Comments on Discharge Permit Application #4419

Attn: Grant McGillivray
Liquid Waste Regulatory Program Lead Regulation & Enforcement Division
Metro Vancouver
4330 Kingsway,
Burnaby, BC, V5H 4G8

regulationenforcement@metrovancouver.org

Dear Mr. McGillivray,

Re: Comments on Fraser Surrey Docks’ Application for a Sanitary Sewer Waste Discharge Permit — Submitted November 19, 2013, Reference: 4419

We are writing in support of the points made in the correspondence you have received from EcoJustice on July 21, 2014.

We would also like to highlight three of the many concerns that have been raised about this application:

1. By dumping industrial waste products into the city sewer system, the proponent is asking for the city and for city taxpayers to subsidize their business. Given that industrial waste products include materials and toxins not found in typical domestic waste, best practices treatment for domestic waste are not assured to safely remove all harmful substances, and may increase disposal costs for sludge and other treatment byproducts.
   Thus, we submit, that by approving this application, the city would be providing a subsidy to a specific industry, and runs the risk that it may trigger significant and expensive upgrades in order to continue to meet environmental regulations.
   If this application is approved, we submit that the proponent should be required to pay fees equivalent to the costs if they were to build their own treatment facilities. Furthermore, that restrictions be placed on the discharge permit that if a prior agreed upon composition of discharged waste changes or is exceeded, the permit be withdrawn and financial penalties be applied.
2. The inclusion of chemical topper agents and other dust suppression compounds in the proposed waste stream is especially concerning. The compositions of these chemicals are often protected by non-disclosure agreements, and have limited or non-existent human health and aquatic health analysis.
   We suggest that language be included in any permit issued that require all substances discharged into the sanitary sewer be publicly disclosed, including all component chemicals, and that independent third-party testing be required, on a quarterly basis at a minimum. Furthermore, we submit that restrictions should be placed on the permit that if any non-reported materials are found, the permit be withdrawn and financial penalties be applied.
3. Finally, the legal position that FSD has taken, claiming that they are not subject to the jurisdiction and regulations of Metro Vancouver, is extremely concerning. Once a permit is issued, what prevents the proponent from making the same claim that they are not subject to any of the restrictions or terms of the permit?
   The applicant has clearly demonstrated that they are not an honourable partner that will respect your terms of service.

In conclusion, we do not support this application for a permit. We believe it is a misuse of city resources, represents an significant subsidy, and places the residents of Vancouver and the surrounding area, as well as the environment at risk.

We urge you to reject this application.

David & Laura Slik
Lasqueti Island
V0R 2J0, Canada