inevitably force the CVRD to do what it’s refusing to do today: Go to an all overland route, as proposed by Project Watershed.
Your enjoyment of our waterfront
One of the joys of living in the Comox Valley often touted in tourism promotions is the pleasure of swimming off beaches around Baynes Sound, including Comox Bay, off the end of Goose Spit, or from the beach at Point Holmes.
Besides swimmers, people paddle kayaks and SUP boards. Youngsters often take unexpected dips into the bay while learning to sail, or tubing behind a boat.
But imagine how even a small leak of raw sewage from the kilometers of pipe that run along our estuary and pristine shorelines could spoil that fun, and foul the Valley’s reputation. Putting raw sewage pipes in our waterfront creates the risk that some people could get ill from unacceptable levels of bacteria, such as e. Coli.
Maybe that risk is small, but it exists. And it’s unnecessary because the Comox Valley Regional District could move most of its sewer pipes inland, and out of our waterfront.
The Dyke Road
This main arterial route connecting Courtenay, the K’omoks First Nation and Comox was named accurately. The road is a dyke. It separates low-lying land, the former Farquharson Farms, from a river and a tidal estuary.
Winter storms make dykes susceptible to breaching. Just watch and read the news, because it happens almost every day in the southeastern U.S.
It could happen here. Imagine a 5.4 metre high tide. Add 1.1 metre for a storm surge (reasonable, based on data from the Campbell River monitoring station), 0.4 metre for sea level rise (conservative) and 0.2 metre for an extreme wind factor. That adds up to 7.1 metres, or just over 23 feet of water.
Just a few feet of water combined with a strong storm floods the Dyke Road. Twenty-three feet would cause an emergency.
Besides property damage, and threats to human and animal life, such a storm could unleash a tragic flow of raw sewage into the estuary, and then it would spread down Baynes Sound and throughout Comox Bay.
Roads have been breached
A winter storm earlier this year flooded the roads at Goose Spit, Point Holmes and on the Dyke. Rising waters and wind flung logs onto the roads, prohibiting safe passage in places until highway crews could clean them.
The sewage commission has so far ignored the predicted effects of climate change in its Sewer Master Plan and the impact that more intense and severe winter storms will have on our shorelines. Shouldn’t we consider these inevitable changes before we spend millions of dollars to put more critical assets at risk?
Neighboring cities, such as Campbell River, are already making plans to remove sewer infrastructure from their foreshore based on this emerging data.
We will have another earthquake
In 1946, a 7.3 magnitude earthquake rocked the Comox Valley. Portions of the Dyke Road were completely destroyed, and made impassable.
When the next quake occurs here, it’s almost certain that the main sewer line that runs along Dyke Road, through the estuary and into Comox Bay will be twisted enough to break, crack and spring a leak. Raw sewage will foul our waters right down into Baynes Sound.
Sewer pipes placed inland could also break, but we could more easily contain the leaked effluent on land, and that would minimize the environmental damage.
Engineers can design safe systems, but that doesn’t preclude the unexpected from occurring.
The Courtenay #1 pump station has an electric alarm system to alert city staff when trouble occurs; when the pumps stop working, for example.
But that didn’t help recently, when rats chewed through the wires and disabled the alarm system, according to the operator of a septic pumping service. The rats also chewed wires that shut down the pumps. Before it was discovered, sewage had backed up in the pipelines.
That incident ended without serious consequences. But it’s proof that every system or piece of infrastructure can malfunction. Doesn’t it make more sense to place sewer pipes inland, and reduce the potential for damage?
In its current rush to patch its sewerage system, the Comox Valley Regional District has stumbled toward yet another unwise decision that could negatively impact our community’s coastlines.
It’s not well known, but a 55-year-old sewer pipe runs beneath Comox Bay, to move sewage from HCMS Quadra to the Comox pump station, located at Jane Place. The pipe is actually the old Comox outfall, which was repurposed for HCMS Quadra in the mid-1980s when the new treatment plant and outfall were constructed at Point Holmes.
There’s a risk this pipe could leak effluent into the bay.
To mitigate that danger, CVRD engineers proposed a new pipe across a shorter stretch of the bay where it would connect with a new large pump station in the Croteau Beach area. But the Department of Fisheries and Oceans said, not so fast.
Before the DFO would approve a new pipe, they asked the CVRD to conduct comprehensive environmental studies to determine the impact of construction on fish habitat and coastal vegetation, such as eel grass.
Rather than take the time to do these studies, the CVRD and the Department of National Defence have chosen to repeat the regional district’s 1980s mistake of placing sewer pipes along the foreshore of our recovering estuary. They plan to build a new pipeline — paid for by the DND — and bury it on the estuary’s foreshore, along Goose Spit road.
This is a mistake for several reasons.
First, pipelines are not 100 percent infallible. Even new pipelines can leak. Putting critical infrastructure on or near the marine foreshore creates the potential for pollution to foul coastlines, or an estuary.
The K’omoks estuary has just begun recovering from acid rock drainage that scorched the once bountiful Tsolum River into a dead river, barren of aquatic life. The Mt. Washington Copper Mining Co. only operated for a couple of years in the mid-1960s, but it left decades of toxins and heavy metals leaching into the Tsolum River’s tributaries, down the river and eventually polluting the K’omoks estuary.
Thanks to the Tsolum River Restoration Society and the the K’omoks First Nation, the river and the estuary have started to recover. The K’omoks have worked hard to establish a successful shellfish harvesting enterprise, partly in Comox Bay, shipping more than 2 million oysters annually worldwide.
The plan to put a new sewer pipe in Comox Bay poses a threat to the K’omoks shellfish harvesting.
Second, pipeline construction in the foreshore in several sections will disrupt coastal vegetation and possibly also fish habitat. But the CVRD doesn’t know for sure, because it has not done any environmental studies of the new sewer pipe route.
Third, the CVRD has not taken into account the impacts on Goose Spit from climate change, sea level rise and the increasing frequency and intensity of winter storms. Sea levels could rise so swiftly within the next 20-30 years that Goose Spit road might become treacherous to navigate, or even impassable.
A recent climate change study led by a retired NASA climate scientist focused on a period about 120,000 years ago when the Earth last warmed naturally, to average temperatures estimated at only slightly higher than today. During that period, sea levels rose by up to 30 feet. The study, published recently in the European journal, Atmospheric Chemistry and Physics, predicts today’s warming will occur more rapidly, within decades.
But a sea level rise of just a few feet, combined with more frequent and severe winter storms, will have a devastating impact on Goose Spit. Higher sea levels could wash the road out completely.
This past winter, several storms sent waves crashing across the Spit road, washing up large logs and a sea lion, and weakening the Spit’s protections. The damage required repairs.
Before building new infrastructure in a marine environment, the DND and CFB Comox must consider the future of HCMS Quarda in light of how the effects of climate change might reshape the Goose Spit shoreline.
The Comox Valley Regional District should also think about these long-term possibilities.
At the April sewage commission meeting, Courtenay councilor Erik Erikksson asked why the DND couldn’t build a self-contained, small treatment plant at HMCS Quarda, eliminating the need for a new pipe. CVRD senior Engineer Marc Rutten responded, “We haven’t investigated” that option, and that he had “no good answer.”
It’s unacceptable that the CVRD hasn’t taken the time to examine every possible option. How can elected officials make good decisions when all the information isn’t on the table?
A decade ago, the CVRD recognized that its sewer pipe on the beach below Willemar Bluffs was vulnerable to winter storms. But it has yet to follow through on its own Sewer Master Plan recommendation to engage a coastal engineer to determine the remaining safe life of the pipeline. Yet, it’s now in an inexplicable hurry to make multi-million dollar changes to its sewerage system, without complete due diligence or exploration of all options.
This tunnel vision has resulted in planning inconsistencies. For example, the CVRD has focussed on the Willemar Bluff section of pipe, but has not yet discussed an equally vulnerable section of sewer pipe from the treatment plant, along the popular Point Homes beach enroute to the outfall into the Strait of Georgia.
At its May sewer commission meeting, the CVRD offered no explanation why replacing the Willemar Bluff section was any more urgent than replacing the Point Holmes section.
Voters and taxpayers in the Comox Valley should call on the CVRD to step back, take a breath and make room for a more environmentally secure plan to evolve, one based on new and emerging scientific data.
Other communities have built leading-edge wastewater management systems that recover and reuse resources, such as reclaimed water and energy to heat and operate treatment plants. Some cities, such as Campbell River, have taken serious notice of how climate change will reshape shorelines and made the wise decision to remove critical infrastructure from the foreshore.
The Comox Valley deserves that kind of thoughtful, calm leadership.
The story of a Vancouver Island municipal infrastructure project, delayed for over a decade, appears headed for a happy ending.
In the 1990s, the City of Campbell River planned to upgrade and replace a key sewer force-main pipe that serves the southern portion of the city. The 6-plus kilometer pipe originally served a much smaller population, so it required upsizing. Also, given its age — about 50 years old — the pipe had begun to fail, causing leaks.
City officials considered starting with a 1.5 kilometer stretch where the pipe sits on the beach and is vulnerable to winter storms. But there were challenges in arriving at a final concept, and funding issues. So they started with the more southern sections, which could also be incorporated into a highway renewal project through Willow Point.
Engineering studies proposed a variety of options for the section on the beach, including twinning the pipe and covering it with concrete to protect it from erosion. The city council of the day liked this idea, especially because it included the potential for a pedestrian walkway on top of the encasement.
Thank goodness the city didn’t dismiss the residents’ concerns and push the project ahead anyway.
But when the concept was presented to the community, it didn’t sit well with nearby residents. The city council listened to the residents’ concerns, and focussed resources on replacing the other sections of the pipeline.
Around 2008, a harsh winter storm washed out sections of the Old Island Highway near Oyster Bay. This caused city staff to notice an increase in the wear and tear on the sea walk and to begin to understand the potential effects of sea level rise, climate change and the impact to the foreshore.
When the city planners turned their attention back to that 1.5 kilometers of sewer pipe, the city’s only sewer force-main pipe located on a foreshore, they realized the original plan had not taken into account the potential impacts of sea level rise and the increasing severity of winter storms.
The world was a different place in the late 1990s. Climate change hadn’t entered the discussion about municipal infrastructure. Fortunately, design standards are continually being updated to address changing conditions.
City staff studied the expected impacts of sea level rise and determined that the marine foreshore environment is likely to undergo significant changes in the next 100 years. As a result of these anticipated changes, staff now recommends that proper consideration be given to the placement of any critical infrastructure within the marine foreshore environment.
Campbell River staff have also determined that it’s a comparable cost to place the force-main within the highway structure and out of the marine foreshore. Moving the pipe overland will also likely result in reduced operating costs as the anticipated changes to the marine foreshore occur in the coming years.
Staff are now working on a report that summarizes these new developments and a plan to move the sewer pipe out of the foreshore. They will present it to City Council in the near future.
So, some people with a self-interest triggered a fortuitous delay of what to some seemed like a good idea in the 1990s, but which would have actually been a serious mistake.
Thank goodness the city didn’t dismiss the residents’ concerns and push the project ahead anyway.
Thanks in part to neighbors who opposed the project, and thanks to a city council that took the residents’ concerns seriously, the delay provided time for a better plan to emerge, one based on new and emerging scientific data.
Comox resident George Le Masurier has responded to a post on the Comox Valley Regional District website. The CVRD post attempts to discredit Le Masurier’s recent op-ed article in the Times-Colonist.
The CVRD has posted on their website a response to my op-ed article in the Victoria Times-Colonist. Unfortunately, parts of their letter are false because they claim I said things that I did not say.
First, the CVRD suggests in their second paragraph that I stated the pipeline “is failing as stated by Mr. Le Masurier.” It’s a false statement.
I did not use the word “failing.” I said it is deteriorating, and that’s a huge difference.
Of course the pipeline is deteriorating. It’s 35 years old and had an expected life of 50 years when first installed. It has to have deteriorated, but to what degree I did not say. (Nor do I believe the CVRD knows.)
Also, the CVRD plans to replace not only the Willemar Bluffs section, but the remaining section of the pipeline by 2029, and have it in their capital plan to do so. Why would they replace the remaining section if it is as good as new? It’s axiomatic that anything in less than new condition has deteriorated.
It’s a fallacious straw man argument.
Second, in their third paragraph, they said “contrary to the statement made by Mr. Le Masurier, the CVRD completed a Sewer Master Plan for the entire Comox Valley.” Again, putting words into my mouth.
I did not say the CVRD lacked an SMP for the entire Comox Valley. I actually said the CVRD was applying a band-aid approach “instead of creating a NEW sewerage master plan for the entire Comox Valley.”
Again, this is a huge difference. I acknowledge the CVRD has an SMP, and my words indicate so. How could they create a NEW plan if they didn’t have an old one? It’s simple logic.
Another fallacious straw man argument.
Third, in their sixth paragraph, the CVRD says, “Mr. Le Masurier suggests that there has been independent analysis completed to show long-term costs savings by upgrading the Courtenay and Jane Place pump stations. The CVRD did not complete this analysis ….”
This is objectionable and misleading for two reasons. One, it implies there may or may not be an independent analysis, calling the veracity of its existence into question; and, two, it tries to imply that I suggested the CVRD “completed” or solicited this analysis and they deny having done so. Again, I did not say the CVRD had anything to do with the analysis.
A project controller who does cost analysis for a major diamond mine north of Yellowknife — and lives in Comox — prepared a detailed analysis of the potential cost savings if the CVRD upgraded the Courtenay pump station and replaced all the pipe immediately. He presented it to the CVRD sewage commission in person. But a Comox director voted against their staff looking at the analysis because it would complicate things.
And that leads me to a final point. It’s true the CVRD formed an Advisory Committee, but only after (and probably because) the neighborhood protested the Beech Street site. I should have edited out the word “eventually.”
However, the bigger issue here is that the CVRD ignored the committee’s recommendations.
The committee considered five alternate sites. The committee gave its #1 recommendation to upgrading the Courtenay pump station and replacing all the pipe now. It rated Beech Street last. It did so, as the CVRD says in its post, because they found the top recommendation too expensive.
But the truth is, the CVRD doesn’t know for sure because they have not done a comprehensive financial analysis, or an environmental analysis, of this option, to my knowledge. Nor have they bothered to consider the independent analysis prepared for them (see my third point, above.)
(It’s important to note that the committee included an elected official from Courtenay, Comox and the CVRD, and one staff person from each jurisdiction, and three citizens. The citizens were outnumbered 2-to-1, and the committee still rated the Courtenay upgrade as #1.)
I don’t mind a good argument, and the CVRD is entitled to defend its position. But I do mind when someone falsely puts words into my mouth in order to spin the facts in their favor.
By George Le Masurier —
While the Capital Regional District slowly moves toward consensus on where to locate one or more sewage treatment plants, another wastewater infrastructure battle is just beginning further up Vancouver Island.
In the Comox Valley, strong disagreements have arisen over how to replace a deteriorating 35-year-old sewer pipeline that was unfortunately constructed through the foreshore of the Courtenay River estuary, under a regional park and along the foot of the iconic Willemar Bluffs.
Neither controversy should surprise anyone: siting a public facility within a developed urban area presents unique technical and political difficulties that can only be overcome by extraordinarily skillful political leaders solely focused on the greater good.
But in the Valley, a questionable siting process has led to a short-sighted plan that harms both taxpayers and the environment.
It’s remarkable that provincial agencies allowed the City of Courtenay and the Town of Comox to build a pipeline that carries raw sewage along the foreshore of several environmentally sensitive areas enroute to a treatment plant. Concerns about climate change and sea level rise were only beginning then, but someone should have seen the potential for an environmental disaster.
A 2005 engineering report recommended abandoning the section of the pipeline that runs along the base of the Willemar Bluffs, where it is vulnerable to winter storms. But the rest of the pipeline also needs to be replaced. In a few years, the main pump station in Courtenay will be inadequate to handle the volume created by one of the province’s fastest growing regions.
Instead of creating a new sewerage master plan for the entire Comox Valley, the CVRD is poised to apply a band-aid for Courtenay and Comox. It proposes to replace only the last half of the sewer pipeline with an overland route. But instead of upgrading the existing secondary pump station in Comox, the CVRD proposed a new pump station on Beech Street, a dense neighborhood outside the Town of Comox boundaries. This may violate the CVRD’s own bylaws.
After protests from the Beech neighborhood, the CVRD abandoned the site. But it foolishly choose another site on an intact K’omoks midden within one of the few remaining salt marshes in an Environmentally Sensitive Area Development Permit Zone, which would have also blocked a popular beach access.
It’s astonishing that the CVRD didn’t step back from these blunders and re-examine its process. They did
eventually form an Advisory Committee, but it ignored the committee’s recommendations and has returned to its original Beech Street location, which the committee ranked as the worst option.
It’s unfair to site this facility in the Beech neighborhood because it has no representation on the sewage commission. Courtenay cast its three votes to oppose the Beech Street site, but a CFB Comox vote helped the three Comox representatives win a 4-3 decision.
This is unfortunate. It’s undemocratic, and dismisses public sentiment. It sets up a political and legal battle. And it creates unnecessary conflict despite having a ready solution that would receive wide public support — and which could potentially qualify the project for federal infrastructure funding.
The CVRD’s Advisory Committee gave its top recommendation to rebuilding the existing pump station in Courtenay. An independent analysis shows the CVRD could save between $7 million and $12 million in the long term if it upgraded the pumps at Courtenay and replaced the entire pipeline now. This would eliminate the need for a second pump station and eliminate the exposed section under the Willemar Bluffs.
But the remaining old pipe has to be replaced eventually, so it would be even better to reroute all of the pipeline overland. This would prevent an environmental catastrophe because a burst pipe today could pour raw sewage into the estuary.
A more ambitious plan would also prevent other battles. It’s unlikely that Environment Canada, Fisheries and the K’omoks First Nation will ever allow the CVRD to replace the pipe that runs through the estuary. The CVRD has no such agreement with agencies or the K’omoks First Nation, who recently won an award for the protection and restoration of the estuary.
It’s curious why the CVRD has not considered this win-win option. It saves long-term money. It avoids serious conflict now. It heads off future lawsuits. And it would surely score political points for the regional directors who finally correct a 35-year-old mistake.
This article was originally published in the Victoria Times-Colonist.