-----Letter from Dr. Robert Cushman - May 11, 2004----- 

(Highlighting added)

-----Reply to Dr. Robert Cushman, May 17, 2004-----

May 17, 2004

Dr. Robert Cushman, MD
Medical Officer of Health
City of Ottawa
Public Health Branch
495 Richmond Road
Ottawa, ON, K2A 4A4

(Via: Email and Fax)

Dr. Cushman:

Sir, your letter is a huge disappointment in that it is devoid of any ‘medical’ rationale which would suggest an interest in protecting the health of residents of the Richmond Village area. Instead of recognizing that a communal sewage treatment system would offer the most obvious health protection, you have spent the major part of your letter "parroting" opinions of non-medical city staff, regarding their forcemain post-rupture "contingency plans", "monitoring", "notification of property owners", "supplying bottled water", "providing boil water advisories", and "keeping residents abreast of the on-going investigations".

Perhaps we have to point out to you that the SCADA Alarm System, (another often-touted contingency measure) did not detect the weeks-to-months-long leakage of the out-going Richmond forcemain, prior to its complete rupture on June 19, 2002. Had such a continuous slow leak occurred in the Richmond Village aquifer, you may well have had a more graphic example in terms of resident deaths to help you achieve the proper medical perspective in order to protect citizens regarding this current issue.

Let us remind you that the less expensive on-site treatment plant does not require any "contingency plan" in order to protect the lives of residents. It is 100% safe, in that it poses zero threat to the shallow aquifer source of drinking water for residents.

Your suggested "providing bottled water" --- coming after, potentially, several months of continuous shallow aquifer contamination--- would not protect lives, one whit, during the entire course of the undetectable slow-leak period! And, it would only be through an increased incidence of illnesses and/or deaths that such slow leaks might be discovered. Why should rate-paying citizens be relegated to the status of "canaries in coal mines", only to mask the larger problems of political/bureaucratic incompetence and self-serving greed?

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This case has been reduced to two principal issues: 1.) health/safety issue by the residents, and; 2.) cost issue by the city. The highest priority issue, by far, is the health issue. Is it not reasonable, then, Dr. Cushman, (in your medical estimation), that you should serve the public interest, with its priority being "health and safety", rather than pandering to the city’s speciously contrived: cost-over-health agenda?

Worse, even, is the fact that the city’s cost-over-health agenda ---that you appear to have bought into--- is a fraud. There is clear evidence that the city falsified the true cost of the forcemain, to make the on-site options appear equal, or marginally higher, after a fictitious 90-year life-cycle extrapolation. The city’s illicit cost arguments are especially irresponsible in light of the fact that the Walkerton fiasco really has cost taxpayers over $155-million. Where is the economy in repeating that?

Also, your (non-medical) confidence in the Class Environmental Assessment (EA) process appears somewhat misguided. The Class EA process, by MOE’s own admission, is "proponent-driven" and "self-directing", and is about process. The Class EA process does not require the performance of "health-risk assessments". This is where YOU are supposed to come in. Has your office done any health-risk assessments on the city’s preferred pipe option? --- Or, in fact, does it even have any of the documentation on the project, or on all five of the ruptures, to date, that have occurred on the Richmond outflow forcemain? Since several EA process errors and city misrepresentations are now being catalogued with the MOE, it would appear that your confidence in the city’s Class EA is misplaced.

In your reference to the 2002 RVA report, you failed to mention the fact that RV Anderson opposed the conclusions of the (OMB-discounted) Conestoga-Rovers & Associates (CRA) report, by instead, recommending against the pipeline, in favour of a communal system for Munster.

Also, the city’s Environmental Advisory Committee (EAC) has clearly stated its preference for the on-site technology option over the forcemain, for reasons of environmental benefit and safety ---even though, strangely, neither you, nor any other city bureaucrats asked for its input.

Sir, abdication of your medical responsibility in your service to your political masters is simply not an acceptable fulfillment of your duty to the public interest. You cannot serve two masters well. We believe that your true duty should be to oversee the protection of health of Ottawa residents. By failing to address the legitimate concerns and fears of Richmond residents and resolving the stress and worry of ALL of the residents on shallow wells, you are already negatively affecting the health of those you are supposed to protect.

It is still not too late to order the safe on-site alternative, (recommended by three out of the four municipally-appointed engineering reviews), as the best (and lowest cost) method by which to safeguard the health and safety of the 5000-plus residents who must depend on your office, alone, for the medical expertise required to protect them.

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Environmental engineering ethics, calls for "plausible worst-case scenario evaluations", of any alternatives being considered. When performed properly, these procedures tend to reduce some of the consultant-client advocacy (bias) that can otherwise drastically skew "preferred alternative" outcomes. In the case of a communal treatment plant, for example, the worst-case scenario would likely be a forced temporary shutdown, with the need for short-term storage or trucking, but no health risk. With a pressure forcemain conveying sewage through a shallow-well drawing area, the worst-case scenario of a sustained undetected sewage leak is obviously orders-of-magnitude potentially more catastrophic. The Medical Officer of Health should plainly rule on the side of caution ---in this issue--- as clearly as he would have to, in reducing risk of exposure in a SARS contamination-avoidance protocol.

In your unique capacity as Medical Officer of Health, to fail to advise the city against the selection of a pressurized forcemain, routed through the vulnerable, shallow well aquifer of close to 5000 residents, is a dereliction of your duty, more so considering that an alternative is available that does not place the public health at risk.

We trust you will review and reconsider this matter in a (plausible worst-case scenario) medical context only (as requested by the affected residents), or be held accountable by other authorities than the temporary politicians you may deem as your masters.

Yours truly,

Bruce Webster,
Director, Richmond Village Association

cc:
Dr. Sheela Basrur, Chief Medical Officer of Health, of Ontario
L. Dombrowsky, Minister, MOE

Related correspondence:   (From #8.8 of Document List)

              Ontario Ministry of Health - December 23rd, 2005 letter
              passes responsibility back to Ottawa Public Health Department
              and the Ontario Ministry of the Environment.