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3.)
Under "Natural
Environment" (on the Comment Sheet, "additional Information"
instruction page), is the sub-heading:
"Aquatic and Terrestrial
Habitat". For the benefit of residents filling out the
Comment Sheets, this was defined as: "This secondary factor deals with
the loss of aquatic or terrestrial habitat as the result of the
installation of a treatment alternative".
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ANALYSIS:
The average person, reading this, would assume that if
one of the options involves direct discharge to the Jock River, and
another is a pipeline conveyance system without benefit to the
river, then the pipeline should rank the worst, Snowfluent should
rank better (because of percolation) and the direct-discharge
treatment plant should rank the most favourably.
Not so, according to the F-1
Table. It correctly gave the pipeline a "10" (for worst). It gave
Lagoon-Spray Irrigation a "5" (for mid-range). It gave Snowfluent a
"5" (which should have been better than the Lagoon-Spray Irrigation,
because the effluent treatment is superior, (perhaps a "4").
And it gave Mechanical Treatment-Direct Discharge a "10" ,
for worst ranking, (when it
should have given it the best ranking, at "0"). If you look at the adjusted F1-Table,
with only the "Aquatic and Terrestrial Habitat" correctly done,
CLICK
HERE, you will see that,
that single small adjustment,
places the
Mechanical Treatment system as the
Preferred Option.
Added bonuses, in the case
of Mechanical Treatment, is that lagoon decommissioning and removal
would, a.): create a greatly enhanced Aquatic and
Terrestrial Habitat, at the Jock River location ---where it's
needed the most; while, b.): reducing risks to Munster
and area residents of West Nile virus exposure ...through removal of
the lagoons as massive mosquito-breeding habitats. (See 'Lagoon
Decommissioning':
CLICK
HERE.) |
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4.) Under "Social Environment" are the
sub-headings:
"Air Quality - This
secondary factor deals with the impact of a treatment alternative on the
ambient air quality from such items as storage lagoons , spray and wind
drift, or odour discharges."
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ANALYSIS:
The Air Quality ratings appear
quite skewed, if one considers the facts. The null rating of (5) was
assigned to the lagoon and spray field expansion option. It could be
argued, that with bigger lagoons, to produce greater generation of
odours, and larger spray fields, to allow for greater wind drift, the
rating could could have been a (6) or (7). The pipeline, on the other
hand, was rated at (1), when it also requires the use of lagoons.
While it does not have spray irrigation, it has the added problem of
H2S-gas production (and release) along the 11 Km pipeline route, (See Hazeldean
Forcemain H2S Problem:
CLICK HERE).
The Pipeline/Lagoon rating could have been more realistically scored
at between (4) and (7). Mechanical Treatment, on the other hand,
received a falsely rated score of (3), considering it does not
employ lagoons, and the treatment units are housed in three, small,
enclosed buildings that could be remotely located beside the old
lagoon cells ---which would now be turned into an odour-free conservation area.
Therefore, this treatment alternative should have been more accurately
rated at (0) or (1) due to its
superiority over the other options in this category. Snowfluent was rated
as a (4), which is better than the null, and is left unchanged.
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"Noise Levels - This
secondary factor deals with the increase in noise levels above ambient
levels for a treatment alternative and the operation of an alternative
that generates noise during the night."
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ANALYSIS:
This category is badly skewed, as
well. While the expanded lagoons, rated as (6), will result in more
spraying, most of the activity will be away from homes, and it is
assumed that only day-time spraying will be conducted. Therefore, this
could probably be kept at the (6). Mechanical treatment, which was
rated at (3), produces no discernable noise, and should
definitely be rated at (0). Snowfluent spraying, rated at (6), has
been adversely targeted because of night spraying, however, the spray
nozzles, pointing skyward, make much less noise than claimed by CRA,
and spraying would occur in an area away from housing. Besides, most
homes have closed windows in the wintertime and residents would likely
not hear any sounds. Snowfluent (even with its diesel compressors)
should probably have been rated at (3) or (4), below null. The most
skewed rating of all, with a (0), is the pipeline. Late evidence at
the OMB hearing, pointed very strongly toward a 10-inch pipeline
(instead of the proposed 8-inch). This would mean that the pumping
station ---located in very close proximity to the lower Dogwood Drive
homes, would require, a change from the existing
10 HP motor,
to an 80 HP motor. At the increased level of noise, this could
be a severe annoyance to the affected homes, (at nighttime, and
through all seasons). The pipeline should, more likely be rated at
between (7) and (10).
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"Aesthetics - This
secondary factor deals with the impact of a treatment alternative on
aesthetics and landscape of the general area."
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ANALYSIS:
As the Munster Public Comment Sheets expressed,
(View "Getting rid of the Lagoons" and
"System of Choice":
CLICK HERE), “Aesthetics”
should refer, mainly, to public disfavour with the lagoons. Therefore,
all the rankings should be quite similar, save one ---Mechanical
Treatment--- which does not require lagoons. Thus, Lagoons, which were
ranked (7), and should probably be kept at (7), because of Lagoon
expansion. Snowfluent, which scored a (7), and the Pipeline, which
scored a (1), both requiring at least one lagoon, could, probably be
rated at (4). Also, consider that there has been no allowance made for
the negative aesthetic impacts upon the Richmond Conservation Area,
caused by Munster sewage entering the Richmond lagoons during peak
flow periods. Mechanical Treatment, on the other hand, which received
a scoring of (2), should be ranked at (0), since it does not require
lagoons at all. |
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5.) Under "Land Use" are the
sub-headings:
"Recreational Land Availability - This secondary
factor deals with the removal of existing passive or active recreational
activities due to an alternative."
"Agricultural Land Availability
- This secondary factor deals with the removal of land from agricultural
production due to an alternative."
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ANALYSIS:
"Land Use" is the most important category, in terms of the
Regional Official Plan, the Provincial Policy Statement, and was the
basis for the OMB Hearing itself.
The Agricultural Land Availability
is a legitimate issue, because the Expanded Lagoon / Spray
Irrigation option, and the Snowfluent option both required
more land space for spray area. They were ranked "8" and "7"
respectively (which appear accurate, because Snowfluent requires
less spray area). Mechanical Treatment is rated as "0", which seems
correct, because it does not require spray area or lagoons (...it
actually frees-up land). However, CRA rated the Pipeline option as
"0", when in fact, it requires at least one large lagoon, and worse, it ties
up the valuable road corridor space of approximately 7.5 Ha, (to
Richmond): crosses a trans-Canada fiber-optic cable, risks the
shallow wells (in porous soils) along the route, and causes needless risks
to the
Richmond Fen (see photo: CLICK
HERE). Given the
availability of the much more favourable communal option (i.e.:
mechanical treatment), the Pipeline option represents very poor
land use planning, therefore, its rating should be moved to that
representing "worse" than the Lagoon Expansion (at 8), and should therefore be a "9", at least.
Rectification
of this significant exclusion would, by itself, place the Mechanical
Treatment Plant as the 'Preferred Option', (not the Pipeline).
The
"Recreational Land Availability"
sub-heading, in this case, is mere filler and
should be eliminated, since none of the options "remove" passive or
active recreational activities. If "Recreational Land Availability"
had to be considered as a serious consideration, then the only
option which would be favourable here, is the Mechanical treatment
plant, because all of the currently used lands ---save 3500 square
feet, could be turned into recreational toboggan/ski hill and park
land.
The, above-mentioned,
utility corridor issue, with its
associated environmental and health risks, should really be inserted
as a consideration, instead.
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6.) Under "Wastewater Treatment" is the:
Adaptability to Accommodate
Future Community Growth - "This secondary factor deals with the ability
of a treatment alternative to either handle
expansion due to community growth
or for a treatment system to be easily expanded."
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ANALYSIS:
"Adaptability to Accommodate
Future Community Growth," was the most
'politically incorrect'
(and rationally dishonest) of
all the questions asked on the Comment Sheet. If you took a poll in
Munster, to ask residents if they preferred the community size to stay
the same, the answer would be, primarily, "Yes". Since this is
well
known, and because the "cap" on Munster's growth is
already protected by both the Official Plan and the by-laws ...the
question should NOT be used by the evaluators, as a method of
promoting the pipeline (which is incapable of expansion). In other words:
"Inferior
sewage handling capacity should NEVER be used as a means of
controlling population expansion". (That is what appears to be alluded
to, here.) The way the question was posed, (re: handling "expansion
due to community growth", as above), makes this a 'Trojan
Horse'-trick question, loaded in favour of the pipeline, due to its
inability to service new construction.
If the Evaluation was to consider
which system could best handle peak flow surges, due to groundwater
infiltration in March-April-May, (see Chart:
CLICK HERE),
then the Pipeline option would have received the lowest, (10) rating,
instead of (0).; the lagoon would have been pretty much the same, at
(5); and the Snowfluent and RBC Mechanical treatment systems would
have been closer to a (0) score, instead of the (4)-rating, they were
given.
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This example
demonstrates how easy it is to skew an evaluation process, simply
by asking the wrong questions ...or by asking them
the wrong way. |
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(To see the Table F-1 of the Evaluation
Matrix:
CLICK HERE)
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The two other sub-headings under
the "Wastewater Treatment" section of the Public Comment Sheet,
should probably not have been asked at all (to a non-technical
public). The sub-headings, with their accompanying explanations are as follows:
"Process Complexity and Demonstrated Experience of Performance
- This secondary factor deals with the amount of automation for the
alternative, the complexity of the treatment process and the
possibility of upsets, the degree of impact from non-controllable
factors such as weather and the historical performance of similar
treatment systems."
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ANALYSIS:
This is one of the categories that
the average person would have no hope of being able to understand the
relative Unit Values, or be competent to rank. Since everyone would
want the best features in all categories, for their community (i.e.:
all-weather performance, etc.), asking the question appears only to cast
unwarranted doubts, in the direction of the 'newer technologies'.
Since the newer technologies ---no matter how superior they may be---
do not have the same "Demonstrated Experience of Performance"
---no matter how relatively poor that older system may be. It's a
'Catch-22" question which can only be considered as misleadingly
specious. It is especially unfair, however, since the whole purpose for the Evaluation
Assessment process, and the RFP, was
to "consider
newer,
advanced technologies, that have not been adequately considered
before".
Furthermore, "professionals"
should be using whatever engineering expertise, they might have, to
define which technologies meet (or do not meet) their
proponents' technical claims ...not the public. All the public wants, (and the
Council order originally asked for,
CLICK
HERE),
is to have the best performance for the
lowest cost, in the
shortest
possible time frame.
(The Evaluation Matrix has 'struck-out' on all three.) |
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"Consistency for Meeting
Effluent Objectives - This secondary factor deals with the
efficiency of a treatment alternative and
the ability of the treatment
alternative to consistently provide results below effluent
objectives."
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ANALYSIS:
It's interesting how CRA dealt with
this one. The "effluent objectives in the Request for Proposals (RFP)
were very specific, and extremely stringent (To see RFP
"Effluent Compliance Objectives":
CLICK HERE).
The pipeline
is noncompliant with the RFP, in ALL respects.
It does not "treat", therefore it cannot meet
any of the "Compliance Objectives", for discharge to:
-
Land application (i.e., Spray Irrigation or equal).
-
Subsurface disposal to groundwater system (i.e., tile bed or equal).
-
Water course discharge (i.e., Jock River).”
The scoring on the Lagoons, at (0);
Snowfluent, at (0); and and the Mechanical Treatment Plant, at (0)
...are all accurately rated, because they are all capable of meeting
their respective "Effluent Compliance Objectives". However, if
you look at the Table F-1 Matrix, you will see that the pipeline was
slipped a (0) rating, as well, when, in fact, it cannot comply with
any of the "Effluent Compliance Objectives", and should not only be
scored the worst, at a (10): but, according to the RFP, it does not
even qualify as an option to be considered.
Accurate rating of this one
criteria, would have placed the pipeline at the bottom of the choices
(or, more precisely, excluded it altogether). |
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7.) Under "Economics"
"Capital Cost - This secondary
factor deals with the capital cost and the importance of the capital cost
to the other cost items."
"Annual Costs (Operation and
Maintenance) - This secondary factor deals with the annual cost and the
importance of annual costs related to the capital cost."
"Life Expectancy and Life Cycle
Costs - This secondary factor deals with the life span of the system and
the costs associated with replacement."
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ANALYSIS:
See point #1 (above). The Engineering firm of Totten Simms
Hubicki (TSH), was asked to present Capital cost estimated, in
February of 1998, just before the Conestoga-Rovers and Associated (CRA)
evaluation. TSH gave Capital Cost
estimates in the 'double-digit'
($15 million to $16 million)
range, (To see estimate:
CLICK HERE).
The
compliant Bidders gave
guaranteed price quotes for Capital Costs, O&M Costs, and
Life Cycle costs. That is how RFP's work, leading to the award of
contract, and includes all design build costs. The non-compliant
bidders, did not give final costs ---fit for the award of contract.
Instead, (contrary to the RFP rules), they were allowed to submit
---and
were selected as the preferred option--- on the basis of artificially
low, 'rough guesstimates', to the edge of Richmond Village, with
additional costs to be tagged on later.
Significant
costs covering items such as
rock determinations, rock blasting, mitigation measures through
Richmond Fen, route selection through Richmond, mitigation measures
for damage to wells and property, Jock River pipeline crossing,
Richmond pumping station upgrades, and a host of others, were
completely ignored.
The RFP originally asked bidders to
be prepared to operate their facility for the first three years, but
this item was later retracted, by CRA, to make way for the
non-compliant pipeline bids.
The Capital and O & M costs of the
Mechanical Treatment System, submitted for the "Guaranteed, fixed
price" requirement, were substantially lower than the pipeline/lagoon estimates
done by all other engineers (except CRA).
Relative costs of the
Rotating Biological Contactor- Mechanical Treatment technology,
compared with the Activated Sludge Method (similar to ROPEC), is shown
in the attached quote from an 'Report to Congress', in the US, where
many of these systems operate: (...for good reason:
CLICK HERE).
With Capital Costs for the pipeline
approximately five times higher ($15 million vs. $3.2 million), than
other alternatives, and with O & M costs substantially higher
for the pipeline, lifecycle costs
appear to be so far out of line, as to place the pipeline option as
"a distant last",
at the bottom of the
evaluation page (as mentioned at the opening, Point #1). |
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CONCLUSIONS:
At their public
meetings, and at every other opportunity, CRA placed emphasis on the
infallibility of their Evaluation Methodology. The OMB Hearing concluded
that the Evaluation Matrix (Table F-1:
CLICK
HERE) was too subjective
(see comments:
CLICK HERE).
CRA’s Dr. George Nakhla’s:
“approach to defending his
methodology used in this instance was more in the nature of advocacy than
forthright professional opinion”, according to OMB Chair, Mr. N. Katary.
CRA, (in critically
reviewing the work done by another engineering firm), made a completely
opposite statement in its “Executive Summary”, for King City, Region of
York, when it stated (in June, 2001):
“The
Decision Matrix
procedure utilized in the ESR is extremely sensitive to criteria weighting
and subjective with respect to individual score assignment. The procedure
is, at best, a screening tool and should not be used for making a final
decision between the Regional and local communal treatment alternatives.”
The bottom line is:
If anyone, (even without engineering expertise), takes the time to go
through the various scorings, which they can arrive at themselves,
(using the Table F-1 format), applying clear rationalization to the
various unity values, they will arrive at a completely different conclusion
than CRA’s.
Common sense,
rationalizations must be applied, in the area of environmental
benefits, aquatic and terrestrial habitat, land-use efficiency (free-up road
corridor, free-up spray field, eliminate lagoons), elimination of risk to
the Richmond Fen, and area, shallow wells, protection of the aquifer and the
watershed, adherence to the Official Plan (not extending central services
unless a health risk, not mixing central and communal services, support new
technologies, minimize cost of municipal services, treating
on-site wherever practical, etc.:
See: #8, #11, #12, #15, #7:
CLICK
HERE), and cost-efficiency
(Capital and O&M) . Use of the above, Evaluation Matrix, but applying
objectively rationalized, common-sense scorings, yields the overwhelming
conclusion:
---by a wide margin--- that
a Mechanical Treatment Plant,
working to the wastewater treatment specifications stipulated in the subject
Request for Proposals, and releasing to the water-starved Jock River, is the correct option.
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