- increased costs for the CMS option by adding a back-up lagoon that CMS says is not required. Since the system would operate on 3 identical modules, the likelihood of total system failure is remote in the extreme. Note that the CMS solution is the only option that does not require a lagoon, an important consideration in dealing with West Nile virus.

- increased costs for both on-site options by misrepresenting the timeline required for approvals of these options. It stated that the on-site options would have to go through another full environmental assessment, adding a minimum of 1 year. MOE guidelines (actually, Municipal Engineers of Ontario guidelines) require that any significant, reviewed modification can be written as an addendum to the ESR. In this case, both on-site options have been overly reviewed so no additional review or study is required. Thirty days notice of the addendum must be given and an additional 30 days allowed for the public’s right for Part II Order (appeal to MOE). Since the MOE minister has not approved a Part II order in recent memory, the delay would be minor. A shortened timeline makes both of the on-site treatment options cheaper than pipe. In addition, completion of the on-site options would be by early 2004, a year ahead of pipe (early 2005). It should also be pointed out that the pipeline costs are uncertain and can only escalate, but the costs for on-site options are known to the penny. How many staff-managed, cost plus projects of this type have been completed on budget?

- added timeliness as an important criterion when it supported pipe. Every opponent of pipe (including the Friends of the Jock River) maintained that timeliness was negligently removed from evaluation criteria in previous studies because it benefited on-site options. If the inclusion of this criterion had been conceded by the City’s lawyers, staff and consultant prior to the OMB, one of the on-site treatment options would have handily won the selection process and it would have been in operation since 2000 or 2001. The savings to the City in the costs for sewage hauling, additional unnecessary studies and litigation would have been well over $3M. City staff bears total responsibility for this needless waste of our tax dollars.

- failed to consider that an Environmental Assessment (EA) is required to select the route through Richmond. This process will add more time to the pipeline process. Failure to conduct an EA would remove the right of redress on the route selection from the residents of Richmond, an issue that could have legal considerations for the City.

- overstated the concern about the ability of the CMS system to meet discharge requirements. Using the CMS technology, Munster's sewage would be treated to a tertiary level (the limit for Ontario's swimmable water requirements) and the effluent would be of higher quality than the water in the Jock River.  The three main components of the treatment process are proven, well-known and reliable technologies in wide use in North America and Europe.  The combination is new to Ontario because of Ontario's stringent Policy 2 discharge requirements but the combination has been proven by the New York State EPA to consistently exceed the MOE discharge requirements.  Furthermore, the technology has been accepted by the City and the Ontario Ministry of Environment (MOE) for Manotick.  The MOE has granted a certificate of approval for the facility in Manotick employing the identical technology for the same discharge requirements.  In a recent article, Councillor Stavinga said that the comparison with Manotick "is a poor one" because the Munster plant will serve more homes.  The statement simply demonstrates her lack of knowledge of the CMS option, which is a modular system that would be sized to the need. One module is required for Manotick and three for Munster.

- during the pipe construction there will be risks of environmental damage to the Jock River (one crossing), and to the Richmond Fen Wetland (15% or 1.7 km of the route). The pipe must pass close to more than 140 households that rely on shallow wells for their water. In addition, the pipe must cross the route of one major gas pipeline (largest number of accidental pipe ruptures relate to gas).

- in operation, the pipe would steal water that currently, for 3 seasons of the year, is sprayed as partially treated sewage onto fields near the Jock River where, as surface and ground water, it ends up in the river. While of questionable quality, it augments the flow of the river. The discharge from either on-site option would augment the flow (more so with the CMS option) with water of higher quality than is in the river and it would represent most if not all of the summer surface flow in the Copeland Road portion in drought years (3 of last 4 summers).

- pressure sewage forcemains rupture, a fact accepted by the City’s Director of Infrastructure, Richard Hewitt, in a recent CBC Radio interview. The Richmond to Glencairn sewage forcemain, has ruptured 5 times since it was built in the 1980’s, two having occurred within 6 months following the recent installation of a twinned section of pipe under the Jock River. With a similar pitiful degree of reliability, the Munster pipe could be expected to fail many times (up to 20 times) over a 60 year time period. Consider the environmental effect and cleanup costs of ruptures on: the Richmond Fen Wetland (1.7 km or 15% of the pipe length) and the Jock River. If there were a rupture, consider the health effects, cleanup costs and costs of supplying clean water to the 140+ homes along the pipe route that rely on wells for their water. Surely, the inevitable costs of mop-up and repair of ruptures (millions in our estimation) should have been added to the lifecycle cost of pipe but they were not. Why not? Given this pitiful degree of reliability, why has there never been an impact study to determine the effect of a pipeline rupture on 140 shallow wells along the route, or on environmentally sensitive areas?  Why has Councillor Stavinga not shown a concern for her constituents over the very real health and environmental risks posed by pipe? Mr. Mayor and Councillors, I implore you not to forget Walkerton.

- sewage in long forcemains has a history of becoming septic. The hydrogen sulfide produced by septic sewage smells, is toxic and corrodes pipe and equipment. Further, septic sewage is expensive to treat. Septic sewage is a problem with the current Richmond-Glencairn sewage forcemain.

- why choose a solution that involves transport of sewage 60 km across the City to have it treated to a secondary level when it can be treated on site to a tertiary level? The concentration of phosphorous discharged to the Ottawa River is 25-30 times that of the CMS system. ROPEC must use chlorine to disinfect the effluent in the warmer months. The chlorine is toxic to aquatic life. ROPEC has no backup system so it must occasionally discharge untreated sewage directly to the Ottawa River (4,000,000 litres in 1998, the last date for which I have data).

- while the ROPEC sewage facility is in compliance with current provincial requirements, the City must recognize that Walkerton has and will continue to influence the Ontario government’s approach to sewage and water treatment. The Ontario government will likely soon require treatment plants to be upgraded to tertiary treatment level to protect our no-longer unlimited supply of clean water. Since the conversion of ROPEC to tertiary treatment will most assuredly happen in the next 60 years, Munster’s proportionate cost of upgrading the ROPEC facility must be added to the lifecycle cost of the pipe option! However, now is an opportunity to get started by removing new demand at a lower cost than pipe alone. (Munsters sewage would represent a small (about 0.7%) but not insignificant amount of ROPEC’s current production.)

- greenhouse gas emissions related to the operation of the pipe are significantly greater that those for either of the on-site treatment options. Pipe requires a large pump (up to 88 horsepower) in Munster, a large pump in Richmond and then in the gravity part of the collection system the sewage must be pumped up 7-8 times before it gets to ROPEC. Treatment at ROPEC involves big motors as well. By comparison, each module in the CMS option operates on a 5 HP motor plus a few other smaller motors. If the City has to deal with reducing its greenhouse gas footprint, it must pay attention.

- in the only scientific survey on this issue of Munster homes in April 2002, responses were received from 73% of Munster households and it showed that 83% of all households (accurate within 2.9%, 19 times out of 20) prefer on-site treatment alternatives on environmental grounds.  A similar survey in Richmond showed that 77% of Richmond residents prefer on-site treatment for Munster.  In its drive to install pipe, it is clear that the City is prepared to act against the wishes of the majority of the affected residents.