The CRD has been punting its management problem down Hartland Ave. for years. Pressure to resolve the region’s biosolids and other solid waste management plan has resurfaced as construction plans to increase capacity at the landfill are underway. The CRD board faces pressure from the province to come up with a final waste management plan by June, as mounting waste at the landfill matches a growing population.

The residuals treatment facility at Hartland Landfill converts residual solids from the wastewater treatment plant into Class A biosolids (free of pathogens after treatment). Currently, 10 tonnes of bio-sludge is spread or buried at Victoria's Hartland landfill. 

In November, the Hartland Landfill received nearly $11M to prepare a new solid waste disposal area or “cell”. The current cell was created seven years ago and is reaching the end of its life-design capacity. According to the CRD Waste Management Plan, the two will have a combined capacity to handle the region’s waste until 2048. The construction of the new cell will mean redirecting commercial traffic to enter the north end of the site via Willis Point Rd, a route that is slated to cost $4M dollars.

The fundamental issue is how to reduce and divert waste from the Hartland landfill safely, efficiently, economically, and sustainably. When it comes to the disposal or recycling of biosolids, decision-making stakes are high and costly.

Because of land constraints and greater investment in the concept of circular economy, Japan, Holland, Germany and a number of other EU jurisdictions have banned biosolid land application because of environmental concerns, favouring waste-to-energy technologies and biorefineries that keep by-products and materials circulating in their economies. 

Biosolids, the by-product of wastewater treatment, contain various contaminants, including persistent “forever chemicals,” (PFAS- Per-and poly-fluoroalkyl substances) heavy metals, and pharmaceutical residues. PFAS do not break down organically and accumulate in the human body and environment. 

The government of Canada reports that “studies in people have found that exposure to PFOA and PFOS can affect the liver and metabolism, the nervous and immune systems as well as the birth weight of infants. The International Agency for Research on Cancer has classified PFOA as possibly carcinogenic to humans.” 

The province disagrees. In his Feb. 2023 letter to CRD chair Colin Plant, the minister responsible for the environment, George Heyman refers to Hartland sludge as “the highest quality by-product suitable for beneficial use.”  Despite that assurance, he goes on to say that “the ministry is pursuing modernization of the Organic Matter Recycling Regulation (OMRR) to improve protection of human health and environment.”  

To that end, wote the minister, “the ministry has established a technical working group on contaminants of emerging concern, which includes experts from academia, and this group will help inform implementation of provincial policy for biosolids.” Their report on toxins of emerging concern, initially scheduled to be released last May, has, according to Larisa Hutcheson, general manager of parks and environmental services, been postponed to May 2024.  

Given revelations about the negative and potentially dangerous impacts of the land application of biosolids and the pressure facing the CRD board to finalize its waste management plan, the stakes of what that report might reveal are high. 

This week, The Guardian reported the U.S. non-profit Public Employees for Environmental Responsibility was filing a lawsuit against federal regulators for failing to address dangerous levels of PFAS “forever chemicals” known to be in biosolid sludge. The state of Maine banned the land application of biosolids in April 2022. A CRD ban on land application of biosolids has been in place since 2011. However, the province considers the land application of biosolids to be beneficial and has insisted that land application options should always be on the table.

The province’s stance raises the question of whether the CRD might expose itself to similar legal risk as U.S. federal regulators if it caves, at some point, to provincial pressure to support land application of biosolids as part of its waste management plan as it suggested it might, in its recent public consultation.  

To advance its decisions around biosolids and solid-waste management, the CRD has been waiting for the OMMR report. Given the delays to provincial reporting on organic matter recycling regulations, Victoria Coun. Jeremy Caradonna forwarded a motion, at the board’s Wednesday meeting asking that it go ahead with asking researchers at UVic to prepare an academic literature review on the uses and impacts of biosolids, as an alternative or complementary source of information to the province. 

There are other pending delays facing the CRD board on pilot projects and Requests for proposals (RFPs) for  thermal pilot plant trials. The first RFP is to hire a technical director and the second is for the actual thermal processing plant that person would be responsible for.

It has been three years since the CRD board approved “next steps” for two pilot programs—–one in Esquimalt—that will evaluate potential thermal resource recovery options for both the Class A biosolids produced through wastewater treatment and some construction waste materials received at Hartland Landfill. In 2021, CRD staff were “directed to support the business case process the Township of Esquimalt was undertaking to explore feasibility and gasification of solid waste, and $50,000 was identified to support this work.” That project has not yet come to fruition. 

“We have re-confirmed funding from the CRD for testing our solid waste that provides the biochar and what quality/value it has,” Esquimalt mayor Barb Desjardins told Capital Daily “Staff are working to get the testing done.” The Esquimalt pilot project applies only to household waste, not to biosolids. 

On Feb. 8, the Peninsula & Area Agricultural Commission (PAAC) drafted a letter to CRD Chair Colin Plant “reaffirming its position opposing the land application of biosolids in the Capital Regional District.” The group is asking the CRD to consider thermal conversion technology as a promising solution. Unlike conventional incineration, thermal conversion involves heating biosolids (using steam) to high temperatures, neutralizing harmful compounds, and producing biochar—a valuable product with various applications.

Time and space are running out—and the waste keeps coming. Hutcheson reminded colleagues that, despite feedback from the Nanaimo RND asking them not to pursue it, the CRD is still considering exploring a second waste quarry site in Nanaimo.

Meeting chair Ted Robbins confirmed that as long as they did not receive direction in contra from the board, they would “continue to look at Nanaimo as a location for our biosolids.”