Comment Sheet #2 

In the period between the first and second Munster Meetings, several ‘troublesome developments’ occurred during the Environmental Assessment (EA) process.

1. “Time Urgency” was left out of evaluation criteria – and the subject of "time urgency" was evaded by the Consultants. The Project Leader was asked at the second public meeting, by two members of the public (affidavit available), why the  “time urgency” issue was left out of the Evaluation Criteria (Matrix). His response was, “What time urgency?” – Yet the Original Council Motion stressed the requirement to guarantee to meet the (MOE) compliance schedule (of approximately 1 year), and Munster Residents certainly felt the need for time urgency (see box of comments on 'Time Urgency', at top of this page).
   

2. The RMOC and Consultants, running the Public Liaison Committee (PLC), barred the Public from quietly auditing their meetings. (So much for the meaning of ‘public’!) Even one Environmental Student, doing his thesis (on the EA process), was barred from the meetings. It gave the appearance that the Consultants may have had something to hide.
   

3. The RMOC and its Consultants on the PLC, placed gag orders on its members, during the second public meeting ---on threat of expulsion. (For those members trying to keep informed for the public's sake, and attempt to communicate internally with the already-seriously-compromised committee, it left little choice, but to temporarily keep silent.)
   

4. Many individuals close to the process observed with increasing concern, what appeared to be unsubstantiated ‘technology bashing’. When asked to provide any evidence to support their defamatory allegations, the Consultants could not provide it.
   
   For example: The Consultants created the impression that the Phosphorus output of the RBC Sewage Treatment Plant would be detrimental to the Jock River. They failed to correct one Councillor who said (in their presence) that “tonnes of Phosphorus” would be dumped into the River by the RBC-mechanical treatment plant. In fact, only one level tablespoon of Phosphorus would be discharged, in a 24-hour period …significantly lower that than the River’s ambient Phosphorus level (thus creating a beneficial ‘diluting effect’).
   
   The Consultants, (as well as those municipal politicians and staff members), who made the numerous distorted and defamatory assertions are likely to be challenged in court when the pending litigation transpires.
   

5. Important questions not answered: (The more probing the questions, the more the PLC-member questioners were ostracized, for not being team-players.)
   

6. The Consultant’s made unsupportable allegations that:

   • Dry ditch discharge was not safe ...when, in fact, the effluent quality would be that of Ontario’s swimable water quality. (All-the-while ---as we wait for a solution--- raw sewage leaks from the lagoon cells, into the Copeland Road ditch, and groundwater (Reference TSH – ESR, 1996)). 

   • That bidders could not meet Policy 2 effluent criteria. At the very same time of that allegation, one of the bidders, (CMS), was receiving an MOE Certificate of Approval (C of A) for a treatment plant to go into a Manotick project ---to discharge into a Policy 2 watercourse. (At the OMB Hearing, Conestoga-Rovers and Associates denied any knowledge of the Manotick C of A. One can only surmise that the Region’s failure to inform CRA of the impending C of A, is indicative of their commitment to another pre-determined selection.)

   • That Mechanical Plants were at high risk of break-downs. CRA singled out the RBC System as posing a risk of impending disaster, due to a high potential of shaft breakage. Of the L-1500 shaft type proposed for Munster, there has not been a single known shaft breakage, after literally millions of hours use. Furthermore, with the three RBCs --- as proposed for Munster--- there would be triplicate redundancy. (Appearance of the practice of fear-mongering is not a fitting or ethical way to disqualify a front-running wastewater treatment system, in order to promote an inferior pre-determined selection.)

   • That the proposed pipeline did not require lagoons. The Consultants told the public ---who were bent on getting rid of the lagoons (see Comment Sheet #1)--- that "temporary holding cell" use would be 1-2 days, once or twice a year. At the OMB, two Engineering Experts testified that, with the small-bore forcemain running such long distance, dealing with such variable flows, a lagoon system would have to be in operation ALL-YEAR-ROUND! (Some recent developments with regard to the Richmond 'temporary-use' Lagoons verify this –See LINK to “RICHMOND”)

   • That pipeline capital cost was less than that, for a Mechanical Treatment Plant. Evidence at the OMB Hearing demonstrated this to be false.

   • That  the pipeline/lagoon system O & M costs where the lowest. Evidence at the OMB Hearing demonstrated this to be false.

   • That Pipeline does not pose an unwarranted risk to the Richmond Fen. How can such claims be made, when an on-site Treatment Plant poses ZERO risk to the Fen, and especially when the Richmond-Kanata forcemain has broken five times in the previous 19 years).
      

7. Requested rationales not given, as promised, in time for second public meeting. Grossly inadequate, superficial, rationales were given, about a month after the Public Meeting of August 19, 1998. The Consultant’s criteria and rationales came under scrutiny at the OMB. The OMB Ruled that the City’s case was not “perfected”, and that it did not have the evidence to support a pipeline.)
   

8. Stories of the occurrence of several RFP irregularities became prevalent:
   (One story was, that the non-compliant pipeline bids had been solicited. (The public had been told all-along, that the pipeline bids were "un-solicited".) Finally a letter surfaced, in which Taggart admitted, in writing, that they had been solicited to put in a pipeline bid.  Another instance, was when the deadline for the “unsolicited” pipeline bid-deadline was delayed for two weeks to allow for their non-compliant inclusion. Also, it appeared 'irregular' for the Region’s Engineer to be receiving the incoming bids ---right in the Consultant’s office. These are just three quick examples...
   

9. Bidder's costing was publicized at the Public Meeting (August 19^th), at near double the amount (in some cases), the guaranteed amounts submitted under the RFP  ..without the agreement (or proper opportunity for refutation), by the bidders).
   

10. The published costing on the pipeline selection, was absurdly low, with final pricing to be determined “at the design stage”. (In other words, the non-compliant pipeline bidders were given ‘carte blanche’, to cost whatever they wanted, during the design stage, or build the pipeline on a cost-plus basis). All bidders had been ordered to put in guaranteed pricing. All-the-while, the city had, in its possession, far more accurate costing figures from Totten-Simmes Hubicki, (prior to the RFP), quoting in the $12 Million to $15 Million range. (The City has since broken the various items of this costing into individual project segments---i.e.: Richmond Pumping Station upgrading, twinning of the pipeline across the Jock River, upgrading the Richmond Lagoons, etc., and has been proceeding with work orders in these areas ---ON THE ASSUMPTION IT WILL BE PROCEEDING WITH THE MUNSTER PIPELINE/LAGOON SELECTION. This is in direct defiance and contempt of the OMB Order. See the “RICHMOND” LINK (at the top of the Home Page, for more details)
    

11. Unsatisfactory answers regarding lagoon decommissioning and reconstruction:
    Neither the Region nor the Region's Consultant could be pinned down on how SAFE decommissioning of the lagoons would be carried out, without disrupting the sludge, in the event that an option was selected that required NEW lagoon(s). It would pose a huge  risk of groundwater contamination, in the event that the City scraped away the sludges in the old lagoons, to rebuild new ones in the same location (which is what they appeared to be planning to do). If an alternative is used that requires lagoons, then the full cost of constructing new lagoons at a new location should be calculated, and proper retiring and decommissioning of the old lagoons should be done as a separate task, without disturbing the sludge seal that rests on top of its fractured rock base.

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12. Even at this early stage of the process" it was becoming more apparent,
    day-by-day ---that "THE PIPELINE/LAGOON-FIX WAS IN".

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SUMMARY of the Comment Sheet  Responses
...with ---Non-Statistical--- total of 38 Respondents

 Comment Sheet:  FIRST-CHOICE OPTION
(where ONE OR MORE options may have been mentioned as acceptable):

  1.) Pipeline Acceptability –FALSELY EXCLUDING Lagoon(s) – All combinations ...........................(35)…92.11% ^{a., b.}

  3.) Pipeline Acceptability –CORRECTLY INCLUDING Lagoon(s) – All combinations..…............................(2) ….5.26% ^d.

  Twenty-five percent of the ‘pipeline acceptable’ respondents had contradictory or
   confused comments
  (For example: They supported a pipeline as their first or second choice, because:
  ● "The various other proposals seem expensive and from what I have been informed are
      only a band-aid solution"; or,
  ●"The idea of having ever-larger sewage treatment plants, at huge cost, is not feasible", or,
  ●" I was very pleasantly surprise(d) to learn that a pipeline to Richmond was the least
     expensive method of treatment").

  Twenty-five percent represents a very high confusion rate. That does not include the percentage
  of residents who believed that the Consultants were providing full disclosure when they
  stated that there would be no lagoons with a pipeline ---merely an "emergency holding cell", to
  be used one to two days, perhaps one to two times a year, then emptied and flushed right away.
  ^(a.)OMB evidence definitively proved that the proposed pipeline, requires full-time use of
  lagoon(s).

  Of the 92.11% who indicated pipeline acceptability, only two respondents, (5.26%), acknowledged
  that a lagoon presence ---with the pipeline was acceptable. It is assumed that the other 86.85%
  were indicating acceptability of a pipeline ^(b.)---in order to get rid of the lagoons--- (see:  
  "GettingRid of the Lagoons": Comment Sheet #1). ^(d.)Therefore, it is expected that the fall-off
  rate of acceptability of the pipeline would be rather dramatic, once residents become aware that
  the Munster pipeline design includes continuous lagoon usage.

  Those selecting the pipeline option (in general) provided comments that were more terse,
  demonstrating ---perhaps—a rather superficial examination of the issues. Mechanical treatment
  comments were of greater length, providing detailed rationales, and demonstrating a more studied
  awareness of all issues (i.e.: environmental, land use planning, socio-economic, efficiency, etc.)
  involved in this complex problem.

  It is important to note that, in spite of the profound ‘lack of clarity’ (see: "Lack of Clarity of
  Comment Sheets": Comment Sheet#1), put before the public on August 19, 1998, a full 31% of
  respondents still indicated a knowledgeable acceptance of the mechanical treatment system.
  ^(c.) Proper presentation of the facts, (including the pipeline requirement for a sewage lagoon),
  may well have put that support level over the 90% range.

  Irrespective of CRA’s one-sided presentation …based on missing, incomplete and erroneous
  information, (as  detailed in the OMB Decision)^e., it is no surprise that the pipeline option drew a
  majority of votes. Had the evaluation matrix (confusing as it is) been presented, and walked through
  ---with the Consultant's rationales for each rating--- the audience could have been able to identify
  the many errors in its logic, and form 'their own' opinions. The result would likely have been
  much different.