Southgate Public Interest…

Southgate Public Interest Research Group: Regarding Draft Policy Changes on Certificate of Approval Process for Municipal Sewage Sludge The purpose of this letter is to respond to the Ministry of the Environment on behalf of the Southgate Public Interest Research Group regarding the draft policy to further deregulate application of municipal sewage sludge (a.k.a. beneficial biosolids) - by eliminating the Certificate of Approval process. First a note about S.P.I.R.G. Our mandate is to conduct and publish research on issues relevant to the public interest among the citizens of Southgate Township in Grey County. Our membership is deeply rooted in a rural community, and we have confidence in Ontario farmers to responsibly manage livestock manure application on their land. That said, we emphatically distinguish between the beneficial biosolids produced by cattle, pigs, and poultry - and the cocktail of household, institutional and industrial wastes that finds its way into municipal wastewater treatment systems. As such, our research leads us to oppose the proposed streamlining (relaxation) of regulation on land application of municipal sewage waste on the following grounds: Public Transparency: Sludge has been spread in Southgate with reported effects that range from the contamination of drinking water, offensive odours, stinging eyes, and serious and persistent illness. We are concerned that the reduced transparency of sludge-spreading under the Nutrient Management Act would provide less opportunity for people to protect themselves by either taking whatever measures they might to minimize their exposure to sludge once applied –or by urging their neighbor to forego this practice. Public Will: We have witnessed several delegations, and motions in council opposed to the practice of land application of municipal sewage sludge. Further de-regulation of the spreading of municipal sewage sludge runs contrary to the will of many people in the affected areas. Public Health: Our investigation of the practice of farmland application of municipal sewage sludge led us to seek the opinion of a health-care expert. Dr. William Plaxton is Director of Critical Care Medicine for Grand River Hospital in Waterloo Region, and is also the Ministry Lead for Waterloo-Wellington Local Health Integrated Network (LHIN) for Critical Care. After investigating this issue in depth, Dr. Plaxton was unequivocal in his assessment of the infectious disease risks involved. This is an excerpt from his letter of opinion from June 2007: As responsible professionals, policymakers, and trustees of the environment, we must learn from our past in order to avoid any recapitulation of past tragedies. The current proposal to use human waste for fertilization purposes is in my opinion a willingness to flirt with immeasurable risk to human health and wellness and one which neglects our experiences with quite congruent situations from Walkerton and Kashechewan. In conclusion, we believe that this is a public interest issue. It seems clear that the proposed policy change would reduce public oversight and give more sway to private interests in a socially divisive and environmentally controversial practice. We understand that the legislative trend in Western Europe regarding the disposal of municipal sewage waste is progressively restricting land application in favour of alternatives with less risk to public health. With the growing evidence that land application of municipal sewage sludge will someday be seen as reckless endangerment, it seems an odd time indeed to deregulate and allow market forces to decide where sludge goes down in secret.

[Original Comment ID: 104743]