Reactions to Waste Spreading

• BC NDP
• First Nations' Environmental Network
• Letters from Citizens

BC New Democractic Party

As you are aware, the BC Liberal government intends to introduce new legislation next spring allowing the use of pulp mill sludge, fly ash and mill waste water to be used as a soil enhancement product.

The NDP Opposition Caucus believes there are problems with the proposed legislation. There is a lack of knowledge about the contents of industrial sludge and waste. Studies that determine the effects of the chemicals present in the sludge are insufficient. It remains unclear how the toxins contained in the sludge will affect our water resources, agricultural lands and food chain. There has also been a lack of public notification and consultation in this process. The BC Liberal government's public consultation process was low-profile and brief.

Protective measures in the proposed legislation are inadequate. It is unclear how the government plans on enforcing the provisions that dictate set-back from water bodies, neighbouring property, and human settlements. It would be difficult to enforce protective measures given the under-funding and admitted slashing of Ministry of Environment staff and officials in the past 5 years.

The Opposition Caucus believes that this is another one of the government's deregulation initiatives that takes responsibility from the public and places it in on individual professionals. The proposed code of practice places enormous responsibility on medical health officials for determining the safety of nearby drinking water for applications in a watershed or on agricultural land. However, it doesn't equip these professionals with the ability to do anything more than make management recommendations. The proposal also doesn't include provisions for input from neighbouring landowners.

My office has received numerous concerned emails regarding toxic sludge and my concern is that the BC Liberal government has not conducted the proper scientific due diligence to justify their new initiative. If they have, it isn't publicly available. I would like the entire process put on hold until the proper information is available and until the public can scrutinize the disposal process given the proper time.

Thanks again for providing me with your thoughts and feedback about this important issue.

Sincerely,

Shane Simpson, MLA
Vancouver Hastings
Phone: 604-775-2277
Fax: 604-775-2352
shane.simpson.mla@leg.bc.ca

To view the BC NDP Caucus issues reaction on their website

First Nations' Environmental Network

To Whom It May Concern (All Citizens and Government Peoples of B.C.)
Re: Government Proposal to Dump Pulp and Paper Sludge into B.C. watersheds
From: First Nations Environmental Network www.fnen.org

The proposal to dump toxic pulp and paper sludge into B.C.'s watersheds is a cheap and dirty deal for all B.C. residents and visitors including all forms of life.

We strongly object to the government's fast tracking of this plan while many people aren't aware this is going ahead.

We strongly object to the use of B.C.'s land and watersheds as dumping grounds that allows Pulp and Paper Companies in B.C. to get away with not dealing properly with this toxic mess they are creating.

We want a full report and disclosure of all chemicals used in these processes and want the B.C. public to be fully informed of what may become part of their waterways and recreational areas.

We expect that you give the public a longer period in order to have input into this as well as having public hearings in the regions you are planning on enacting this to ensure proper consulting.

There are few people that have even gotten word that this is going ahead and something of this nature certainly needs some precautionary principles involved and more public information and time.

This is not "consultation" of any form in regards to First Nations usage of these lands and therefore is a breach of legal requirement on the part of the B.C. Government.

For All Our Relations, Steve Lawson, National Coordinator, FNEN, Susanne Hare, Assistant

Letters from Citizens

Dear Mr Minister:

I am concerned that the proposed plan for disposal of industrial wastes on farm and forest lands is dangerous and that the proposed code of practice is inadequate.

The chemical mix in the waste materials may be very complex, and the proposed testing processes appear inadequate to determine just what toxic constituents may be present. The proposed standards for metals do not meet existing CCME standards for agricultural use. Standards for organic contaminants are inadequate and incomplete.

I am concerned that assessment of impacts on the affected farmland and adjacent surface and groundwater is inadequate. There is inadequate provision in the plan for notification of the public that may be affected, and there is little opportunity for affected members of the public to secure action about concerns or remedy for impacts sustained.

Please rethink this plan and modify it to better protect the interest of the public.

Mike Morrell
Denman Island BC V0R 1TO

RE:  Land Spreading of Pulp Mill Sludge - Industrial Waste on Farmland

Belatedly, it has come to the public’s attention that the BC Liberal government is proposing, after only thirty days internet-based consultation, to allow the almost uncontrolled land spreading of pulp mill sludge industrial waste on BC farmland.

For the government website notice, please see:

http://www.env.gov.bc.ca/epdiv/ema_codes_of_practice/soil_enhance.html

Regardless of the rather innocuous sounding turn of phrase “soil enhancement”, toxic sludge is not an “enhancement” to nature’s soil.  Pulp mill sludge contains a toxic stew of contaminants, including a variety of heavy metals and chlorinated and non-chlorinated benzenes and phenolics with the amounts appearing to vary from sample to sample.  In fact, no one seems to know exactly what each load of the brew may contain, nor does anyone appear to know the actual environmental impact of land spreading sludge because, for almost 25 years, industry across North America has been denying all efforts to have honest testing done.

A citizen’s first response to this incredibly asinine proposal is:  Are you nuts?

I checked out your bio Mr. Penner, and yours Mr. Bell and failed to see any reference to either of you perhaps having any gardening or farming experience which leads me to assume (please forgive me for this assumption if it is not true) that you have relatively little if any interconnection to the earth.  My life’s experience includes organic gardening and I pride myself on keeping my land free of chemicals of all kinds.  I would hate to live next door to a toxic sludge disposal farm.  Wouldn’t you?  Or eat food from it.  Wouldn’t you?

While the proposal focuses on plant nutrients such as nitrogen, ash and lime which may be in the sludge, it rather tip-toes around the problem that these wastes contain unknown quantities of toxic “stowaways”; contaminants such as dioxin and heavy metals like arsenic, lead and mercury.  Do you really think it is wise to dispose of these toxins by mixing them into our farmlands and referring to them as “soil enhancement”? 

What this proposal tells the public is that industry may dispose of their hazardous materials as fertilizer, a cheap and unregulated means of disposal, eh?  How cost effective for them!

Quoting from “Fertilizer Hazardous Wastes in Fertilizer Threaten Farmers, Gardeners and Our Food Supply”, “Heavy metals and dioxins in fertilizers accumulate in agricultural soils, are taken up by plants and erode into surface waters.  Repeated applications of contaminated fertilizers put the integrity of our farmland and food supply in question.”

The Ministry of Environment’s Intention Paper – Response Form is very misleading not to mention downright oblivious as to how nature functions.  You cannot put a substance on or in the soil and expect it to stay put, it doesn’t work that way!  Question 2 Prohibitions to protect human health and the environment states that provisions would be made “including prohibiting application of any soil amendment that would:  1) result in leachate entering a well or stream 2) introduce unacceptable levels of contaminants into the terrestrial food web…”

Hello!  As soon as rainwater or irrigation water makes contact with the substance it leaches!  It’s like gravity.  Jump off a building, you drop like a rock.  The same law of nature applies here and your government can’t control that!  And, as for “contaminant limits in soil amendments”, do you have any idea how excessively expensive it would be to monitor and measure the contents in every truckload of sludge prior to it being dumped on farmland?  We know that won’t happen in your cost conscience style of governing.

If I critiqued the Intention Paper – Response Form I’d be at this letter all night.  The long and the short of it is not how sanitized the questions are but how morally ethical it is to dump poison on the land.  The short answer is it is not ethical, it is sheer madness!

This proposal is doubly outrageous as government has a duty to prevent harm, not add to the toxic burden.  Rather than assume the sludge is harmless until proven otherwise, government must practice the precautionary principle of “Do No Harm”, based on mutual respect rather than the bottom line profit margin of financial interests.

The goal of good government should be in promoting and establishing a healthy living environment which protects our natural resources and the health of our people, not to flirt with how close they can get to contaminating the earth from which we draw life itself. 

Certainly Mr. Penner and Mr. Bell your government is far from consistent when you preach healthy nutrition in the school system and a healthy lifestyle and in the next breath propose dumping industrial sludge/waste on farmer’s fields.  Just where do you think the healthy food comes from?

Using farmlands as disposal dumps for industrial hazardous waste is unacceptable.  When hazardous waste is used a fertilizer or “soil enhancement”, it allows industry to transfer their liability onto the landowner or farmer.  Rather than providing a cheap disposal method for these industries, government should be adopting a zero tolerance policy to keep toxins off our agricultural lands.

The highest regard must be made for those who may be affected and for our irreplaceable natural resources, not for those with financial interests.  Please choose correctly.

Rita Dawson, Ladysmith, BC V9G 1H5