West Bench water and the RDOS: Some frequently asked questions and answers

The West Bench water system upgrade is a complex project with multiple competing technologies, numerous political and governance issues, and tens of millions of dollars in capital and operating costs at stake.  It is not surprising therefore that much confusion surrounds the issues.  What follows are my responses to some of the most common questions I am hearing.  Contact me if you have any questions or use the comment feature at the bottom if you like.

The RDOS is not the water supplier for the West Bench.  Why is the RDOS involved in this project?

The short answer is that the RDOS is the local government for the West Bench and might be responsible for some or all aspects of West Bench water in the future.  It is natural that the RDOS would take an interest in any infrastructure it might be asked to take over on the dissolution of the West Bench Irrigation District.

Some background: “Irrigation districts” and “improvement districts" are legacy governance structures that exist at the pleasure of the Province.  The boards of these limited-purpose entities are staffed by elected trustees.  Smaller boards rely on external consultants and contractors for technical expertise and operations. Given the increased complexity of infrastructure issues, the Province is attempting to phase out irrigation and improvement districts in favor of municipal and regional governments.  This makes some sense to me: municipal and regional governments generally have the continuity, scale, and scope to deal with complex infrastructure problems.  For example, the RDOS runs multiple water systems, employs full-time engineers and accountants, has existing relationships for audit and legal advice, and so on.

So, when the West Bench Irrigation District is phased out, an established government will have to take over.  Since the West Bench lies entirely within Area F of the RDOS, the RDOS is the natural candidate.  The water infrastructure could also be transferred to a municipal government such as Penticton through an extraterritorial service agreement.  But it is important to recognize that West Bench is not part of the City of Penticton and cannot vote in the city's elections. Residents in an extraterritorial service thus forfeit a certain amount of democratic representation (more about this below).

Does the RDOS support UV or filtered water?

The RDOS has no opinion.  The RDOS provides services when asked to do so by residents.

My own personal view, based on my analysis of the engineering reports, is that it should be possible for the City of Penticton to supply filtered water to West Bench cheaper than the RDOS can treat water using UV.  This is because the Penticton water treatment plant has already been built and has (or soon will have) excess capacity.  In short, I think filtered water from Penticton could be the cheapest and most reliable alternative.

However, a caveat: Recognize that to beat the cost of UV treatment, Penticton is going to have to tolerate a certain amount of free-riding on its past infrastructure investments.  This might not fly.  My analysis of this issue is here.

I do have strong opinions about extraterritorial service (in which the City of Penticton owns and controls the piping and infrastructure on the West Bench).  I think this is a recipe for future conflict.  The basic issue is that West Bench residents will cede control of strategic infrastructure to a municipal government in which it has absolutely no voice.  Moreover, there appears to be no provision for something like a utilities commission in the extraterritorial proposal. [Update 29 Jun 09: distribution systems that span political boundaries have become a problem in Vernon; to avoid these problems, Kelowna is trying to hang on to its irrigation districts.  See one of many news stories on this ongoing debate here.]

My preferred alternative is the original bulk water arrangement.  It provides all the health and cost benefits of partnership with Penticton without the political risk.  The basic idea is that the RDOS buys filtered water from the City of Penticton and establishes service areas along the existing West Bench and Sage Mesa water system boundaries.  Each system is run separately by the RDOS on behalf of its residents.  Residents who are unhappy about the manner in which their infrastructure is operated, maintained, replaced, etc. have direct recourse through their elected Area Director.

Didn’t the RDOS refused in 2007 to work with the WBID?

Here is the situation:

1. The RDOS Chair sent a letter to the WBID on December 5, 2007, that stated:

[the RDOS Board] resolved to work with the [WBID] when the WBID agrees to comply with the conditions set out by the Provincial grant application and the Provincial requirements to utilize the grant.”

The WBID was then asked to contact the RDOS

“[…] if or when there is a change in the current position of the WBID to comply with this grant.  In this event, the RDOS would once again commit its full staff resources to deliver a cost effective water improvement project to West Bench residents.”

2. As far as I know, the WBID has never formally alerted the RDOS of its intention to comply with the Province’s requirements for receiving water upgrade grants.

3. All this is water under the bridge because the WBID has since informally acknowledged that it has little choice but to comply with the terms of the grants (otherwise there is no money).  For example, it acknowledges that the WBID will “cease to have a function [for water delivery]” in its October, 2008 newsletter.

4. As the newly elected Electoral Director for Area F, I have been committed since Day 1 to work the WBID.  I have also called on RDOS staff from time to time to help clarify issues.  In short, the RDOS is still working on West Bench water.

5. The RDOS has not been called on by the WBID to provide any new information or provide any support since 2007.

[Update: 08 May 09]  I asked the RDOS Board to rescind Motion B536/07E in its May 7th meeting because I percieve the motion to be barrier to open communication between the RDOS and the WBID. The Board agreed.

Is the Ultra-Violet treatment option dead?

According to October, 2008, WBID newsletter, the UV option is still being considered by the WBID.  This was re-affirmed in the April, 2009, WBID newsletter.  Mitch Moroziuk, Director of Development and Engineering Services for the City of Penticton, stated that his proposal to the WBID regarding extraterritorial service would include an analysis of the UV option (ostensibly based on the 2007 Associated Engineering report on West Bench treatment options).

In all the plans I have seen for UV treatment of West Bench water the RDOS is the supplier.

Could the new funding for the Penticton extraterritorial option be applied to a RDOS-operated UV treatment plant instead?

It is impossible to answer this with any certainty. Maybe, maybe not.  An email sent to the WBID on 20 April, 2009, by the Ministry of Community Development states the the following:

If the project were to revert to the original project under the BCWIIP, it is conceivable that the approved BCF grant could be redirected the the RDOS (instead of the City) with the cooperation/agreement of the City. However, since BCF is a joint federal - provincial program, and since the original project is not the preferred project, this may be more difficult.

Why won’t proponents of UV treatment let it die?

The 2007 report from Associated Engineering provided cost estimates for a number of different water treatment options for the West Bench.  The cost of each option was expressed as an average increase per household.  The summaries of these costs are provided here.  Note that two basic scenarios are considered in the two tables:

  1. Maximum funding (two-thirds) from senior level of governments for all alternatives.
  2. The original $2.35M grant only.

In its April, 2009, WBID newsletter, the WBID points out that the cost of option 2-UV is more than $1000 per year per household.  The exact number in Table 2 is $1,171.  However, what the WBID neglected to mention in its newsletter—and I think this is an important oversight—is that the cost of the Penticton option (Option 1) under the same conditions was significantly higher: $1,856.  Indeed, even if the Penticton option received full-two thirds funding whereas the UV option received only the original grant, the Penticton option would still cost significantly more (see Table 1).

I think this is why there are “UV zealots” out there. The UV options are significantly cheaper than the Penticton option in all scenarios.

Of course, the Penticton options (Option 1 and Option 7) in the Associated Engineering report are different from what is currently (mid 2009) being proposed by the WBID.  The 2007 options were bulk water arrangements in which the RDOS bought filtered water from the City of Penticton and distributed it on RDOS-managed pipes and infrastructure.  The new Penticton option is extraterritorial service, in which the City of Penticton owns and manages all West Bench water infrastructure.

But here is a critical point: Extraterritorial service does not make the Penticton option cheaper.  The cost of the Penticton options in the Associated Engineering report are dominated by the annual cost of Penticton’s water treatment plant allocated to the West Bench.  The details of this allocation are provided in Enclosure 1B of the Associated Engineering report (p. 68).  The annual operating and “capital service fees” that the City of Penticton proposed to charge for bulk water delivery (column U, p 71) are roughly $400K per year.  This is just for water treatment.  For comparison, total annual operating costs for Option 2-UV are less than half this amount.

In summary, extraterritorial service does not change Penticton’s average cost of providing filtered water.  However, whether Penticton decides to recoup its average cost is a separate issue addressed in this posting.

Stantec Engineering concluded that tying into Penticton’s water treatment would be the most cost-effective option.  Is this true?

The 2006 Stantec Engineering report was based on high-level conceptual design.  Its estimates did not include, for example, the cost that the City of Penticton might charge for water or any contribution to capital costs the City might require.  As noted above, these costs are significant.

Stantec acknowledges the limitations of its conceptual analysis (p. 4.1) and recommends further analysis and negotiation to specify cost-sharing arrangements with the City of Penticton.  Hence the 2007 Associated Engineering report.  The Associated Engineering report reviewed all prior studies (p. 16) in order to provide more specific analysis of the various options.

I am not sure why the April, 2009, WBID newsletter quotes an engineering report that has clearly been superseded and which, by its own admission, is missing entire categories of cost.

Will Interior Health (IHA) permit us to have UV? Won’t they simply make us switch to filtration in the future?

IHA has a draft “filtration deferral” policy (see p. 74 of the Associated Engineering report) that allows water suppliers to install a secondary treatment system other than conventional filtration and thus defer filtration indefinitely.  According to the recommendations of Associated Engineering in its 2007 report:

“Okanagan Lake water is currently being supplied and treated successfully with ultraviolet in nearby communities. We believe that the Filtration Deferral is a reasonable option for this project.”

According to Appendix B-2 the draft filtration deferral policy, “water suppliers must be prepared to install filtration” in certain circumstances, such as a waterborne illness outbreak.  Much was made of this condition for deferral at the recent WBID AGM.

I guess what residents have to ask themselves is: What is the probability of a waterborne illness outbreak in the West Bench water system?  To my knowledge, the WBID and Sage Mesa systems have operated for generations without a single outbreak.  This provides some evidence regarding future likelihood.  And all the alternatives include a new, deeper intake in the lake (where the water quality is more predictable) and a second level of treatment.  So the future risk is likely to be lower than any estimate based on historical data.  Finally, all level of governments (including the Okanagan Basin Water Board, on which I sit) are working towards improving source water quality by, for example, moving more residents near reservoir lakes to community sewer systems instead of septic systems.

Appreciate that many jurisdictions in BC are facing the same issue and are claiming the right to defer filtration in favor of UV treatment.  The basic argument is that the health benefits of filtration over UV treatment do not appear to justify the differences in cost.  That is, the economics are clear, but the science is not.  For example, the report of the 2008 Ministerial Technical Advisory Committee (BC Ministry of Health) concludes (p. 6):

Evidence and feed back, based on consultation with personnel from a number of health regions and water purveyors within B.C., accompanied by relevant national and international documentation, leads the TAC to consider a broader drinking water issue - whether filtration of surface water supplies should be mandatory. All parties involved agree that protecting public health is essential, consequently disinfection is essential. The majority of parties agree that a multiple barrier approach, to assure drinking water safety, is sound. Therefore, the way forward, to resolve the debate about mandatory filtration for surface waters, is to explore how the commitments to protect public health and implement an effective multiple barrier approach can be adapted to the specific circumstances which exist in British Columbia. Fortunately, recent advances in water treatment technologies, particularly the demonstrated capabilities of UV disinfection, offer the potential to develop equally effective alternative means to conventional filtration for achieving the agreed upon public health protection goals.

Clearly, IHA and the some folks in the Ministry of Health are not singing from the same songbook. I expect the Province to step in a attempt to settle this issue in the coming year.

[Update: 13 May 09] The Southern Interior Local Government Association (SILGA) has recently sent a letter to the Premier asking about the uneven requirements for water filtration in BC.  The letter asks:

The SILGA membership would appreciate receiving an explanation outlining why each Health Authority has the ability to set individual standards and why the standards are not consistent across the province. Further, we would like to know how our members are supposed to fund systems that have to provide treatment to standards higher than those imposed in rest of the province.

Comments

The City of Kelowna, which processes Okanagan Lake water using UV, has posted its "filtration deferral" documents: http://www.kelowna.ca/CM/Page3393.aspx

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