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Two Letters on Land Application of Biosolids in the CRD by Philippe Lucas of Biosolid Free BC/Peninsula Biosolid Coalition:

Dr. Harris, Chair Plant, CRD Board, and the PBC and other key stakeholders,

I’m reaching out today on behalf of Biosolid Free BC with a note of thanks for the updates that have been made to the ancillary material informing the CRD consultation on the long term management of biosolids, and to request a few additional related updates. 

Despite modest improvements to the information provided, the FAQs and background material still fail to factually reflect 1) the history of the CRD ban on land application; 2) the current state of regulations around the globe; or 3) the contemporary scientific understanding of the harms associated with land application, so we’d like to request that the associated material be updated for the sake of accuracy and to promote informed decision making for those interested in this issue and participating in the consultation and survey.

1. As it stands, under the heading “Why is the CRD the only regional district in BC to ban land application?”, the response is: “In 2011, prior to introducing wastewater treatment in the core area, the CRD Board of Directors passed a biosolids land application ban based on the concerns of members of the public.”

Unfortunately, that is entirely inaccurate. As one of the CRD Director that collaborated on the drafting of the original motion, I can share that the initial CRD Board motion in 2011 and follow up Board motion that maintained the ban in 2013 were not the result of “concerns of members of the public”, but rather through the efforts, lobbying and support of local, regional and provincial environmental and agricultural organizations such as the Dogwood Initiative, the Georgia Strait Alliance, the Sierra Club of BC, the Island Organic Producers Association, the Island Chef’s Collaborative, the Farmlands’ Trust, and the Peninsula and Area Agricultural Commission, all of whom submitted written letters of support and strongly advocated for the ban on land application.
 

Of course, the minutes from those meetings would confirm those assertions, and would also highlight significant opposition to land application by Indigenous Bands like the Dididaht Nation as communicated at the time by Director Mike Hicks, as well as the legal analysis provided to the CRD by the UVic Environmental Law Society (attached) that definitively found that there was significant risk of legal liability for the CRD and any farmers and home-owners that might apply biosolids resulting from harm to the environment, animal and human health, and negative impacts on property value. 

All of which I’m sure you would already know, Dr. Harris, since you, Mrs. Hutchinson and some of the current Directors were also involved in those early discussions as well. If the goal is to be transparent , accurate and infromative on this issue, it would also be worth mentioning that despite dozens of committee and Board votes on this matter over the past 10 plus years, the Board has ALWAYS voted to maintain the ban on land application, with modest amendments to allow disposal at Hartland and shipping to Cassidy for land application there. 

Could you please ensure that this section is updated accordingly? Thanks.

2. Under the heading “How are biosolids used by others?”, the response given is: “Biosolids are commonly used within communities across Canada, and the globe; mostly land-applied to add nutrients and organic material back to the land, but also thermally processed and some landfilling.

All other large communities in BC (e.g. Kelowna(External link), Kamloops(External link), Comox(External link) and Metro Vancouver(External link) primarily utilize their biosolids as fertilizer or in compost.

There are currently no full scale advanced thermal facilities processing biosolids in Canada. The CRD is advancing a pilot project utilizing thermal technologies to process biosolids; however, if it proves successful, it will be several years before it can be utilized fully as a permanent facility in the capital region.”

This unfortunately is inaccurate, and fails to tell the full story. Within North America, there are many large and small municipalities that have banned the land application of biosolids, including the entire state of Maine, which banned the spread of any biosolids that contained PFAS due to contamination of milk and animals, and impacts on the environment and farm industry. In fact, the State has allocated $100 million dollars to assist farmers that have had to destroy their livestock due to PFAS contamination. Additionally, New Hampshire, Massachusetts and New York have all severely restricted land application due to concerns over PFAS contamination of drinking water, and in the US trends are moving away from land application and towards thermal destruction.

Finally, as the attached EU report from 2023 makes clear on p. 13, Germany, the Netherlands, Slovakia, Belgium and Austria have banned the land application of biosolids due to concerns of environmental contamination, preferring waste-to-energy projects instead. Japan has also opted for the same strategy in order to protect its agricultural base and environment. 

Rather than portraying the CRD ban as a stand-alone out of sync with the rest of the world, isn’t it more accurate to share that we’re at the forefront of an ever-increasing trend moving away from land application due to proven environmental and public health impacts, and towards waste-to-energy along with some of the world’s most environmentally progressive countries and regions? 

We look forward to seeing this section updated to more accurately reflect current trends in North America and around the world.

3. Recent staff presentations at the CRD and the information provided in the FAQs seem to suggest the potential harms of land application of biosolids are somehow debatable or non-existent, stating “Biosolids do not pose a risk to human health or the environment when they are produced, distributed, stored, sold or used in accordance with all of the requirements in the Organic Matter Recycling Regulation“, and that the only risk would be through mismanagement. 

As I have noted on a number of occasions, there are literally thousands of peer-reviewed publications highlighting the risks of land application due to the presence and dispersal of microplastic, PFAS, pharmaceuticals and other toxic compounds. However, I know that it is challenging for staff and Board members to wade through dozens of academic studies, and staff have unfortunately resisted calls for an independent evaluation of the current state of knowledge. Therefore, I’d like to call attention to a recent scoping review specific to the hams of land application of biosolids published in the peer-reviewed journal of Environmental Health in 2023 (attached). 

For those who may not know, a scoping review is a scan of the biggest and best studies and academic publications sources, with the goal of determining the current state of the science. In this publication by Pozzebon and Seifert titled “Emerging environmental health risks associated with the land application of biosolids: a scoping review”, the authors reviewed, assessed and compiled the findings of 172 top-tier studies examining potential environmental and health impacts associated with the REGULATED application of biosolids on land, and here’s what they found (please note that these quotes are taken directly from the publication and are unaltered, and all the data is fully referenced in the attached publication as well):

Microplastics:

• …microplastic concentrations were significantly correlated with biosolids applications.
• …studies have repeatedly detected microplastics at significant distances from their source of origin and at higher elevations, indicating their susceptibility to becoming airborne.
• Inhalation of microplastics is associated with oxidative stress in lung tissues, along with general inflammatory responses in airways and bronchi and chronic exposure can lead to death.
  

PFAS:

• A more recent study investigating the impact of land applying biosolids on the occurrence, concentration, and distribution of PFAS in soils and groundwater detected PFAS in all near surface soil samples (< 30 cm below ground surface), in more than 83% of soils between 30 and 90 cm below ground surface, and in the immediately underlying groundwater.
  
• PFAS can cause adverse health impacts even at ultra-low concentrations, and have been found to bioaccumulate in animals and humans in lung, kidney, liver, brain, and bone tissue.
• PFAS exposure is associated with reproductive and developmental, liver and kidney, and immunological effects, as well as tumors in laboratory animals. In addition, inhalation of PFAS can cause acute lung toxicity and inhibit lung surfactant function
  

Pharmaceuticals and personal care products 

• Studies investigating the occurrence and distribution of pharmaceuticals in biosolids following wastewater treatment indicate that pharmaceuticals find their way into the environment mainly through the land spreading of biosolids.
• Preliminary evidence has suggested potential risks that are similar to those observed in aquatic species and these compounds have been implicated as potential contributors to diabetes, cancer, fertility decline, and a host of other environmental and public health issues.
• Ultra-low nanogram per liter (ng/L) concentrations have exhibited impacts to both humans and aquatic organisms, including hormonal interference in fishes, genotoxicity, carcinogenicity in lab animals, endocrine disruption, and immune toxicity.
  

Conclusions 

• The authors indicate that the precautionary principle needs to be applied consistently to ensure a clean and healthy environment for future generations, which is also why further studies on the risks induced by emerging pollutants, due to their specific environmental behavior, toxicity, and impacts on the environment and human health become essential.
• Biosolids, in their current form, have often been referred to as an organic waste to be recovered and recycled. But given the presence of contaminants that originate from both domestic and industrial wastewater sources, is that really the appropriate designation in law or regulation?
• As a society, if we fail to take definite policy actions to modernize environmental standards that pertain to the land application of biosolids, and continue to land apply layer upon layer of these complex mixtures of pollutants to our soil without adequate public health protections in place, and without regard to the long-term environmental consequences, we may potentially cause irreversible damage to the very soils we use to grow our food and to our surface and ground water that sustain life. 

Since time is of the essence re. this consultation and the associated discussions and debate regarding how to best handle the region’s biosolids, the CRD and public should certainly use the latest and best available science where available to inform our decision-making about both short and long term plans. 

Thankfully, as an alternative to an independent review of the available data, we can access and cite the findings of this comprehensive academic scoping review to ensure we’re sharing accurate and unbiased information with the region’s elected officials, policy-makers, residents and farmers, and we look forward to seeing the CRD consultation website quickly updated with this “state of the science”, which represents society’s best and most up-to-date understanding of the potential harms associated with the land application of biosolids. 

Thanks and best regards,

Philippe Lucas, PhD

Biosolid Free BC/Peninsula Biosolid Coalition



Another letter on the subject by Philippe can be read here:

LETTER: Spreading biosolids would put region’s environmental health at risk – Peninsula News Review