The White Rock Safe Water Alliance has sent a letter to Federal and Provincial government officials setting out reasons why it believes that the decision to give $11.8 million in Public funds that the governments of British Columbia and Canada have awarded to the City of White Rock to build as yet undetermined and undersigned Arsenic and Manganese Treatment Plants ought to be further reviewed and reconsidered.
From: Andrew Schulz
Sent: April 18, 2017 11:38 AM
Cc: firstname.lastname@example.org; John.Aldag@parl.gc.ca
Subject: Letter Requesting a Review of the CWWF Grant Monies Given to White Rock for Arsenic and Manganese Treatment PlantsThe Honourable Diane Watts
M.P. for South Surrey – White RockHouse of Commons, OttawaApril 18, 2017Dear Diane Watts.
I am writing on behalf of the White Rock Safe Water Alliance to follow up my recent conversations with your constituency office suggesting that it would be prudent to take a closer look and have a further review of the $7,102,500 grant that the Federal Government is giving the City of White Rock under the Clean Water and Wastewater Fund (CWWF). Details of that Program can be accessed at this web link: http://www.infrastructure.gc.ca/plan/cwwf/cwwf-program-programme-eng.htmlUnder the CWWF, the Federal Government and the BC Provincial Government are partnering to provide up to $373.6 million of Public funds to support water infrastructure projects in communities across British Columbia. The Canada – British Columbia Clean Water and Wastewater Program Guide can be found at this web link:http://www2.gov.bc.ca/assets/gov/british-columbians-our-governments/local-governments/environmental-infrastructure/cwwf_program_guide.pdfThe City of White Rock has been awarded a total of $11,790,150 in CCWF monies ($4,687,650 from the Province and $7,102,500 from Canada) for its “Arsenic and Manganese Water Treatment Project“. I believe that this grant should be reviewed for the following reasons:1. Concerns that this Project is Inconsistent with “Value for Money” Principles of the CWWF ProgramThe principle of “good value for money” is a basic tenet of the CWWF Program. The latest total estimated cost of this project is $14,205,000. This $14.2 M total represents the current estimated capital cost to build Arsenic and Manganese Treatment Plants. No such metal water treatment plants would be required if White Rock opted instead to join the Greater Vancouver Regional Water District and source its water supply from Metro Vancouver.Although White Rock is a member municipality of Metro Vancouver and its 1.98 square mile total area enclave sits on the doorstep of world-class clean and safe drinking water which is provided by Metro Vancouver to 2.5 million other residents in the Lower Mainland, the City of White Rock has instead decided to strike off on its own and enter the water utility business.White Rock’s water utility business model relies on old, antiquated wells that source groundwater from the Sunnyside Aquifer. Use of Federal and Provincial funds to subsidize the desire of a municipality to enter the water utility business when there is no compelling need to do so, but in fact, sounder and better alternatives exist, is not “value for money”. Between EPCOR and the City of White Rock, over $12,000,000 has already been recently spent on Chlorination Plants and storage facilities, the bulk of which would not have been necessary if White Rock had turned to Metro Vancouver for its water rather than independently chose enter the water utility business. It should be noted that the City of White Rock’s decision to continue sourcing its water supply from existing wells was apparently made at a Closed City Council Meeting in June of 2013, but that decision never sought Public engagement or Public approval.I fear that even after the building of $14.2 M worth of Arsenic and Manganese Treatment plants at Public expense, even if these proposed treatment plants produce adequate water quality to meet the Canadian Drinking Water Guidelines, the insufficient capacity of White Rock’s ground water system will very soon require that White Rock join Metro Vancouver for water supply anyhow. This will mean that all of the millions of dollars of Public monies put into the water utility just so that White Rock could independently operate its own separate water utility were unwisely wasted. This would simply be a case of throwing more good money after bad.2. Concerns that this Project Does Not Meet the CWWF Program RequirementsThe CWWF Program is clear that one of the expected outcomes is that “Municipalities have plans and designs aimed at meeting applicable water quality guidelines and wastewater regulations.” At this point, White Rock does not appear to have any firm plans and designs, let alone a well defined project. The City of White Rock has made it quite clear that despite the awarding of the grants, the City does not at this point in time know what they are going to do to try solve the water quality problems, nor have specific targets or standards been set. Although a number of Ph.D consultants have been engaged and the water utility continues to act as a “field laboratory” for academics, no design, no plan and no expected outcomes of the completed project have been established.At the City’s December 7, 2016 “Water Quality Open House” the City’s expert consultants were cautioning the Citizens in attendance that the problem of multiple streams of water with highly varying levels of contaminants would be very, very challenging to treat. So challenging that at that point even after the City’s CWWF grant application had been submitted, the experts were unclear and uncertain whether the contaminant reduction would achieve negligible risk or simply better than current levels. The grant application should contain at least some statement of the treatment goal which needs to be publicly disclosed so that all levels of government can know that the funds are being spent to achieve that goal, not some other less desirable end point.To further illustrate this point, on January 4, 2017 in the Peace Arch News, the City very publicly “unequivocally” denied that “a ‘doubling-up’ of arsenic and manganese treatment facilities at Oxford …is being contemplated“. Even though by this date in 2017, the City had already submitted its CWWF grant application, the City declared: “We are still in the early stages of evaluation of further treatment and no revisions have been made”. These quotes can be found here:Furthermore, on March 21, 2017, even after the City had been awarded its $11.8 M of CWWF grant monies, the Peace Arch News reported, “The research group has yet to announce the best treatment option for the city. The city hasn’t decided if it’s more appropriate to build two treatment centres, or just one, and have the water pumped to the secondary reservoir.” This quote can be found here: http://www.peacearchnews.com/news/416751843.html.If by March 21, 2017, four days after the Public ceremony announcing that White Rock would be getting $11.8 M of taxpayer monies the City still had not yet made a decision as to what it was going to try to do to try to tackle its water quality problem, how could $11.8 M in Public funds be properly granted to White Rock? How could this action possibly be consistent with the Program requirements of the CWWF? It appears that there have been no controls or conditions set and no accountability put into place for the City of White Rock before this grant was given and as such, this is inconsistent with the requirements of the CWWF Program.The CWWF Program also requires that an Environmental Assessment Process be detailed and undertaken and it appears that any such Environmental Assessment is absent from the City’s grant application. One would expect that at minimum, the removal of arsenic-laden material from water utility well sites and its handling and transport through the Community to its ultimate disposal site would necessitate a thorough and detailed environmental assessment.The City’s CWWF grant application is itself an interesting but concerning topic. Back in November of 2016, a member of the Public submitted a FOI Request for a copy of the City’s grant application in accordance with the Freedom of Information and Privacy Act (FIPPA). The fact that FIPPA legislation applies to a CWWF grant application was made very clear by senior government in its Program outline.But strangely, in response to the FOI Request, the City of White Rock wrote the applicant:
“Unfortunately, we are unable to provide access to this record at this time. We are withholding the requested grant application pursuant to section 17 of the Act. Section 17 allows a public body to withhold information that could reasonably be expected to harm its economic or financial interests if disclosed. We believe that disclosure of the requested grant application would allow for interference with the application process. Such interference could frustrate or impede the City’s application
You are welcome to submit another request for this record once a determination with respect to the awarding of the grant has been made. Concerns about the City’s economic or financial interests will likely have been alleviated by then. It is not clear when such a determination is expected.”And even though the $11.8 M grant to White Rock was announced at a Public ceremony in White Rock on March 17, 2017, despite follow-up from they FOI Applicant, the City still refuses to disclose its CWWF grant application. Naturally, negative inferences can only be drawn by such behaviour. In the continued absence of full disclosure and Public transparency, one can only speculate whether or not the details that the City of White Rock supplied the senior governments in its application for Public funds are indeed correct , accurate and sufficiently comprehensive.Attached, please find a scanned copy of the November 7, 2016 Staff Report seeking Council’s approval to submit a CWWF grant application for the “Arsenic and Manganese Water Treatment Project”. Although a copy of the City’s actual grant application continues to be withheld from the Public, it appears that the grant application may have contained incorrect and misleading information.Please note the Recommendations on the first page of the Report. At Recommendation 4, Staff writes that: “… the Arsenic and Manganese Water Treatment Project could not proceed without program funding“. At Recommendation 5, Staff writes that: “… the full scope of the Arsenic and Manganese Water Treatment Project would not otherwise have been undertaken without program funding in fiscal years 2017-2018“.Neither of these two statements are factually correct.Please refer to the scanned copy of the attached February 15, 2016 Staff Report on the “2016-2019 Draft Financial Plan – Water Utility.” Council did later approve this DRAFT and it is abundantly clear that the City of White Rock had planned to proceed with the “Arsenic and Manganese Water Treatment Project” more than a year before it was awarded grants through the CWWF. Also, it is clear that $1.2M was earmarked to commence undertaking the project in 2016 with a further $5.53 M in 2017 followed up by $6.25M in 2018. Later estimates in 2016 bumped the total project estimate to its current $14.2M total.Note that Staff writes: “A major difference is the addition of a $13 million Arsenic/Manganese Treatment project, with design budgeted in 2016, Phase 1 Construction (Merklin) in 2017 and Phase 2 Construction (Oxford) in 2018.“
The facts contained in these two City of White Rock Reports are markedly different but what is important to remember is that under the CWWF Program, one of the requirements as listed in Section 5.4 of the Canada- British Columbia Clean Water and Wastewater Program Guide is that an eligible CWWF project must be one that:
“... requires the federal and provincial governments’ financial support to enable the proposed project to be implemented, its scope enhanced (increase in size – expressed in the form of a percentage) or its timing accelerated (by number of years); ”
The record shows that White Rock’s Arsenic and Manganese Water Treatment Project does NOT require the federal and provincial governments’ financial support. In fact, the City was planning to borrow money over a 30 year term to do this work as early as February of 2016. As such, the requirements of the CWWF for White Rock’s project have NOT been met.
3. Concerns that this Project Does Not Meet the Long Term Sustainability Requirements of the CWWF Program
Among the criteria for a project to meet the requirements of the CWWF Program is the need to embrace and support “sustainability principles“, including:
- consistency with integrated long-term planning and management
- advancing the sponsoring local government’s development and financial plans
- supporting sustainable long-term economic growth
- exhibiting long-term sustainability, including operational viability, asset management (maintenance), and environmental sensitivity
- contributing to environmental, economic, community and innovation objectives
- being the best available economically feasible technologyTo know whether an infrastructure project is truly sustainable, all of the relevant facts need to be gathered, reviewed and carefully considered. One of the critical facts that the City of White Rock has avoided is the annual operation and maintenance costs of an Arsenic and Manganese Treatment Plant. If these costs are prohibitive, then long term viability is put to question and sustainability is compromised.
Although in its various water utility business cases and reports, the City of White Rocks failed to include any estimate of the cost of operating Arsenic and Manganese Treatment Plants, presumably because such costs were not readily available, White Rock need only have asked its next door neighbour, the City of Surrey, to get a an idea as to how much it costs to operate and maintain such a facility.
Nearly 11 years ago, on May 29, 2006, Surrey City Staff presented a Report on this exact same topic to Surrey City Council. A copy of that Report is attached and it will be noted on page 3, that back in 2006, it was estimated that it would cost $510,000 annually to operate and maintain a single Arsenic and Manganese Water Treatment Plant in South Surrey. Such a plant would tap into the same Sunnyside Aquifer relied upon by White Rock.
Note too how in 2006, the capital cost of such a treatment plant was only estimated at $4,000,000 not the $7,000,000 now estimated by White Rock for a single treatment plant. So if White Rock proceeds with its twin Arsenic and Manganese Treatment Plants, the White Rock water-using Public can expect to pay about $1,2000,000 annually in 2006 dollars just to operate and maintain the two treatment plants. These costs have never been presented to the Community by the City and should have been scrupulously weighed into the financial equation when the City of White Rock embarked on its course to rely on wells and groundwater for its water supply and build, operate and maintain Arsenic and Manganese Treatment Plants to attain acceptable standards of water quality.
Neither should it be overlooked that there are six (6) existing water connections between Surrey and White Rock and no work nor any study has ever been carried out to determine whether or not these connections could adequately provide White Rock clean and safe water from Metro Vancouver sources without the need for millions of dollars for capital for Arsenic and Manganese Treatment Plants and millions of dollars annually for additional operating and maintenance expense. Surely building, operating and maintaining unnecessary Arsenic and Manganese
Treatment Plants is not the best available economically feasible technology to solve White Rock’s water quality troubles.
As stated earlier, I and many others are very concerned that the quantity limitations and the insufficient capacity of White Rock’s ground water system will very soon require that White Rock join Metro Vancouver for water supply in any event. This fact was made resoundingly obvious during the tragic May 15, 2016 three-storey building fire at Five Corners in White Rock which resulted in the City’s water supply being exhausted, many businesses and residents – including Peace Arch Hospital – being without water and a three day Boil Water Advisory. Both this news feature http://vancouversun.com/news/local-news/white-rock-tapped-into-surreys-water-supply-to-fight-blaze and the feature found at this web link will be informative http://vancouversun.com/news/local-news/white-rock-knew-years-ago-it-had-a-firefighting-water-deficiency.
As a result of this fire not only was it publicly revealed that White Rock’s water supply for firefighting purposes was so inadequate that it was necessary for White Rock to open its water connections with Surrey and rely on Metro Vancouver water to extinguish the fire, it was also publicly revealed that six (6) water connections to Surrey were already in existence. Before the May 15, 2016 fire, the City of White Rock kept to itself this information about the existing water connections to Metro Vancouver water.
Of course, the point to be made is that the $14.2 M worth of Arsenic and Treatment Plants will do absolutely nothing to improve or enhance the quantity of water available for water users of the White Rock water utility. As the May 15, 2016 plainly showed, already Public health and safety has been put at risk by the limitations inherent in White Rock’s reliance on wells and its ground water supply. The utility as it is currently operating is not sustainable now, and this deficiency with only be further exacerbated when White Rock’s ongoing frenzied residential densification projects are completed. As small as White Rock is, it currently has ten (10) densifying OCP Amendment development projects on its books, all in various stages of approval., with more projects no doubt waiting in the wings. If the water utility under its current operation is not sustainable now, how can it possibly be sustainable over the long term? Spending millions of dollars to build, operate and maintain Arsenic and Manganese Treatment Plants will not add a single litre of water capacity. In fact, these plants will constrain and reduce existing capacity and outputs by the requirement for some period of “contact time” on the water in order to remove the Arsenic and Manganese.
Equally disturbing is the recent revelation that the capacity and output of the existing wells is diminishing over time. In support of an earlier grant application pre-dating the WWCF Program the City of White Rock commissioned a “Water Conservation Plan” from consulting engineers Kerr Wood Leidal. This Water Conservation Plan was given to the City of White Rock on April 21, 2016 and a copy is attached.
Note from the chart on page 4 of the 2016 Plan that the total capacity of all seven wells of the water utility system is 172 litres/second.
Contrast this number with the capacity number found in Section 6.1 of the attached “2013 Water System Master Plan Update” prepared for the previous White Rock water utility owner and operator, EPCOR. This Plan was prepared by the same consulting engineers, Kerr Wood Leidal and presented in November of 2013. Note that thirty (30) months earlier, the total capacity of the water utility was 199 litres/second. The drop in well capacity and output from late 2013 until early 2016 represents nearly a 14% decrease. How can this be sustainable? How will spending millions of dollars to treat metal-laden ground water change this situation.
It appears that the grants that the CWWF is bestowing upon the City of White Rock will simply use taxpayer funds to subsidize the City’s entry into the water utility business to accommodate the City’s own Corporate desires to generate ongoing revenue for the City rather than as first priority enable sustainable, safe and clean water and support a cleaner and healthier environment for the Community. Building Arsenic and Manganese Treatment Plants when there is a more sustainable, more long term cost-effective, more robust and more proven alternative such as joining Metro Vancouver for water supply is not a wise and prudent use of Public monies. Nor is it “value for money”.
Given the facts that have been disclosed to the Public, it appears that the City of White Rock does not really know what it will build, can not really say how its project will improve water quality, has not yet sought or obtained the required environmental approvals, knows that the completed construction date of the project will not meet even the extended March 31, 2019 program funding deadline window, but somehow, the City has still been awarded nearly $11.8 M of Public funds. All of this sounds more like a gift with no strings attached rather than a grant with defined and appropriate standards and accountabilities to be met. Public monies should not merely be handed out as gifts to corporations, even if that corporation is a municipality.
For these reasons, I ask please, that action be taken to review and reconsider the grant that has been given to the City of White Rock to build Arsenic and Manganese Treatment Plants. The best interests of the Public should be paramount when Public monies are being spent and the current project that White Rock is seeking to have taxpayers subsidize does not meet the CWWF Program requiremnets and it is not in the overall long term best interest of the White Rock water-using Community, nor the Public at large.
I look forward to an early reply.
Thank you.Andrew SchulzCo-Chair, White Rock Safe Water Alliance (WRSWA)cc: The Honourable Peter Fassbender, BC Minister for Community, Sport and Cultural Development – For the reasons cited above, the Province should similarly carefully review and reconsider the Public monies bestowed upon the City of White Rock as a grant under the CWWF Program. Better, more sustainable projects involving the White Rock water utility make tremendously greater sense by any set of criteria.