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Letter to Public Services and Environment Departments 26th February 2006 Dear Sirs Thank you for the opportunity to comment on future waste water treatment options. As previously identified in our letter to the Public Services Department of 17th February 2005, Friends of the Earth Guernsey believe that a distributed system of Sequencing Batch Reactors is the preferred waste water solution for Guernsey, starting immediately with the Creux Mahie. The current policy of connecting West Coast properties to the Belgreve pumping station is not a cost effective proposal bearing in mind that after the expenditure of £10 million, the associated road works, pumping stations and ongoing pumping costs, no sewage will actually have been treated. Friends of the Earth have examined the proposals put forward by Mr Roy Bisson, and are in complete agreement with his argument on the treatment options and associated costs. The Public Services and Environment Departments need to proceed with urgency together with Environmental Health to develop the legislative and regulatory framework to enable communities such as estates and clos, larger organisations and institutions such as hotels, schools and office complexes to install their own compact SBR (or similar) sewage treatment units. This should be combined with legislation to allow similar developments to install water recycling facilities, which we understand the Water Board have been resisting for some years. We do however believe that a benthic survey should be included within the Environmental Impact Assessment, as to date only computer modelling of our actual discharges has been done, and that several years ago. We are keen to see controls on the type of chemicals, oils, heavy metals and other toxins that are discharged to the marine environment, and would urge the relevant departments to take a more pro-active approach to banning the use of toxic chemicals in the Island while sea discharge is still our disposal method. In this regard we would congratulate the Water Board section of Public Services for producing an excellent guide to water supplies and discharge. However, this has not been distributed throughout the Island, and not everyone who received it has read it. If education on what can and cannot be put down the drains is not effective, then steps must be taken to prevent the most pervasive chemicals from coming into the Island when their only disposal route is our coastal waters. Addressing the programme to connect 90% of Islanders to the main drain, Friends of the Earth would suggest that the priority for sewerage connection should focus on those areas where properties are below sea level or in flood plains and are most severely hit by the problems of water ingress in their cesspits. Many households are having to have their pits emptied twice a week because they are in low lying areas. These surely should be the priority areas for main drain connection. In respect of charging, the group would agree that one charge covering
water use and disposal seems to be an equitable system. However the Public
Services Department has not detailed how this could be made fair to people
who have paid substantial amounts to connect their properties to the main
drain, or to people who will continue to have cesspit emptying charges
because the main drain option is not available to them. Any system of
charging must include rebating options to ensure that everyone is treated
fairly. As with all utility services (e.g. gas, electricity, telephone
etc) Friends of the Earth are strongly opposed to 'standing charges',
which increase the fixed costs and discourage the 'polluter/user pays'
principle, as low-level users end up paying a higher charge per unit than
a heavy user, because the fixed costs are spread over fewer units. Fixed
costs mean that reductions in water usage then don't yield a proportional
reduction in bills for people on low and fixed incomes. Yours faithfully Michelle Levrier |