This is a follow up amendment to my initial post about the value wines. I am including some other wines I felt were very worthy of buying, including some more expensive ones, plus some comment on the show.
The following are the wines I tasted that I thought bring excellent quality and price ratio. These are some I liked that won't break the bank, but bring some "real wine" to your table.
HENRY LAGARDE CAB SAUVIGNON*
Article Number:1013433
$18.80
ARGENTINA (real wine, Cab S with tannins, acidity to age for <$20)
FOURNIER URBAN UCO TEMPRANILLO
1010838
ARGENTINA
$14.49 (great fruit nose, rewarding smooth drinking red)
DISTANT LAND MERLOT MALBEC
1013587
Price:$23.79
NEW ZEALAND (balanced tannins, solid red)
CATALAN EAGLE ORGANIC GARNACHE VIOGNIER*
1013639
SPAIN
$16.99 (crazy good nose, nice clean white wine)
FAMILIA ZUCCARDI Q MALBEC, 2009 and CATENA MALBEC 2009
1006724 and 1004863
$24.99
ARGENTINA A great take on the Malbec made for steak wine. Perhaps a bit more edge than the Catena Malbec 2009 (also recommended, at $24.79) Buy them both, choose the one you prefer.
VEGA MORAGONA VINAS VIEJAS, 2008
1013621
$17.80
SPAIN Hard to beat on price, this wine, from just outside the Ribera del Duero region brings a lot of complexity, class, and value. It's little brother, the basic Tempranillo, at $13.99 is a great every day quaffer bistro wine (1013620).
Here are some remaining wines I tried and liked and thought were decent value, for those who spend more on wine.
PALACIO VILLACHICA 5T, 2008*
DOC: Toro
Article Number:1013623
Price:$29.99 Varietal:TEMPRANILLO
Country:SPAIN Classy use of oak, easy drinking red, will age but drinking OK now.
BLACK HILLS CHARDONNAY, 2009*
1012548
$33.99
BRITISH COLUMBIA Just enough oak, I thought. Warm climate Chardonnay but retaining acidity. Jason Priestly apparently owns part of this, and because of him, I had to put up with a TV light in my eyes on Saturday while pouring next door. He did show up to pour a few glasses for an NSLC staffer who was suitably tall and gorgeous (way taller than him, BTW) but I saw him coming and left.
BODEGAS CATENA ZAPATA, ALTA CHARDONNAY, 2008*
1009626
$41.29
ARGENTINA One of the wines that won an award (for what those are worth at this show) and this was totally deserving. New World does Burgundy, and does it well. A total value for those who are buying wine over $30 a bottle. Delicious.
PETALUMA COONAWARRA, 2008
1013603
$54.99
AUSTRALIA After wading though I don't know how many Shiraz wines that all tasted the same, with only minor variations of tannin, and sugar, I hit a real wine. Yes, it's $55, but at least it shows that when they try, they can make a wine that actually has some acidity and might pair with protein. It was tasty, layered and complex. I am betting it will age very well.
A note on Australia -> I am not in love with the bulk of the wines coming out of here, still. Some movement to cooler climate regions is encouraging, and I've recently had totally delicious, amazing things. The show, however, was more focussed on selling the popular goop that, well, sells. That is why the NSLC do the show, to sell wine. Not to educate us, and rarely to let us near something new and cutting edge.
This year, the show was focussed on Australia. Every year since they were forced to move to an earlier time slot, the NSLC have lost the interest of the northern hemisphere wine regions because their winemakers and managers are all in the middle of harvest, and our own are getting ready for it. Wine is, after all, supposed to be an agricultural product, not an industrial one.
At the show there was a huge Australian section, and it was packed with people acquiring heat stroke. It was a sauna. My ventures into the sweat zone were limited. I did try, but only found two I'd own, and I bought one of them.
It would be nice to get this show back in line with the right time of year for the wineries, and the other three big shows in Atlantic Canada, especially the New Brunswick show. Then we might see our French, German, Italian, Spanish, Portuguese and Austrian winemaker friends again.
The reality is that the best wines in the world are still being made in France. There, I said it.
Here are the French wines that were really good, and I thought provided good value.
BOUCHARD PERE ET FILS, BEAUNE MARCONNETS, 2008
1013829
$48.49
FRANCE, BURGUNDY, RED So you say you like Pinot Noir. Well, try this. This is Pinot Noir.
CLOS DE LA BARONNE, MEURSAULT, 2008*
1013780
$47.29
FRANCE, BURGUNDY, WHITE So you say you like Chardonnay. Well, try this. This is Chardonnay. A monopole, from an producer whose reputation, and wines, are on the start of an upswing. I predict in 5 years, this same label will be $75
CAMILLE CAYRAN ANTIQUE CAIRANNE*
1013809
FRANCE
$26.79 (I think you have to pay at least this much to get good red Rhone, and here you do.)
Two California wines that showed the Americans are responding to the anti-goop movement in the wine world.
SONOMA-CUTRER SONOMA COAST CHARDONNAY, 2009
1009253
CALIFORNIA
$31.99 Not all California Chardonnay tastes like fake vanilla and a carpentry shop.
GREG NORMAN SANTA BARBARA PINOT NOIR, 2008
1013542
CALIFORNIA - YES, CALIFORNIA
$30.79 Not for everyone, but it's Santa Barbara Pinot, and not a bad version. I wanted to not like it, but just like the Chardonnay that the great white shark's company had out in our market the past two years, it rang true to me.
And now for Italy. What can I say? Probably the best wines at the show, and the most great to very good wine as well. But I was struck with the similarity of so many of the plus $20 wines I tasted. Super Tuscans, Super Venetians, Modern Barolos and Barbarescos, New World Style Sicilians and Southern Italians....
What do you do when your climate allows you to make almost anything, and your competitor is getting 50 Euros for his Sangiovese if he piles some Merlot in it? Or when your most expensive wine is made from Merlot? Or when your newly hired Australian winemaker takes your new stainless steel winery and uses your Nerello Mascarese or Aglianico and turns it into a Shee-raz lookalike that wine writers of dubious foreign origin melt over?
Italy is the new Australia. And it's out of synch with the style and direction modern wine is moving in. I tasted about 20 Italian wines. I bought three. The rest? I have pretty good taste memory. They were all very good (except the corked one - ever notice how European visitors to these shows can't detect corked wine? haha) but they run into one another - a pool of common style and, dare I say it - taste. When your Barolo starts to taste like a Californian Pinot Noir, I say you have problems, and that you should not be allowed to call it Barolo any more.
It was so busy, I could not really get into the wines I wanted to, though. There were some Friulian wines, a bunch of southern stuff, and some interesting Ripasso things.
I bought three wines, all oddities of a sort. Two reds, of which one was wonderful. The other I bought to show to people that I am right with my theory. Guess which is which.
But first, a white.
KELLEREIKALTERN GEWURZTRAMINER*
Article Number:1013867
$32.99
ITALY Italian Gewurtraminer. Hell yeah. Northern Italy does not have the climate to do whatever the heck it wants. So they make what grows in their climate and has for a while. Traminer and its variants in white.
OTTOVENTI NERELLO MASCALESE*
Article Number:1013872
$43.79
ITALY Not 100% sure this is wine or a port style. I do love that the NSLC site says the grape is traditionally grown on the slopes of Mount Edna. Very "Far Side".
NINO NEGRI SFURSAT VALTELLINA DOCG*
Article Number:1013866
$45.29
ITALY My favourite wine at the medal winner pre-tasting for licensees. Barolo but not. Gattinara but not. Nebbiolo it is. But from a relatively obscure DOCG. Has all the smoke, tar and floral notes that some other Barolos at the show have forgotten how to display, or have hidden in the scent of new oak barriques.
DISCLAIMER WINES
I poured for Chateau des Charmes all four shows, on and off. They brought two of their most interesting wines to the market, and they are now available in many stores (Joe Howe, Portland Street etc.). The Chardonnay Musque (1013144) is a fun wine, from a single clone of Chardonnay that is highly aromatic, almost muscat-like. It makes you think you're going to get a sweet wine, but then it tastes clean and crisp. A lot like our best NY Muscat wines here in NS, and some Alsace wines. At $19.99 it's a treat, and a fun thing to share with friends.
Their Gamay Noir Droit (1013145) is the same price, but I think of it as a more serious wine. As a lover of Cru Beaujolais, I know that Gamay can make great wine. Niagara Gamay has always impressed me, from just about any producer, but CdC do it as well as, and often better than anyone. That may be due to this mutation of Gamay that appeared in their vineyards, and that they now "own" the clone of. The Droit, or upright clone. The wine is deeper, and darker than many other Gamays, and reminds one of Crus known for ageing, like Morgon, Cotes de Brouilly and Chenas. I have successfully aged this wine almost 10 years, but you can drink it now. I think Chateau des Charmes may have been the only winery at the show that "owned their own grape".
GEEK WINE ALERT!!!
My geek wine, the one you want to spring on people when they come visit, not a "value wine" at all, but this is the first Australian Zinfandel I've seen. Tastes about like what you'd expect. Big stewy fruit but with spicy character and alcohol. States only 14% but I think higher.
GROOM BUSH BLOCK ZINFANDEL*
1013615
AUSTRALIA
$39.79
Finally, remember, these are just what I liked. I can guarantee you that we do not share the same palate, nor will we like or dislike the same wines. I know at least one person who will agree with me on most of the wines above, but violently disagree with me on a few of them. But it's not about what I think, or like, it's about your preferences. I think you will enjoy these wines, and perhaps they might lead you into new places to explore in the wine world. But really, all I'd really like you to do is never stop trying new things. Just keep having fun with it.
* I bought this wine.
Saturday, October 01, 2011
Thursday, September 15, 2011
Saint John and its Lethal Parking Policy - The Tyranny of Small Decisions
I was visiting Saint John this summer, as a tourist, attending a great music event on their waterfront, and staying with a good friend right in their downtown. Following is a record of email exchanges between me and various City of Saint John staff surrounding a parking ticket I received for not driving my car when I had parked it in a paid parking area, and left it overnight, as I was patronizing several of their great pubs and restaurants.
Me to the general parking email address on the city's website:
Their initial response:
And me, again:
And here are the photos....
A view as you walk past...
When you actually leave the sidewalk and go looking for it..... Oh, wait, what's that peeking from behind the flag?
Oh, and it wasn't me that damaged that sign, I am not surprised others have gone before me.
And the dirty culprit itself, just like the speed limit sign behind the bushes in Butt-F Mississippi....
The monolith responds.... (knowing I live in Halifax)
And I return fire, twice:
No response... I try again.
So, he actually must have had to walk by for some other reason, because he went and realized that there were flags blocking the sign.
Of course, I went by before the flags were down, this bit of logic escapes Mr. Bureaucrat.
So I try to be nicer:
And I try even more to be nice.... (this was probably a bad move, I think he interpreted it as his winning in some way)
Maybe I was getting somewhere? Is there hope for logic in a backwards little place like this?
No, it goes up the line to an even bigger bureaucrat. I mean, these people cannot grasp that they are supporting entrapment and encouraging drinking and driving. It's like the emperors are all running around naked and everyone knows they are too stupid to believe you when you tell them, so they let them run around naked and laugh at them behind their back.
The grand poobah speaks. Note, his closure time for the store is different from what the other guy told me, reinforcing my point, but he then expects me to have gone back to the street and check for no parking signs I might have missed due to flags, I guess. What a total dumbass. And this is the boss.
By this time, I have decided it's not worth the effort. They are beyond help. This was like dealing with a lost tribe of people who are living in the 50's. But I decide to give it one more shot....
In the end, I just paid the ticket. But I had written to the councillor for the area about my experience, as well as emailed back and forth with one of the local business owners. All the business owners know how stupid the parking commission is, but they have been in Saint John so long, they also know how ineffective and plain lazy their municipal government is. They have a budding jewel of a downtown happening, but they also have a parking policy that is brutally inhospitable to the people who they expect to come spend money to keep it viable.
I wrote out this experience in clearer language to the local councillor, Mel Norton. He seems to be a bright guy who might actually grasp the connection between the parking policy and their high drunken driving rate.
Here is his response. I sense some hope here, but really, this is a one company, blue collar town, and it may always be.
And my last words....
Me to the general parking email address on the city's website:
I drove to your city from Halifax yesterday. Found a pay and display parking spot downtown right by my friend's apartment. Pay and display said I had to pay until 6 pm. Street sign said no overnight parking when snow removal ban is in effect.
I paid up till 6 and went out to Market Square to the Alehouse, then to Salty Jam, happinez and then Big Tide. I spent about $200 in your economy. (I was paying for someone else too).
As you might presume, I was not driving anywhere after that.
This morning I have a ticket on my car for what is, essentially, doing what you really should be encouraging visitors to do. That is spend money, support local festivals, patronize your food and beverage industry and not drive drunk and kill your children.
If this city is to grow out of its backwardness one small initial step you can easily take is to bring your parking policies into this century.
I can't help but wonder how many people's deaths and injuries this policy is indirectly responsible for. Surely you want to do everything you can to encourage people to cab home from your nice, vibrant downtown.
The fact is, many if not most people will choose to "take a chance" on getting caught over the certainty of a $20 ticket. I know this is illogical, but they HAVE been drinking, haven't they?
I was not confronted with that choice. I saw no sign (I parked on Germaine right beside the pay and display kiosk and went into a building right there) as they were at opposite ends of the block. And besides, as a Professional Engineer who does urban design work I can't really be faulted for assuming the city is sophisticated enough not to have a policy that encourages drinking and driving (do you even want people living in the downtown?). The lovely state of the downtown certainly sends a misleading message. It implies this is not a backward little town but then this parking policy proves the reverse.
The real cost of this policy can't be measured in ticket revenue. It is measured in the damages to people's lives it most definitely contributes to. if you can't see that you are in the wrong job.
Saint John really should change this. How many deaths have you had from drinking and driving where the fatal trip initiated downtown after the bars closed? One is too many.
Their initial response:
This by-law (No parking on metered streets from 12 midnight to 7 AM) has been in place for a number of years, so that the city can plow the streets in the winter months and clean the streets in summer months or to do repairs to streets. We do advertiser that all of your lots are free after 6 PM, and are free all weekend and holidays. There is the Coast Guard lot (Water Street), Sydney Street Lot (behind Services New Brunswick), Trinity Lot (behind the Royal Bank).
After looking at the circumstance concerning ticket number AA850883, that this is a valid ticket. A sign was posted just forward of the vehicle. I will hold payment at $20.00 until July 15.
If you have any question please contact me.
xxxx
Supervisor
And me, again:
No there is no sign "just forward of the vehicle". You are wrong. There is a winter snow clearing sign. So you are willing to lie for $20?
Much further down the block there is a sign but I had to actually seek it out.
Not only was it almost a block away, it was hidden by a flag. I sent a photo the next day after I started wondering why I saw no signs. I looked.
The sign was not clearly posted and the ticket is therefore invalid. So enough with the cut and paste answers. Get those flags out of there and you are technically correct though there should still be information proximal to the pay and display kiosk.
I have more pics if you like.
There was no way for me to know that your antiquated and backwards parking policy existed (it kills your kids). This makes Saint John look like one of those Southern good ol' boy towns with the speed limit sign behind a tree, just for tourists.
If I lived there I'd presumably have seen the advertising about parking lots. But then I'd still have to drive under the influence to get to a lot. There was no visible sign saying I could not park overnight in a location I would be expected to see it.
As I said in my follow up email, please advise me when the ticket has been cancelled. You can't hide signs and collect fines.
My next emails are to the councillor and the media. I'll be blogging about your pro-drinking and driving policy anyway. Twitter is already awash in this. And I'll be emailing your local MADD chapter as well.
I'd like to save lives even if Saint John doesn't care.
And here are the photos....
A view as you walk past...
When you actually leave the sidewalk and go looking for it..... Oh, wait, what's that peeking from behind the flag?
Oh, and it wasn't me that damaged that sign, I am not surprised others have gone before me.
And the dirty culprit itself, just like the speed limit sign behind the bushes in Butt-F Mississippi....
The monolith responds.... (knowing I live in Halifax)
If you do not agree with this answer. You will be issued a summons and on the summons will be a court date that will allow you to tell your side in front of a judge and he will make the final call.
xxxxx
Supervisor
And I return fire, twice:
Now I know why I did not know there was no parking overnight. A store has flags up on the sidewalk. One of them obscures the only sign I would have had a chance to see. I walked right down this sidewalk after parking. Do you see the sign in the attached photo?
Hint. It is right behind the Union Jack.
So I never had a chance to know. Being a visitor to the city. I had no idea what the ticket was for because the no parking order was improperly posted.
As long as the flag obscures the sign none of the tickets on Germaine are legal.
Please send me confirmation that ticket AA850883 is cancelled.
Thank you.
I would advise you to have the store remove the flag.
No response... I try again.
Go to Germaine Street yourself. Park right by the Kiosk across the street from the used record store.
Pay for your parking.
Walk towards King Street. (I turned down a one way street)
Tell me if you see a sign. There is one, but unless you look for it, knowing it has to be there, you don't see it.
I was a visitor to your city. I am home in Halifax. You act like one of those sheriffs in a two cent town in Mississippi, hiding your signs behind bushes and wanting money from out of towners.
So, he actually must have had to walk by for some other reason, because he went and realized that there were flags blocking the sign.
After looking into the circumstance concerning ticket number AA850883 that this is a valid ticket.
Different stores along Germain Street will put flags out that the city will give them to display on the street. I have talk to the owners of Bustin's Furniture and they stated that they take the flags down at 17:00 every day, and on the day in question they do not have a written down, but they are sure that the flag was taken in.
If you have any question please contact me.
xxxx
Supervisor
Of course, I went by before the flags were down, this bit of logic escapes Mr. Bureaucrat.
So I try to be nicer:
I believe you that the flag may have been taken down around 5. I parked just before 5 and walked down to Market Square. The place was open when I went by.
And I try even more to be nice.... (this was probably a bad move, I think he interpreted it as his winning in some way)
I know you are just an employee doing what you are told. Saint John would probably go bankrupt without parking fines..
All I can tell you is that as a visitor to your city, I left feeling that I really was jerked around, and conned into a ticket. I felt like you did not really want me to visit.
If that is consistent with the direction you get from your superiors, well, so be it. But there was no way for me to have avoided that ticket.
The flag probably covered the sign. It was not that close to where I was parked anyway. There was a sign further back, but I was looking for the street number. I parked, paid until 6, knocked on the door, got my friend and we walked down to begin the evening. From that point on, I was either going to have to drink and drive or get a ticket. It is simply a sucker punch play unlike any other I have encountered in North America. Italy has something like it, mostly in the corrupt towns in the south, with the clocks on the windshield that they don't tell tourists how to use. But this is Canada, we expect a fair system, not one designed to fleece us.
The downtown business owners I have spoken with all hate it, partly because it discourages business, but also because it makes people more likely to drink and drive (no intelligent person disputes that), increasing their liability as the establishment that may have last served the drunk driver.
And if you really do clean the streets every night, allow me to advise you that your money would be far better spent repairing the many many potholes throughout the downtown. I certainly experienced those as well.
Maybe I was getting somewhere? Is there hope for logic in a backwards little place like this?
This ticket complaint is still under review, with the your additional commons (sic).
xxxx
Supervisor
No, it goes up the line to an even bigger bureaucrat. I mean, these people cannot grasp that they are supporting entrapment and encouraging drinking and driving. It's like the emperors are all running around naked and everyone knows they are too stupid to believe you when you tell them, so they let them run around naked and laugh at them behind their back.
The grand poobah speaks. Note, his closure time for the store is different from what the other guy told me, reinforcing my point, but he then expects me to have gone back to the street and check for no parking signs I might have missed due to flags, I guess. What a total dumbass. And this is the boss.
I have reviewed the comments outlined in your e-mail. For your information, the furniture store has permission and places the flag on the street each morning and removes the flag around 6pm each day. The sign basically states that there no parking from 12midnight to 7am and the flag does not cause a problem because it is removed long before the parking restriction comes into effect.
The parking ticket # AA850883 is a valid ticket and I will hold the fine amount at $20.00 (discounted fine amount) until July 28, 2011 and if the fine remains unpaid after that date the ticket will continue to increase. Because the discounted period has expired, the ticket cannot be paid online at the discounted amount and you must call our office at 506-xxxx or my direct line number xxx and advise my staff we are holding the ticket amount at $20.00 until July 28-11.
Please call me at xxxx if you have any questions.
Sincerely,
xxxx
General Manager
Saint john Parking Commission
By this time, I have decided it's not worth the effort. They are beyond help. This was like dealing with a lost tribe of people who are living in the 50's. But I decide to give it one more shot....
How was I supposed to know?
A visitor comes to your city. Parks. Pays as per the apparent signs. Returns to their car to find a ticket. It turns out the only chance he would have had to see a sign was when it was covered by a flag permitted by the city.
That is entrapment. A dishonest practice.
I would like to think you'd treat your guests better.
In the end, I just paid the ticket. But I had written to the councillor for the area about my experience, as well as emailed back and forth with one of the local business owners. All the business owners know how stupid the parking commission is, but they have been in Saint John so long, they also know how ineffective and plain lazy their municipal government is. They have a budding jewel of a downtown happening, but they also have a parking policy that is brutally inhospitable to the people who they expect to come spend money to keep it viable.
I wrote out this experience in clearer language to the local councillor, Mel Norton. He seems to be a bright guy who might actually grasp the connection between the parking policy and their high drunken driving rate.
I am writing out of a serious concern for the people of your city, and, indeed, the surrounding county, regarding the City of Saint John's downtown (I think you call it Uptown) parking policies.
I came to the City this weekend for Saltyfest, and to visit friends and family. I think your City is becoming one of the best places in Atlantic Canada to visit for the food, pubs, and local music and art. The small, but vital downtown "entertainment district" has grown in a very organic manner and shows other cities, such as mine (Halifax) how older buildings can be integrated into a commercially successful and active urban neighbourhood. BUt you have one major problem.
With any western european culture comes the presence of establishments that offer alcoholic beverages, some as bars, and some as part of a dining experience. Saint John is better than most at this, and really "plays above its weight" in the quality thereof. It is getting so good that people come there for it, and they spend a lot of money in those businesses.
At the same time, a downtown like that also attracts the element of the local population who enjoy the social aspects of eating and drinking out, including the local college and university populations.
In any city in the world with self knowledge and sophistication around the consumption of alcoholic beverages, there is an acceptance that in some cases, people will drink more than they should before driving. This act has become socially unacceptable in our society, (well, at least in Halifax). Here we do whatever we can to offer people an alternative to drinking and driving. The busses and ferries now run later than they used to, there is, during holidays season, Operation Rudolph, where for a charitable donation, someone will come and drive your car home, with a friend following to take them back for another trip. And, most importantly, overnight parking - leaving your car at a valid spot instead of driving home, is encouraged. The next morning, if it is a working day, you will even see the ticket patrol giving a bye to cars until 9 am so people have time to get them before work.
We know this policy makes a big difference in people's decisions as to whether or not to take the chance and drive when they are close, or even when they know they are over the legal BAC limit. Many people, working with the fuzzy logic of their obvious state, weigh the two options - the risk of a ticket on the car, vs. the risk of getting the car home while drunk.
In Halifax, that's an easy decision. No chance of a ticket, vs. a chance of getting caught. In Saint John, however, you remain in the dark ages. That same decision is: Certainty of getting a $20 ticket, vs. a good chance of not getting caught. (you see my little play with the drunken logic there?).
The odd, ill conceived policy had the minor impact of totally annoying a tourist to your city who ended up spending over $400 in your economy, by having him find a ticket on his windscreen for doing what is expected of you in most North American cities - leaving one's car in a parking space until the morning. And that has issues that matter a lot to your downtown businesses and to the reputation of your city in the region (yes, frankly, it makes you look like idiots), but it pales in comparison to the real damage it does.
I'm 53. I am a responsible drinker, probably like you. Once I have had two drinks, I stop if I am driving. The third drink is, for me, a trigger that the car stays where it is. My brother, a wine and beer writer, is pretty well the same. We don't drive when we are even close to the legal limit. But you see, we have learned how to drink by now. I'd guess that many of the younger people I saw out in Saint John that evening have not learned how to drink responsibly yet.
When faced with the decision above, I'd take the $20 fine (even though I had no idea it existed and feel exactly like a tourist caught in a good ol' boy southern town's pet speed trap with the old sign behind the tree gag). But I bet many of those other cars that were still on the street when I crashed at my friends' place on Germaine Street were not driven away by sober people.
You see, this policy encourages people to drink and drive. I enquired the next day and found, much as I expected, that you have experienced a number of accidents and even a couple fatalities resulting from trips that originated at night from your downtown.
Now I am not saying the City is totally liable for those deaths and damage, but I am saying this policy likely contributed to them. And you have to ask why you even have a policy that:
1) Discourages people from leaving their car on the street overnight when they are drinking;
2) Discourages people from staying longer at local businesses and spending more;
3) Is slanted to harm tourists and visitors to the city, compared to residents, who might better know about the policy and apparent parking lot options; and
4) Discourages anyone from wanting to live in the downtown. One thing we know about the economic success of modern cities is that getting people to live downtown is paramout to their success. Who would want to live there when you can't have someone drop in and stay over, let alone park your car or rental car on the street in front of your place overnight?
One reason staff keep faling back on to support this policy is for street cleaning and maintenance. This is unheard of - closing an entire downtown from on-street parking every night to allow for the chance that city staff will be working overnight? Everywhere else, we either have designated nights (Monday or Tuesdays usually) when this happens on different streets for cleaning; and signage and meter hoods are used for specific construction related maintenance activities. You current policy cuts off its nose to spite its face.
But the main concern here is that you are actively enforcing a parking policy that is almost certainly indirectly responsible for people's deaths. In trying to not break one law, people may choose the risk of breaking an even greater one, even if only to relocate their car to a parking lot.
My own ticket concerns are from both the perspective of feeling like I was conned, because the sign that was supposed to inform me of the policy (if I had actually believed it) is impossible to see on Germaine Street as one of three flags put out on the street by a shop down Germaine, past which I walked to the Alehouse after parking, obscures the sign, sometimes wrapping around it.
So my tourist experience of Saint John's downtown was: find my friends apartment, park in front at a pay and display (I overpaid with a toonie for time from 5 to past 6), go out of the town with her and other friends and drop $200 that night. Wake up to find a ticket on my window for a "mystery reason". Look for signs saying I could not park, not find any until I peered under a Union Jack hiding the sign, and then realize your city encourages drunk driving with this policy.
I complained to the parking email person and today got a cut and paste answer (I know it is a cut and paste answer, because my brother showed me the email he got for a very similar complaint before, which I had no idea about). I then went out and spent another $160 in your economy shopping for records, beer and wine. Then I went out to lunch at Brit's where I spent another $26. Over the day, I also put another $7 in various pay and display parking kiosks and meters in your city.
The next day I came into town and survived the rain for the songwriters circle in front of the Alehouse and had lunch there (another $25) and eventually went out to Rothesay with my brother.
And for this reasonably large personal injection into your economy I get a $20 ticket for not drinking and driving, because of a hidden sign, when I had overpaid already for my parking spot. I have to tell you, Moncton kicks your ass at this game. They want my business, not my parking fines. It really soured my visitor experience. I feel like I've been ripped off and am significantly less inclined to come back to the downtown.
But mostly, I am concerned about the drinking and driving aspects of the by-law. You really need to have it changed.
Here is his response. I sense some hope here, but really, this is a one company, blue collar town, and it may always be.
Thank you for taking time to articulate so well this concern. This is an issue I really had not heard of or considered - so thank you for making me aware of it and giving the perspective of a visitor.
I'm sorry it has taken me so long to respond.
Thank you for visiting the Uptown and enjoying what is, in my view, the only urban experience in NB! Slowly but surely investments in the heritage district is paying dividends. Thank you for spending your hard-earned dollars here! It is so appreciated.
I agree with what you have said - I think this policy should be changed. If I understand the core of your concern would it be:
Parking tickets should not be issued to vehicles left parked overnight on city streets within the Uptown business district?
Would it make sense to have the exemption only apply on certain nights of the week, e.g. Friday-Sunday?
And my last words....
In my opinion, Saint John's Uptown area has grown in a healthy, "organic" manner. As an occasional visitor to the City (since 1981 when I worked on building Market Square, right out of University), I have had the luxury of seeing this progression. I appreciate how it has not done a lot of the energy sapping "leapfrogging" that many similar places have fallen prone to, diluting the investment, and the audience. The core strength is excellent, I believe.
The level of sophistication in the businesses, in the private sector, is simply not matched by the Municipal Government policies that I was subjected to, and have heard from residents and business owners alike since my unpleasant experiences with the draconian parking policies.
To hear the Staff response to my concerns is to hear the voice of "that's just how we've always done things" - a sure and certain path to extinction. Change is good, when done right. Yes, change can be bad, but really, even bad change can be better than stagnation and death by entropy.
Here is the one main lesson I can offer you, based on 30 years of engineering and urban planning and design experience. You are not unique. There is nothing new under the sun. It has all been done before. You don't need to re-invent the wheel. You just need to climb out of the dark ages and into something approximating this decade. It's pretty easy, really. Find a similar size small city with a healthy downtown. See what they do. My guess is that they allow overnight parking until 9:00 AM every night except for one, which is posted, for street cleaning, usually during the early part of the week.
These cities will also have a healthy size residential population in the downtown. Do you have any idea how many Saint John residents are employed in the bar and restaurant business? It is a LOT. Affordable and higher end housing mixes are where it's at these days - all quality build, but in different unit sizes, so the smaller, bachelor apartments and one bedrooms can house students and the hospitality industry workers, while, in the same buildings, larger units attract urban professionals and retirees who often winter away. No ghettos, just a healthy mix.
But to encourage people to live in the downtown, there needs to be a system for those people to have access to guest parking, or even year round on street (some streets closed one night a week for cleaning and maintenance) with winter off-street options. Snow happens. We need to deal with it.
Recognizing that parking can be viewed in two ways - a short term thinker's "cash cow", or a long term thinker's "leverage", takes a degree of sophistication and intelligence that needs to exist anyway if Saint John is to not stagnate. The economic growth and subsequent tax revenue benefits from a healthy parking policy can far outweigh the restrictive, negative, and, frankly, petty means of generating funds that parking tickets to visitors and tourists represents. Vision is not some elusive rare thing - it is just common sense with an ability to imagine how things might be better.
Again, the biggest issue here is the reality of how this late night policy, when the streets are basically empty anyway, most certainly increases the number of people driving when they really shouldn't. City staff can make excuses all they want, but no reasonable person, who has ever had more than they perhaps should have to drink, can dispute the reality that people sometimes choose to drive because they will get a ticket if they don't move their car.
I would recommend that Saint John:
1. Simply not ticket vehicles between 5 pm and 9 am unless they are parked where they are in the way of a scheduled street cleaning, clearly posted, or blocking access or egress to an off street property or hydrant. (how much patrol staff time would this save?)
2. Advertise this in conjunction with an anti-drinking and driving campaign. "Leave Your Car when you Leave the Bar" (free slogan by me)
3. Initiate, for the 2011 Holiday season, Operation Rednose as done in Halifax (they did not invent it) - volunteer groups respond to a hotline - two people come out in a car, one drives your car home with you in it (puking only happens in the drunk's own car, which is good), the other follows to take the driver back to headquarters. This is done for a set fee (ask them about the fee structure) that goes to the charity they are volunteering through. It works great here. Some bars will even call them for you, let you put it on your tab, and they give the cash to the volunteers. (I HAVE SINCE LEARNED THAT THEY DO PRACTICE THIS - GOOD!!)
Ask my brother - I'm an optimist - I see the positive side of things. I am sure you can see how this can accomplish both the objectives of enhancing the business life and the entertainment quality in The Uptown, while at the same time really reducing the incidence of drunk driving in your community.
Responsible drinking is possible - as you now know, both my brother and I practice it regularly.
Every goal can be furthered by policies that make it easier to do the right thing than to do the wrong thing. Any policy that makes it easier to do the wrong thing is, by definition, a bad one. I'll just use one more cliché - you get more with sugar than you do with salt.
Regards, and good luck with this. It can really save people's lives.
Tuesday, July 26, 2011
Proposed changes to the Nova Scotia Environment Act - a Response
The Government of Nova Scotia has recently released "A discussion paper" describing their proposed direction in the next scheduled (or behind schedule) revisions and updates to the Environment Act. They have invited public comment. The paper can be found here: http://www.gov.ns.ca/nse/dept/docs/env.act.review.2011.pdf
This will be the third time I have responded to a request for public input, and, frankly, I am not expecting much. Mainly because the previous two times there was not one response, and none of the issues I identified were fixed prior to the proclamation of the revised Act. Including some very bad typos that actually changed the intent of the legislation for the bad, and were subsequently enforced as law by the Department. We have been conditioned to think of this Department and the term "Public Consultation" as mutually exclusive. Dealing with them day to day, we know they do not respect the public's interests, and their lack of attention to any responses, such as this one of mine, is simply normal behaviour from them.
So, with that deluge of optimism, let's begin! I am only reviewing this document, and by inference, the existing Act and Regs, from a perspective I know very well, that of how it works with the current administration of the on-site sewage disposal and small scale sewage treatment world. This is an area where I have practiced for almost 30 years.
To start with, the paper immediately points out the first of the Department's failings. An inability to comply with their own Act. First passed in 1995, and mandated to be updated every 5 years, it took them 12 years to do the first two updates, although I seem to recall one of those was not really a formal update - perhaps I am incorrect on that. Later on in the document, will we find them asking to have this requirement waived or changed, giving them less public scrutiny and obligation to respond to how the world changes? I wonder.... I mean, who wants to be held accountable every 5 years!!
The current Act states it's purpose very clearly, and it has long been my opinion that the Department has been abdicating part of its responsibilities under it. Here is what the Act is supposed to be all about:
Purpose of Act
2 The purpose of this Act is to support and promote the protection, enhancement and prudent use of the environment while recognizing the following goals:
(a) maintaining environmental protection as essential to the integrity of ecosystems, human health and the socio-economic well-being of society;
(b) maintaining the principles of sustainable development, including
(i) the principle of ecological value, ensuring the maintenance and restoration of essential ecological processes and the preservation and prevention of loss of biological diversity,
(ii) the precautionary principle will be used in decision-making so that where there are threats of serious or irreversible damage, the lack of full scientific certainty shall not be used as a reason for postponing measures to prevent environmental degradation,
(iii) the principle of pollution prevention and waste reduction as the foundation for long-term environmental protection, including
(A) the conservation and efficient use of resources,
(B) the promotion of the development and use of sustainable, scientific and technological innovations and management systems, and
(C) the importance of reducing, reusing, recycling and recovering the products of our society,
(iv) the principle of shared responsibility of all Nova Scotians to sustain the environment and the economy, both locally and globally, through individual and government actions,
(v) the stewardship principle, which recognizes the responsibility of a producer for a product from the point of manufacturing to the point of final disposal,
(vi) the linkage between economic and environmental issues, recognizing that long-term economic prosperity depends upon sound environmental management and that effective environmental protection depends on a strong economy, and
(vii) the comprehensive integration of sustainable development principles in public policy making in the Province;
(c) the polluter-pay principle confirming the responsibility of anyone who creates an adverse effect on the environment that is not de minimis to take remedial action and pay for the costs of that action;
(d) taking remedial action and providing for rehabilitation to restore an adversely affected area to a beneficial use;
(e) Government having a catalyst role in the areas of environmental education, environmental management, environmental emergencies, environmental research and the development of policies, standards, objectives and guidelines and other measures to protect the environment;
(f) encouraging the development and use of environmental technologies, innovations and industries;
(g) the Province being responsible for working co-operatively and building partnerships with other provinces, the Government of Canada, other governments and other persons respecting transboundary matters and the co-ordination of legislative and regulatory initiatives;
(h) providing access to information and facilitating effective public participation in the formulation of decisions affecting the environment, including opportunities to participate in the review of legislation, regulations and policies and the provision of access to information affecting the environment;
(i) providing a responsive, effective, fair, timely and efficient administrative and regulatory system, recognizing that wherever practical, it is essential to promote the purpose of this Act primarily through non-regulatory means such as co-operation, communication, education, incentives and partnerships, instead of punitive measures. 1994-95, c. 1, s. 2; 2006, c. 30, s. 1.
I always like to point out the inclusion of the phrases "socio-economic well-being"; "sustain the environment and the economy", "linkage between economic and environmental issues", "encouraging the development and use of environmental technologies, innovations and industries", and, of course, the final clause: "providing a responsive, effective, fair, timely and efficient administrative and regulatory system, recognizing that wherever practical, it is essential to promote the purpose of this Act primarily through non-regulatory means such as co-operation, communication, education, incentives and partnerships, instead of punitive measures. "
I like to look at these, because these are the parts the Department has basically chosen to ignore over the past 10 or more years. They have completely turned their administrative backs on any care for the public's "socio-economic health". A repeated and common mantra we hear regularly from NSE officials is "the cost is not my problem". To find anyone in that Department who can grasp any issue related to linkages between economic and environmental issues is rare. Maybe they are closeted away on Terminal Road somewhere, but we never see them. The only linkage to the economy with NSE we can demonstrate is how they damage it, without a commensurate benefit to the environment.
The mandate to encourage environment technologies is, in my experience, laughable. Or sad. If anything, the opposite occurs, as it is pretty well impossible to establish a new idea here. When I, and my partners, attempted to do so years ago, this same Department funded another company to copycat our product and attempt to patent-break it!
Currently, there are three "approved" technologies using peat to filter on-site sewage disposal effluent. Department policy has resulted in each of them having their own different siting, construction and approval requirements. One of the systems is so restricted by how NSE allows it to be used, that its practical application is essentially non-existent, and probably completely non feasible for its owner.
As for a fair and timely process, well, consider this: When one engineer went on vacation last summer in Bridgewater (and again this year), just from the files of my company alone, about 50 homeowners had to wait at least one extra month for an approval to install an on-site sewage disposal system, which they needed first, to get a building permit. This effectively halted all new home construction on the South Shore for over a month.
When we made this apparent to the MLA, and to the administrators in Halifax (none of whom know anything about septic system design) the response we got was to have NSE send one of their inspectors out on what seemed to be every one of our jobs, to try to find things we might have done wrong at one time, and to audit our old files looking for retribution. They then sought to actually charge us for making paperwork typos or engineering judgements that differed from their technicians' interpretation of their rules or policies (more on policies later), but had not even come close to causing any adverse effects. This is the kind of organization that is attempting to change their own legislation. This is how they work, with a totally self insulating, vindictive and often arrogant lack of concern for their primary mandate. They need to be obligated to greater responsibility towards the people of Nova Scotia, not less.
Their own staff recognize this problem - in their own recent employee survey, staff morale has dropped off the table since 2009, with the main cause being cited as a lack of clear direction and communication from their head office with respect to personnel issues, and direction on enforcement.
Embedded in this current discussion paper, albeit in nice words, is the removal of their obligations to act in an economic and socially responsible manner. Of course they want to be relieved of this obligation - they already consider it superfluous and demonstrate their disdain for the public on a regular basis.
So, to summarize. If you see anything in this discussion paper that involves giving this Department any more power or authority, or reduces their obligation to respect the socio-economic welfare of Nova Scotians, you will see something that should not be allowed to proceed. They have simply not demonstrated the maturity and good judgement to justify affording them any more trust to do the right thing than we would a large multi-national corporation. Their own people don't trust them to make good decisions, why should we?
Goal #1: Matching resource use to the level of risk to the environment and human health
Ooops!! What happened to socio-economic well being? Gone. They want to abdicate their responsibility to care about Nova Scotians.
Now in this section there are some good words, but take care - if they are no longer required to consider the economic implications of their decisions it won't make things worse, it will simply validate their current behaviour. And that is to not care a whit about what they do to a family's, or a company's, bottom line. They don't want to have to ever worry about that silly little money thing.
Understanding environmental risk requires an understanding of the science behind most of the environment features and functions that need to be protected, or enhanced. Let's take wetlands. There are many different types of wetland, each with their own environmental sensitivities, and resiliencies. Most are less sensitive to nearby development than open watercourses. Yet current regulations under the Act assign a greater importance to any type of wetland than even the most sensitive watercourse. This does not really communicate any confidence that the Department even understand what it is mandated to protect. Indeed, the focus on wetlands in Nova Scotia is like worrying about getting enough rain. We have a lot of land in Nova Scotia that currently meets the description of a wetland. The joke is that Shelburne County is now totally undevelopable.
The design of a single family home on-site sewage disposal system (septic system) is an interesting one. This is an important, Province-wide consideration, as about one half of all Nova Scotians rely on septic systems to treat their sewage. In some cases there is real risk. A badly designed or sited septic system can contaminate someone's well and make them sick.
In 1997, NSE went to a lot of trouble and expense to allow people with no engineering or public heath background to assess land, size lots, select septic systems, and locate them on those lots. NSE effectively used their powers under this Act to discourage the public from accessing the services of a professional who would presumably have some expertise in surface water flow, biology, sewage treatment and hydrogeology. Instead, they created a pseudo-trade of people they called "Qualified Persons Level 2" who NSE themselves then "qualified" - not any school, university or even existing industry association. NSE then actually created and funded a new Industry Association for this new group of pseudo-designers. One has to wonder what kinds of logistic gymnastics someone went through to demonstrate that they were satisfying any of their mandates under the Act by doing all this. Had they left the work to Professional Engineers, they would not need to worry about protecting the public good at all - Engineers are already so obligated by another Provincial Act. The economic benefit to the public would become clear soon enough. To hire one of the QP2 people to take care of your septic system only costs $500~$800, to hire an Engineer costs $1200~$2000. But to build an engineer-designed system usually costs about $3000 to $5000 less. But, you see, NSE do not care about your money.
Goal #2 Using resources more efficiently and effectively
One of the more obvious problems the Department has demonstrated in dealing with sewage treatment is a total ignorance of what other legal and technical jurisdictions already govern some of the spheres of work they are attempting to regulate. Of particular note is the Engineering Act, where the work of Professional Engineers is already regulated and governed. Only recently has NSE actually assigned an engineer to look after the on-site program, their division with the most employees and one that regulates how more than half of Nova Scotians manage their domestic waste. In case you did not know, we have not had a Chief Public Health Engineer in Nova Scotia in about 20 years.
Words like "a mandatory standard or code of practice" always sound good to people who never do the actual work. It makes them feel safe, when the reverse is usually true. In real life, these sort of things, developed in advance of doing the actual work, only apply to the average, normal occurrences. Many times a prescribed solution is not the best, and often causes more harm than good, because the situation encountered in real life does not fit well with the mandated solution that someone ass-u-me-d would fix everything.
Instead of being concerned about the intent of the Act (is our environmental, public health, and socio-economic well being really protected?) it is the process, the regulation itself, that is being protected by staff and their policy, not our environment. This problem is further amplified when such codes or practices are created by people who are not actually practitioners - and exacerbated when they are administered by lawyers. The actual goal - to reduce or eliminate adverse effects, is lost in the haze of bureaucratic protection of self developed policy. That's how it is now in the part of the Environment Act that we have to wrestle with daily. One engineer I know said to me recently that he felt like his entire engineering skill set and imagination was becoming dedicated to finding ways around the rules just to be able to serve people in the best way possible, rather than designing better ways to do it with Engineering thought and advancement of technology. This is depressing, really.
So, in the spirit of contribution, here is how NSE can truly match resources efficiently and effectively in the on-site sewage disposal and small scale sewage treatment business. Get out of the way of Professional Engineers who are trying to practice professional engineering. We are already regulated once, by a Act of the Legislature. Don't waste your own personnel resources subjecting us to a double jeopardy in our work. If we figure out a new way to prevent an adverse effect from occurring that saves the public money, let us be Engineers and apply it to the public good. If we mess up and cause an adverse effect to occur, then yes, we have a liability under the Environment Act, and possibly under the Engineering Act. If we make a typo on some form or drawing, but no harm ever happens to anyone or to the Environment, just go away. Mistakes happen on engineering drawings all the time, but we fix them. We are responsible for our work, we already have an Act that makes us so much more responsible than any subsequent piece of poorly written legislation you can dream up, you are wasting your staff time and public resources trying to regulate an already regulated group of people, and you are stifling our ability to serve the public. Our job is to help people. Let us do our job.
There - I just saved Nova Scotians about $500,000 a year in personnel cost.
The discussion paper talks about redefining the concept of an "adverse effect" in a manner that will eliminate any care for our reasonable enjoyment of life or property. This sends a clear message: NSE don't really care about you, and they don't care to be mandated to care about you. They'd really rather have this review never happen, and do whatever they pleased, even if it means we can no longer enjoy our property in a reasonable manner. The interpretation of "reasonable" is something we allow the courts to decide in most every other walk of life. Noise bylaws, for example. NSE are now trying to remove even the oversight of common law and decency from their obligations to us.
There is discussion about "round tables", "advisory committees" and the like. That's interesting... they even seem to think they may have value. My experience from having been on three of these in the past is that, with one exception, the NSE representative on the committees never showed up for a meeting. This includes one committee that had a great representation of all the industry stakeholders, and oversaw and directed much of the technical research and support that we now all use to design on-site sewage disposal systems in Nova Scotia. They stopped listening to the ideas coming from that committee so it simply disbanded. I believe it shows in the advancement of policy since then.
The next proposal is no surprise. NSE only want to have to be subjected to this horrid, distasteful public scrutiny every 10 years instead of every 5. From a technical perspective, in the past 10 years, the field in which much of my practice exists, and it is regulated by this Department, has radically changed such that they are about 6 years behind the times now. We are able to save people money and allow a much better, sustainable means of developing land, but this out of date, behind the times "authority" has not caught up to the private sector, and we cannot properly serve the public because our industry is hamstrung by an out of date, disinterested, and in many instances, unqualified bureaucracy. If NSE can't stay current with a review every 5 years, how can 10 year intervals represent an improvement?
Timelines for approvals are in some need of repair. In the part of the Act I deal with, it's random. On one application it's 2 days, then next it's 6 months. And this is sometimes just trying to get permission to fix a malfunction that is causing an ongoing adverse effect, so the bureaucratic delay actually causes that adverse effect to continue or occur.
Here's one suggestion that will fix most of this problem in the on-site business. Change to a notification process for engineering designs for single family on-site sewage disposal systems (NOT QP2 submissions, unless you rally want adverse effects). We can investigate, design, oversee and certify a system and then register it with NSE with as-built drawings, owner, PID, design notes etc. Variances would still need to be approved, but the worst case scenario would still be a working system protecting the environmental, public health and socio-economic well being of Nova Scotians, just maybe not always in exactly the same way that NSE's own (often less experienced) staff would have done the work. But there would be no adverse effects and the work would be done in a timely manner, under the supervision of a Professional. Remember, regardless of whether there is an Environment Act or not, we Engineers are still liable and obligated to do the work such that it protects all three of those things, including caring about what it costs someone (this obligation to care puts us in conflict with an otherwise uncaring NSE on a regular basis). We tend to regard any prescriptive parts of The Environment Act or regulations thereunder as unnecessary, because, when it comes to regulating Engineering Design work, they simply are. Give us the desired results, don't tell us how we achieve them. Define the problem, not the solution. The solution part is our job.
Goal #3 Strengthening protection for the environment and human health
I just noticed - the word used in the legislation is "human" health, not "public" health. I think NSE abhor the term "public". How can you argue that socio-economic well being, or "health" is no longer something to strive for in how the act is administered? This is the same ethos we now live with that has resulted in decisions by NSE that have put seniors into government homes early, when their families would have kept them in their home; threatened to take away property from families on which taxes have been paid for generations; and has been applied to pursue a dogged interpretation of regulations in a manner as punitive to people's economic well being as possible, with no care whatsoever as to a family's financial circumstance or social structure.
Much of these proposed changes around giving Inspectors more flexibility and authority sound just fine until you have to deal with some of the inspectors we now have. Not that they are not good people, they simply are under-educated and too inexperienced to make the types of decisions they are being asked to make. Many of the decisions that are made by NSE staff can easily be described as falling under the term "engineering judgement". Engineers don't allow graduates of a 5 year science based university program to make such judgements until they have been working under another Professional Engineer, and overseen by an independent mentor, for four years after they finish University. Yet we are expected to not question and accept orders from a recent graduate of a two year community college course in water resources? All too often, they know the letter of their law, but they might as well be asking water to flow uphill, they know so little about how things work and what the rules actually mean. Again good, well meaning people, but asked to do things they are not qualified or ready to do.
Goal #4 Correcting the errors and inconsistencies in the Environment Act
To do this properly would mean writing a totally new piece of legislation. The Regulations Respecting On-site Sewage Disposal need to be re-written, as well as the parts of the Act that prescribe specific numbers for areas. clearances etc. directly in a legislative document, such that it takes a Minister's signature to authorize even the smallest change to an otherwise arbitrary minimum lot area. Many many times a year, obvious common sense solutions that would harm no one and benefit all, are refused approval by NSE because they are very slightly under some hard and fast number that is written into the legislation and which NSE staff are too weak, or not empowered, to vary, even when it makes sense to. Common sense never gets a chance.
The biggest problems in the current legislation and policy are those that remove staff's incentive to care about the well being of the public and allow them some twisted interpretation to needlessly disenfranchise people. Some of my experiences with these decisions have felt like the Department (because it was not just one person) was acting out of pure spite and hatred toward an unsuspecting citizen. I remain appalled at some of them.
The Act clearly needs to properly allow for the inclusion of "engineering judgement" in cases where the Act or regulations made thereunder are unclear. Regulations can never anticipate every circumstance (there are ALWAYS grey areas), and in which of several directions a solution to an environmental problem can procede. That is what Engineering design and judgement is for.
Part II Should We Introduce Administrative Penalties?
And now, Part II, in which Franz Kafka and Joseph Heller are hired by Nova Scotia Environment to design a new enforcement system.
This part might bear the alternative title of "Because the charges we lay are almost never about any actual adverse effects, we never win in court, so we are going to replace the justice system with our own judgement!"
I love how this includes a point of discussion: "What are the benefits and drawbacks of this approach?" but then the drawbacks are never discussed. I guess they left that for me.
In short, this Department has not demonstrated the maturity, good judgement, and overall care for the people of Nova Scotia to be entrusted with even the level of authority they now have, let alone such an enhanced Draconian proposal as this could end up being.
Consider this. In the on-site business we work in, our current governance is as much about adhering to policies, thought up on an apparently random basis, by different staff members over the past 17 years, than it is about following the actual Regulations and the Act. This collection of policies, written up to address every little thing that has happened outside of the normal course of work over that time, is thicker than the regulations. Worse, once written and accepted by management, these policies then start to be applied broadly all over the Province to other situations where they really don't apply, were never intended to apply. To add to the inanity, they are blindly enforced if their enforcement stops something from moving forward, but never mentioned if they might enable something to happen. It's never about how to do it right, or do it better, it's about coming up with new ways to say no.
These ad hoc policies are not all in one place where you can find them, and sometimes we never know they exist until we cross some unpainted line. None of them were ever proclaimed by the legislature, yet it seems they are seen to hold the same force of law as anything that was. NSE already have the authority to make the rules up as they go! And they do. Several times over the past decade we have had an Application for Approval come back rejected because of a new policy about which we had not been informed. Just as if an RCMP officer told you you were speeding because the limit wasn't the posted 100 KM/hr, it was 80 KM/hr, but they had not yet changed the signs, and by the way, they lowered it because one little old man lost control of his car and now everyone has to slow down. With these proposed "Administrative Penalties", in addition to being able to make things up as they go, they also want the authority that would be equivalent to having that RCMP officer be authorized to take your money from you right there, by force if need be, and with no recourse!
They want to be judge, jury, and executioner. They cannot be allowed to escape the recourse of law, and access to justice for the people they want to punish.
Or wait, maybe Nova Scotia is now some third world state?
The Department simply do not have the technical and moral authority to handle that kind of responsibility. Then again, no one entity does. That is why we have Professional Engineers, and why we have a justice system. And why these proposed changes should not be allowed.
This will be the third time I have responded to a request for public input, and, frankly, I am not expecting much. Mainly because the previous two times there was not one response, and none of the issues I identified were fixed prior to the proclamation of the revised Act. Including some very bad typos that actually changed the intent of the legislation for the bad, and were subsequently enforced as law by the Department. We have been conditioned to think of this Department and the term "Public Consultation" as mutually exclusive. Dealing with them day to day, we know they do not respect the public's interests, and their lack of attention to any responses, such as this one of mine, is simply normal behaviour from them.
So, with that deluge of optimism, let's begin! I am only reviewing this document, and by inference, the existing Act and Regs, from a perspective I know very well, that of how it works with the current administration of the on-site sewage disposal and small scale sewage treatment world. This is an area where I have practiced for almost 30 years.
To start with, the paper immediately points out the first of the Department's failings. An inability to comply with their own Act. First passed in 1995, and mandated to be updated every 5 years, it took them 12 years to do the first two updates, although I seem to recall one of those was not really a formal update - perhaps I am incorrect on that. Later on in the document, will we find them asking to have this requirement waived or changed, giving them less public scrutiny and obligation to respond to how the world changes? I wonder.... I mean, who wants to be held accountable every 5 years!!
The current Act states it's purpose very clearly, and it has long been my opinion that the Department has been abdicating part of its responsibilities under it. Here is what the Act is supposed to be all about:
Purpose of Act
2 The purpose of this Act is to support and promote the protection, enhancement and prudent use of the environment while recognizing the following goals:
(a) maintaining environmental protection as essential to the integrity of ecosystems, human health and the socio-economic well-being of society;
(b) maintaining the principles of sustainable development, including
(i) the principle of ecological value, ensuring the maintenance and restoration of essential ecological processes and the preservation and prevention of loss of biological diversity,
(ii) the precautionary principle will be used in decision-making so that where there are threats of serious or irreversible damage, the lack of full scientific certainty shall not be used as a reason for postponing measures to prevent environmental degradation,
(iii) the principle of pollution prevention and waste reduction as the foundation for long-term environmental protection, including
(A) the conservation and efficient use of resources,
(B) the promotion of the development and use of sustainable, scientific and technological innovations and management systems, and
(C) the importance of reducing, reusing, recycling and recovering the products of our society,
(iv) the principle of shared responsibility of all Nova Scotians to sustain the environment and the economy, both locally and globally, through individual and government actions,
(v) the stewardship principle, which recognizes the responsibility of a producer for a product from the point of manufacturing to the point of final disposal,
(vi) the linkage between economic and environmental issues, recognizing that long-term economic prosperity depends upon sound environmental management and that effective environmental protection depends on a strong economy, and
(vii) the comprehensive integration of sustainable development principles in public policy making in the Province;
(c) the polluter-pay principle confirming the responsibility of anyone who creates an adverse effect on the environment that is not de minimis to take remedial action and pay for the costs of that action;
(d) taking remedial action and providing for rehabilitation to restore an adversely affected area to a beneficial use;
(e) Government having a catalyst role in the areas of environmental education, environmental management, environmental emergencies, environmental research and the development of policies, standards, objectives and guidelines and other measures to protect the environment;
(f) encouraging the development and use of environmental technologies, innovations and industries;
(g) the Province being responsible for working co-operatively and building partnerships with other provinces, the Government of Canada, other governments and other persons respecting transboundary matters and the co-ordination of legislative and regulatory initiatives;
(h) providing access to information and facilitating effective public participation in the formulation of decisions affecting the environment, including opportunities to participate in the review of legislation, regulations and policies and the provision of access to information affecting the environment;
(i) providing a responsive, effective, fair, timely and efficient administrative and regulatory system, recognizing that wherever practical, it is essential to promote the purpose of this Act primarily through non-regulatory means such as co-operation, communication, education, incentives and partnerships, instead of punitive measures. 1994-95, c. 1, s. 2; 2006, c. 30, s. 1.
I always like to point out the inclusion of the phrases "socio-economic well-being"; "sustain the environment and the economy", "linkage between economic and environmental issues", "encouraging the development and use of environmental technologies, innovations and industries", and, of course, the final clause: "providing a responsive, effective, fair, timely and efficient administrative and regulatory system, recognizing that wherever practical, it is essential to promote the purpose of this Act primarily through non-regulatory means such as co-operation, communication, education, incentives and partnerships, instead of punitive measures. "
I like to look at these, because these are the parts the Department has basically chosen to ignore over the past 10 or more years. They have completely turned their administrative backs on any care for the public's "socio-economic health". A repeated and common mantra we hear regularly from NSE officials is "the cost is not my problem". To find anyone in that Department who can grasp any issue related to linkages between economic and environmental issues is rare. Maybe they are closeted away on Terminal Road somewhere, but we never see them. The only linkage to the economy with NSE we can demonstrate is how they damage it, without a commensurate benefit to the environment.
The mandate to encourage environment technologies is, in my experience, laughable. Or sad. If anything, the opposite occurs, as it is pretty well impossible to establish a new idea here. When I, and my partners, attempted to do so years ago, this same Department funded another company to copycat our product and attempt to patent-break it!
Currently, there are three "approved" technologies using peat to filter on-site sewage disposal effluent. Department policy has resulted in each of them having their own different siting, construction and approval requirements. One of the systems is so restricted by how NSE allows it to be used, that its practical application is essentially non-existent, and probably completely non feasible for its owner.
As for a fair and timely process, well, consider this: When one engineer went on vacation last summer in Bridgewater (and again this year), just from the files of my company alone, about 50 homeowners had to wait at least one extra month for an approval to install an on-site sewage disposal system, which they needed first, to get a building permit. This effectively halted all new home construction on the South Shore for over a month.
When we made this apparent to the MLA, and to the administrators in Halifax (none of whom know anything about septic system design) the response we got was to have NSE send one of their inspectors out on what seemed to be every one of our jobs, to try to find things we might have done wrong at one time, and to audit our old files looking for retribution. They then sought to actually charge us for making paperwork typos or engineering judgements that differed from their technicians' interpretation of their rules or policies (more on policies later), but had not even come close to causing any adverse effects. This is the kind of organization that is attempting to change their own legislation. This is how they work, with a totally self insulating, vindictive and often arrogant lack of concern for their primary mandate. They need to be obligated to greater responsibility towards the people of Nova Scotia, not less.
Their own staff recognize this problem - in their own recent employee survey, staff morale has dropped off the table since 2009, with the main cause being cited as a lack of clear direction and communication from their head office with respect to personnel issues, and direction on enforcement.
Embedded in this current discussion paper, albeit in nice words, is the removal of their obligations to act in an economic and socially responsible manner. Of course they want to be relieved of this obligation - they already consider it superfluous and demonstrate their disdain for the public on a regular basis.
So, to summarize. If you see anything in this discussion paper that involves giving this Department any more power or authority, or reduces their obligation to respect the socio-economic welfare of Nova Scotians, you will see something that should not be allowed to proceed. They have simply not demonstrated the maturity and good judgement to justify affording them any more trust to do the right thing than we would a large multi-national corporation. Their own people don't trust them to make good decisions, why should we?
Goal #1: Matching resource use to the level of risk to the environment and human health
Ooops!! What happened to socio-economic well being? Gone. They want to abdicate their responsibility to care about Nova Scotians.
Now in this section there are some good words, but take care - if they are no longer required to consider the economic implications of their decisions it won't make things worse, it will simply validate their current behaviour. And that is to not care a whit about what they do to a family's, or a company's, bottom line. They don't want to have to ever worry about that silly little money thing.
Understanding environmental risk requires an understanding of the science behind most of the environment features and functions that need to be protected, or enhanced. Let's take wetlands. There are many different types of wetland, each with their own environmental sensitivities, and resiliencies. Most are less sensitive to nearby development than open watercourses. Yet current regulations under the Act assign a greater importance to any type of wetland than even the most sensitive watercourse. This does not really communicate any confidence that the Department even understand what it is mandated to protect. Indeed, the focus on wetlands in Nova Scotia is like worrying about getting enough rain. We have a lot of land in Nova Scotia that currently meets the description of a wetland. The joke is that Shelburne County is now totally undevelopable.
The design of a single family home on-site sewage disposal system (septic system) is an interesting one. This is an important, Province-wide consideration, as about one half of all Nova Scotians rely on septic systems to treat their sewage. In some cases there is real risk. A badly designed or sited septic system can contaminate someone's well and make them sick.
In 1997, NSE went to a lot of trouble and expense to allow people with no engineering or public heath background to assess land, size lots, select septic systems, and locate them on those lots. NSE effectively used their powers under this Act to discourage the public from accessing the services of a professional who would presumably have some expertise in surface water flow, biology, sewage treatment and hydrogeology. Instead, they created a pseudo-trade of people they called "Qualified Persons Level 2" who NSE themselves then "qualified" - not any school, university or even existing industry association. NSE then actually created and funded a new Industry Association for this new group of pseudo-designers. One has to wonder what kinds of logistic gymnastics someone went through to demonstrate that they were satisfying any of their mandates under the Act by doing all this. Had they left the work to Professional Engineers, they would not need to worry about protecting the public good at all - Engineers are already so obligated by another Provincial Act. The economic benefit to the public would become clear soon enough. To hire one of the QP2 people to take care of your septic system only costs $500~$800, to hire an Engineer costs $1200~$2000. But to build an engineer-designed system usually costs about $3000 to $5000 less. But, you see, NSE do not care about your money.
Goal #2 Using resources more efficiently and effectively
One of the more obvious problems the Department has demonstrated in dealing with sewage treatment is a total ignorance of what other legal and technical jurisdictions already govern some of the spheres of work they are attempting to regulate. Of particular note is the Engineering Act, where the work of Professional Engineers is already regulated and governed. Only recently has NSE actually assigned an engineer to look after the on-site program, their division with the most employees and one that regulates how more than half of Nova Scotians manage their domestic waste. In case you did not know, we have not had a Chief Public Health Engineer in Nova Scotia in about 20 years.
Words like "a mandatory standard or code of practice" always sound good to people who never do the actual work. It makes them feel safe, when the reverse is usually true. In real life, these sort of things, developed in advance of doing the actual work, only apply to the average, normal occurrences. Many times a prescribed solution is not the best, and often causes more harm than good, because the situation encountered in real life does not fit well with the mandated solution that someone ass-u-me-d would fix everything.
Instead of being concerned about the intent of the Act (is our environmental, public health, and socio-economic well being really protected?) it is the process, the regulation itself, that is being protected by staff and their policy, not our environment. This problem is further amplified when such codes or practices are created by people who are not actually practitioners - and exacerbated when they are administered by lawyers. The actual goal - to reduce or eliminate adverse effects, is lost in the haze of bureaucratic protection of self developed policy. That's how it is now in the part of the Environment Act that we have to wrestle with daily. One engineer I know said to me recently that he felt like his entire engineering skill set and imagination was becoming dedicated to finding ways around the rules just to be able to serve people in the best way possible, rather than designing better ways to do it with Engineering thought and advancement of technology. This is depressing, really.
So, in the spirit of contribution, here is how NSE can truly match resources efficiently and effectively in the on-site sewage disposal and small scale sewage treatment business. Get out of the way of Professional Engineers who are trying to practice professional engineering. We are already regulated once, by a Act of the Legislature. Don't waste your own personnel resources subjecting us to a double jeopardy in our work. If we figure out a new way to prevent an adverse effect from occurring that saves the public money, let us be Engineers and apply it to the public good. If we mess up and cause an adverse effect to occur, then yes, we have a liability under the Environment Act, and possibly under the Engineering Act. If we make a typo on some form or drawing, but no harm ever happens to anyone or to the Environment, just go away. Mistakes happen on engineering drawings all the time, but we fix them. We are responsible for our work, we already have an Act that makes us so much more responsible than any subsequent piece of poorly written legislation you can dream up, you are wasting your staff time and public resources trying to regulate an already regulated group of people, and you are stifling our ability to serve the public. Our job is to help people. Let us do our job.
There - I just saved Nova Scotians about $500,000 a year in personnel cost.
The discussion paper talks about redefining the concept of an "adverse effect" in a manner that will eliminate any care for our reasonable enjoyment of life or property. This sends a clear message: NSE don't really care about you, and they don't care to be mandated to care about you. They'd really rather have this review never happen, and do whatever they pleased, even if it means we can no longer enjoy our property in a reasonable manner. The interpretation of "reasonable" is something we allow the courts to decide in most every other walk of life. Noise bylaws, for example. NSE are now trying to remove even the oversight of common law and decency from their obligations to us.
There is discussion about "round tables", "advisory committees" and the like. That's interesting... they even seem to think they may have value. My experience from having been on three of these in the past is that, with one exception, the NSE representative on the committees never showed up for a meeting. This includes one committee that had a great representation of all the industry stakeholders, and oversaw and directed much of the technical research and support that we now all use to design on-site sewage disposal systems in Nova Scotia. They stopped listening to the ideas coming from that committee so it simply disbanded. I believe it shows in the advancement of policy since then.
The next proposal is no surprise. NSE only want to have to be subjected to this horrid, distasteful public scrutiny every 10 years instead of every 5. From a technical perspective, in the past 10 years, the field in which much of my practice exists, and it is regulated by this Department, has radically changed such that they are about 6 years behind the times now. We are able to save people money and allow a much better, sustainable means of developing land, but this out of date, behind the times "authority" has not caught up to the private sector, and we cannot properly serve the public because our industry is hamstrung by an out of date, disinterested, and in many instances, unqualified bureaucracy. If NSE can't stay current with a review every 5 years, how can 10 year intervals represent an improvement?
Timelines for approvals are in some need of repair. In the part of the Act I deal with, it's random. On one application it's 2 days, then next it's 6 months. And this is sometimes just trying to get permission to fix a malfunction that is causing an ongoing adverse effect, so the bureaucratic delay actually causes that adverse effect to continue or occur.
Here's one suggestion that will fix most of this problem in the on-site business. Change to a notification process for engineering designs for single family on-site sewage disposal systems (NOT QP2 submissions, unless you rally want adverse effects). We can investigate, design, oversee and certify a system and then register it with NSE with as-built drawings, owner, PID, design notes etc. Variances would still need to be approved, but the worst case scenario would still be a working system protecting the environmental, public health and socio-economic well being of Nova Scotians, just maybe not always in exactly the same way that NSE's own (often less experienced) staff would have done the work. But there would be no adverse effects and the work would be done in a timely manner, under the supervision of a Professional. Remember, regardless of whether there is an Environment Act or not, we Engineers are still liable and obligated to do the work such that it protects all three of those things, including caring about what it costs someone (this obligation to care puts us in conflict with an otherwise uncaring NSE on a regular basis). We tend to regard any prescriptive parts of The Environment Act or regulations thereunder as unnecessary, because, when it comes to regulating Engineering Design work, they simply are. Give us the desired results, don't tell us how we achieve them. Define the problem, not the solution. The solution part is our job.
Goal #3 Strengthening protection for the environment and human health
I just noticed - the word used in the legislation is "human" health, not "public" health. I think NSE abhor the term "public". How can you argue that socio-economic well being, or "health" is no longer something to strive for in how the act is administered? This is the same ethos we now live with that has resulted in decisions by NSE that have put seniors into government homes early, when their families would have kept them in their home; threatened to take away property from families on which taxes have been paid for generations; and has been applied to pursue a dogged interpretation of regulations in a manner as punitive to people's economic well being as possible, with no care whatsoever as to a family's financial circumstance or social structure.
Much of these proposed changes around giving Inspectors more flexibility and authority sound just fine until you have to deal with some of the inspectors we now have. Not that they are not good people, they simply are under-educated and too inexperienced to make the types of decisions they are being asked to make. Many of the decisions that are made by NSE staff can easily be described as falling under the term "engineering judgement". Engineers don't allow graduates of a 5 year science based university program to make such judgements until they have been working under another Professional Engineer, and overseen by an independent mentor, for four years after they finish University. Yet we are expected to not question and accept orders from a recent graduate of a two year community college course in water resources? All too often, they know the letter of their law, but they might as well be asking water to flow uphill, they know so little about how things work and what the rules actually mean. Again good, well meaning people, but asked to do things they are not qualified or ready to do.
Goal #4 Correcting the errors and inconsistencies in the Environment Act
To do this properly would mean writing a totally new piece of legislation. The Regulations Respecting On-site Sewage Disposal need to be re-written, as well as the parts of the Act that prescribe specific numbers for areas. clearances etc. directly in a legislative document, such that it takes a Minister's signature to authorize even the smallest change to an otherwise arbitrary minimum lot area. Many many times a year, obvious common sense solutions that would harm no one and benefit all, are refused approval by NSE because they are very slightly under some hard and fast number that is written into the legislation and which NSE staff are too weak, or not empowered, to vary, even when it makes sense to. Common sense never gets a chance.
The biggest problems in the current legislation and policy are those that remove staff's incentive to care about the well being of the public and allow them some twisted interpretation to needlessly disenfranchise people. Some of my experiences with these decisions have felt like the Department (because it was not just one person) was acting out of pure spite and hatred toward an unsuspecting citizen. I remain appalled at some of them.
The Act clearly needs to properly allow for the inclusion of "engineering judgement" in cases where the Act or regulations made thereunder are unclear. Regulations can never anticipate every circumstance (there are ALWAYS grey areas), and in which of several directions a solution to an environmental problem can procede. That is what Engineering design and judgement is for.
Part II Should We Introduce Administrative Penalties?
And now, Part II, in which Franz Kafka and Joseph Heller are hired by Nova Scotia Environment to design a new enforcement system.
This part might bear the alternative title of "Because the charges we lay are almost never about any actual adverse effects, we never win in court, so we are going to replace the justice system with our own judgement!"
I love how this includes a point of discussion: "What are the benefits and drawbacks of this approach?" but then the drawbacks are never discussed. I guess they left that for me.
In short, this Department has not demonstrated the maturity, good judgement, and overall care for the people of Nova Scotia to be entrusted with even the level of authority they now have, let alone such an enhanced Draconian proposal as this could end up being.
Consider this. In the on-site business we work in, our current governance is as much about adhering to policies, thought up on an apparently random basis, by different staff members over the past 17 years, than it is about following the actual Regulations and the Act. This collection of policies, written up to address every little thing that has happened outside of the normal course of work over that time, is thicker than the regulations. Worse, once written and accepted by management, these policies then start to be applied broadly all over the Province to other situations where they really don't apply, were never intended to apply. To add to the inanity, they are blindly enforced if their enforcement stops something from moving forward, but never mentioned if they might enable something to happen. It's never about how to do it right, or do it better, it's about coming up with new ways to say no.
These ad hoc policies are not all in one place where you can find them, and sometimes we never know they exist until we cross some unpainted line. None of them were ever proclaimed by the legislature, yet it seems they are seen to hold the same force of law as anything that was. NSE already have the authority to make the rules up as they go! And they do. Several times over the past decade we have had an Application for Approval come back rejected because of a new policy about which we had not been informed. Just as if an RCMP officer told you you were speeding because the limit wasn't the posted 100 KM/hr, it was 80 KM/hr, but they had not yet changed the signs, and by the way, they lowered it because one little old man lost control of his car and now everyone has to slow down. With these proposed "Administrative Penalties", in addition to being able to make things up as they go, they also want the authority that would be equivalent to having that RCMP officer be authorized to take your money from you right there, by force if need be, and with no recourse!
They want to be judge, jury, and executioner. They cannot be allowed to escape the recourse of law, and access to justice for the people they want to punish.
Or wait, maybe Nova Scotia is now some third world state?
The Department simply do not have the technical and moral authority to handle that kind of responsibility. Then again, no one entity does. That is why we have Professional Engineers, and why we have a justice system. And why these proposed changes should not be allowed.
Wednesday, July 20, 2011
The Four Red Herrings of Development
I've been around development projects since I was born, literally. My dad was a construction foreman when I was a baby, and sometimes he'd just stick me in the truck when he went out on the job sites. As I entered the business of engineering and planning, I always sought to understand the issues, and not simply react emotionally to a project. Or to others' impressions of a new project.
I've watched, read, practiced and observed for 30 years since I graduated as a young engineer, one who wanted to do things better in response to what I then saw as a growing problem with our environment.
Working as a consulting engineer, I almost always have ended up of the proactive side of the development debate - I've been part of a team designing those new projects. Sometimes I am completely disgusted with ignorant, rude, and insulting comments from uneducated people who seem to assume that those of us designing a project are not thinking about how to do it right. I've had "hippie-chick" BFA grads tell me that because I became an Engineer, my opinion was no longer valid! I was "part of the system". Let me tell you - perhaps the best change, maybe the only change, comes from within a system.
I've learned that almost always, objections to new projects are based on the objector's perceived loss of PERSONAL finance (usually property value). Most often, it is coated in a thin veneer of environmental concern, aesthetic concern, safety concern, or some other concern that is usually totally wrong, and only has any force of effect because of the emotional connotations associated with it.
The other objector that always rings so false is the misled conscientious complainer. This is usually a young person who has been convinced by another, older person, who has sway over them, that something is wrong. They usually cry at microphones at public meetings. I feel bad for them. But, ignorance really is no excuse.
So, to lessen said ignorance, here are the four big falsehoods that are trotted out whenever someone wants to slow, stop or otherwise hinder a project. Don't get me wrong - most certainly, not all development is good development. But it is important to be able to understand what makes a development good, and what makes it bad. All too often, well, almost always, the public objections are over misunderstood things that are not a problem, and the real problems with development are missed completely. Sometimes we even stop a project that needs to be stopped, but for the wrong reasons completely.
1. Density
The number of people living on one acre of land is a measurement that planners can make, because most of them can count. It has absolutely no bearing on whether a development is good or bad. There are excellent, highly dense developments. There are great densely populated cities and neighbourhoods. And the reverse holds true. A high density is not, in and of itself, a bad, or a good thing.
2. Height
The height of a building has almost nothing to do with whether it is bad or good for a community. At some point, in a city, shadows already exist across a street at some time of a day. By definition. But a tall tower, set back from a street facade makes no difference in what we all experience from the street once that shadow reaches across the street. In some cities, this is encouraged, as it cools the street. Height is something we need to start allowing, but in trade for leaving more land open at ground level - get back more park space, pedestrian areas, and treed shady spots, in trade for allowing the office and residential indoors to stack on top of itself. Don't be against a project just because it is high. This is not New York, sure, but it also is not the old part of Paris either.
3. Heritage or Historic Character.
Remember, at one time that nice old building was the newest avant guard design. It sits there demonstrative of its period, an example of the Architecture of its day. Our city now has almost 20 years of no new architecture in the downtown. Some day an architectural historian might look at Halifax and wonder what happened here over that period, and surmise that perhaps a disease that attacked the local design skill IQ and rendered us all worshipers of the 4.5 story boxes littered around our outskirts like un-scooped doggie do. We need to keep the best examples of every period's architecture. No one can be the judge of which has more value, because they are all no more than what they are. We need to allow today's designs to find a place in our city beside the existing well designed, and well built, older building stock. This is not Sherbrooke Village, we are not making a museum here. Even worse is fake history. Restore, but don't mimic or save only the facade. A building is a three dimensional work. Keep the good examples, and let the others fade into history.
4. Traffic
Here lies the issue with the most common moronic public perceptions. Tell someone that the traffic on their street will rise by 100 vehicles a day and they have a fit. Stop and think about what an increase in traffic really means. Take the design capacity of a street, and find out what percentage of that already happens on a road or street. Then calculate what percentage decrease in capacity the projected increase will cause. In almost every single case, this is almost nothing. If you could take the "anti-traffic increase" person at a public meeting, and stick them on a street with the before, and the after, traffic activity of almost every single development I've seen, they could not tell you which scenario they were in. I am sick and tired of someone saying, "this will double the traffic on our street" when they only have 200 trips a day now. 400 a day is nothing.
When its all said and done, traffic engineering is little more than voodoo anyway, and as Jane Jacobs said in her final book "Dark Age Ahead", Traffic Engineers have never got anything right. I am certain they don't consider human factors enough. Cars do not flow though streets like water through pipes, or current through wire. They go where people aim them. They take U-turns to avoid congestion, and sometimes, they choose another route altogether.
Traffic modelling is so fraught with uncertainty, I don't rely on it as a positive or negative factor in assessing any development. No more than I trust ghosts or magic.
Now, of course there will be exceptions to the above. Plenty of them, maybe. But in them lie the greatest errors people make when opposing a development. And for sure, it is usually a development that they think will affect their own financial situation, or they have simply become addicted to seeing their name in the media as the standard go to "no person".
My next missive, when I get around to it, will be the things we really need to be making sure are done right that we almost never do. You can complain about anything I write by commenting below.
I've watched, read, practiced and observed for 30 years since I graduated as a young engineer, one who wanted to do things better in response to what I then saw as a growing problem with our environment.
Working as a consulting engineer, I almost always have ended up of the proactive side of the development debate - I've been part of a team designing those new projects. Sometimes I am completely disgusted with ignorant, rude, and insulting comments from uneducated people who seem to assume that those of us designing a project are not thinking about how to do it right. I've had "hippie-chick" BFA grads tell me that because I became an Engineer, my opinion was no longer valid! I was "part of the system". Let me tell you - perhaps the best change, maybe the only change, comes from within a system.
I've learned that almost always, objections to new projects are based on the objector's perceived loss of PERSONAL finance (usually property value). Most often, it is coated in a thin veneer of environmental concern, aesthetic concern, safety concern, or some other concern that is usually totally wrong, and only has any force of effect because of the emotional connotations associated with it.
The other objector that always rings so false is the misled conscientious complainer. This is usually a young person who has been convinced by another, older person, who has sway over them, that something is wrong. They usually cry at microphones at public meetings. I feel bad for them. But, ignorance really is no excuse.
So, to lessen said ignorance, here are the four big falsehoods that are trotted out whenever someone wants to slow, stop or otherwise hinder a project. Don't get me wrong - most certainly, not all development is good development. But it is important to be able to understand what makes a development good, and what makes it bad. All too often, well, almost always, the public objections are over misunderstood things that are not a problem, and the real problems with development are missed completely. Sometimes we even stop a project that needs to be stopped, but for the wrong reasons completely.
1. Density
The number of people living on one acre of land is a measurement that planners can make, because most of them can count. It has absolutely no bearing on whether a development is good or bad. There are excellent, highly dense developments. There are great densely populated cities and neighbourhoods. And the reverse holds true. A high density is not, in and of itself, a bad, or a good thing.
2. Height
The height of a building has almost nothing to do with whether it is bad or good for a community. At some point, in a city, shadows already exist across a street at some time of a day. By definition. But a tall tower, set back from a street facade makes no difference in what we all experience from the street once that shadow reaches across the street. In some cities, this is encouraged, as it cools the street. Height is something we need to start allowing, but in trade for leaving more land open at ground level - get back more park space, pedestrian areas, and treed shady spots, in trade for allowing the office and residential indoors to stack on top of itself. Don't be against a project just because it is high. This is not New York, sure, but it also is not the old part of Paris either.
3. Heritage or Historic Character.
Remember, at one time that nice old building was the newest avant guard design. It sits there demonstrative of its period, an example of the Architecture of its day. Our city now has almost 20 years of no new architecture in the downtown. Some day an architectural historian might look at Halifax and wonder what happened here over that period, and surmise that perhaps a disease that attacked the local design skill IQ and rendered us all worshipers of the 4.5 story boxes littered around our outskirts like un-scooped doggie do. We need to keep the best examples of every period's architecture. No one can be the judge of which has more value, because they are all no more than what they are. We need to allow today's designs to find a place in our city beside the existing well designed, and well built, older building stock. This is not Sherbrooke Village, we are not making a museum here. Even worse is fake history. Restore, but don't mimic or save only the facade. A building is a three dimensional work. Keep the good examples, and let the others fade into history.
4. Traffic
Here lies the issue with the most common moronic public perceptions. Tell someone that the traffic on their street will rise by 100 vehicles a day and they have a fit. Stop and think about what an increase in traffic really means. Take the design capacity of a street, and find out what percentage of that already happens on a road or street. Then calculate what percentage decrease in capacity the projected increase will cause. In almost every single case, this is almost nothing. If you could take the "anti-traffic increase" person at a public meeting, and stick them on a street with the before, and the after, traffic activity of almost every single development I've seen, they could not tell you which scenario they were in. I am sick and tired of someone saying, "this will double the traffic on our street" when they only have 200 trips a day now. 400 a day is nothing.
When its all said and done, traffic engineering is little more than voodoo anyway, and as Jane Jacobs said in her final book "Dark Age Ahead", Traffic Engineers have never got anything right. I am certain they don't consider human factors enough. Cars do not flow though streets like water through pipes, or current through wire. They go where people aim them. They take U-turns to avoid congestion, and sometimes, they choose another route altogether.
Traffic modelling is so fraught with uncertainty, I don't rely on it as a positive or negative factor in assessing any development. No more than I trust ghosts or magic.
Now, of course there will be exceptions to the above. Plenty of them, maybe. But in them lie the greatest errors people make when opposing a development. And for sure, it is usually a development that they think will affect their own financial situation, or they have simply become addicted to seeing their name in the media as the standard go to "no person".
My next missive, when I get around to it, will be the things we really need to be making sure are done right that we almost never do. You can complain about anything I write by commenting below.
Thursday, June 16, 2011
The Culture of Imaginary Entitlement
I've been thinking a lot about this recent spate of "scandals" we seem to be having exposed for us by the local media. The "cash for concerts" scandal, the "Olympic Hockey tickets for unknown industrialists" scandal, and what looks to be perhaps an even bigger bomb on the horizon, the "what happened to our $9.5 Million?" Commonwealth Games scandal.
I'm sure there are more.
One thing these all have in common is a cultural behaviour that is simply getting to be too common these days. I call it the Culture of Imaginary Entitlement. This is when you find yourself in a position with the authority to spend someone else's money, and it goes to your head to the point where you start to believe it is your money. To make you look good. Or be famous. Or to make special friends with. Maybe even get laid!
This state of mind is not one that happens instantaneously, but it is one that slowly seeps into the psyche. Those "this should be mine, I deserve it" thoughts worm away at your self confidence, and diminish your ego. So you slowly start to live the dream - spending the money as if it was your own, and as if it is infinite. And you can't stop.
You aren't really a bigwig, heck, you've never had a real job, maybe, but now you have power, yeah, you can spend other people's money just like, well almost as if, it... was.... really.... yours.
So, what do you do? You wine and dine truly successful people, the ones who actually have money of their own to spend, and try to buy your way into their circle with your expense accounts, your grants, and your tax breaks and subsidies. Instant friends!! You are the shit !!
Heck you can hire some famous bands and get to meet the stars, maybe Mick Jagger, Paul McCartney, and even Gene Simmons and Paul Stanley (who you still secretly love from your old Kiss Army days). And of course you can jet the world, maybe even with that cute little gal from admin along as your executive assistant. You can even get to play dress-up like your heroes, paint your face, have your picture taken with them, pretend you're George Harrison walking that crosswalk at Apple Studios, and even do after-party coke lines with Keith Richards! Yes, you too can be a star.
In time, you can actually convince yourself that you really deserve this, you are the ONE destined to decide how the public money is spent, and the rest of the rabble in your city can just fuck off and try to beat you in an election. You're so cool now, it is obvious you'll be elected for life.
Of course, the reality is that just like the servants in those movies who pretend to be the master when the boss is away, it all falls apart when the owners come home from vacation and find you wearing their clothes and trying to sleep with their friends' daughters.
And that's what's happening now. The pants are down around the ankles, and the fan's spraying shit like it's going out of style.
I'm sure there are more.
One thing these all have in common is a cultural behaviour that is simply getting to be too common these days. I call it the Culture of Imaginary Entitlement. This is when you find yourself in a position with the authority to spend someone else's money, and it goes to your head to the point where you start to believe it is your money. To make you look good. Or be famous. Or to make special friends with. Maybe even get laid!
This state of mind is not one that happens instantaneously, but it is one that slowly seeps into the psyche. Those "this should be mine, I deserve it" thoughts worm away at your self confidence, and diminish your ego. So you slowly start to live the dream - spending the money as if it was your own, and as if it is infinite. And you can't stop.
You aren't really a bigwig, heck, you've never had a real job, maybe, but now you have power, yeah, you can spend other people's money just like, well almost as if, it... was.... really.... yours.
So, what do you do? You wine and dine truly successful people, the ones who actually have money of their own to spend, and try to buy your way into their circle with your expense accounts, your grants, and your tax breaks and subsidies. Instant friends!! You are the shit !!
Heck you can hire some famous bands and get to meet the stars, maybe Mick Jagger, Paul McCartney, and even Gene Simmons and Paul Stanley (who you still secretly love from your old Kiss Army days). And of course you can jet the world, maybe even with that cute little gal from admin along as your executive assistant. You can even get to play dress-up like your heroes, paint your face, have your picture taken with them, pretend you're George Harrison walking that crosswalk at Apple Studios, and even do after-party coke lines with Keith Richards! Yes, you too can be a star.
In time, you can actually convince yourself that you really deserve this, you are the ONE destined to decide how the public money is spent, and the rest of the rabble in your city can just fuck off and try to beat you in an election. You're so cool now, it is obvious you'll be elected for life.
Of course, the reality is that just like the servants in those movies who pretend to be the master when the boss is away, it all falls apart when the owners come home from vacation and find you wearing their clothes and trying to sleep with their friends' daughters.
And that's what's happening now. The pants are down around the ankles, and the fan's spraying shit like it's going out of style.
Wednesday, June 08, 2011
Sometimes the Bullshits Explains Itself
PRESS RELEASE:
Alexander Keith's Introduces
Three New Brews to the United States
Famed Nova Scotia Beer Brand, Alexander Keith's, Debuts in the U.S.
ST. LOUIS (June 8, 2011) – Alexander Keith's announces the U.S. launch of three new brews: Nova Scotia Style Lager, Nova Scotia Style Pale Ale and Nova Scotia Style Brown Ale. The beers are now available in 22 states across the U.S.
The three new Alexander Keith's brews are perfect for the adventure-seeking beer lover:
With a deep amber color and brewed with noble hops prized for their subtle, spicy character, the Nova Scotia Style Lager has a crisp finish with an assertive, but clean bitterness.
Brewed with traditional two-row malt for a full, malty flavor, the Nova Scotia Style Pale Ale also includes a fruity, spicy and citrusy hop nose.
The Nova Scotia Style Brown Ale is a classic full-bodied brown ale with hints of honey and caramel, balanced with a fresh hop aroma provided by the addition of cascade hops.
Though new to the United States, the heritage of Alexander Keith's traces back nearly two hundred years to its brewery in Nova Scotia, founded in 1820 by Scottish native Alexander Keith. After completing his brewer's apprenticeship and emigrating from Scotland to “New Scotland” (Nova Scotia), Keith created what is now one of the oldest beer brands in North America. The Nova Scotia brewery is still in operation today under the leadership of its brewmaster emeritus Graham Kendall.
The three new beers are brewed in Baldwinsville, N.Y., and Alexander Keith's will also continue to be brewed in Canada in Nova Scotia, British Columbia and Ontario.
“Alexander Keith's brands continue to be brewed under the guiding principles of our founder and the strong sense of adventure found in the people of Nova Scotia,” said brewmaster emeritus Graham Kendall. “The brewery and its brewmasters have been certified under our strict certification program, showing our unwavering commitment to our heritage.”
About Alexander Keith's
Alexander Keith's brands maintain the quality and heritage first introduced by Alexander Keith himself in 1820. Only the finest barley malt and select hops are used to brew these fine beers, which in the U.S. include Nova Scotia Style Lager, Nova Scotia Style Pale Ale and Nova Scotia Style Brown Ale.
The new Alexander Keith's brands will be available in the following locations: AZ, CA, CO, CT, DC, DE, FL, IN, MA, MD, ME, MN, ND, NH, NY, OR, PA, RI, VT, WA, WI and St. Louis (MO & IL).
# # #
Holy fuck, there is a "Nova Scotia Style" !?!? Good god, now where did I put my Propeller IPA.......
Alexander Keith's Introduces
Three New Brews to the United States
Famed Nova Scotia Beer Brand, Alexander Keith's, Debuts in the U.S.
ST. LOUIS (June 8, 2011) – Alexander Keith's announces the U.S. launch of three new brews: Nova Scotia Style Lager, Nova Scotia Style Pale Ale and Nova Scotia Style Brown Ale. The beers are now available in 22 states across the U.S.
The three new Alexander Keith's brews are perfect for the adventure-seeking beer lover:
With a deep amber color and brewed with noble hops prized for their subtle, spicy character, the Nova Scotia Style Lager has a crisp finish with an assertive, but clean bitterness.
Brewed with traditional two-row malt for a full, malty flavor, the Nova Scotia Style Pale Ale also includes a fruity, spicy and citrusy hop nose.
The Nova Scotia Style Brown Ale is a classic full-bodied brown ale with hints of honey and caramel, balanced with a fresh hop aroma provided by the addition of cascade hops.
Though new to the United States, the heritage of Alexander Keith's traces back nearly two hundred years to its brewery in Nova Scotia, founded in 1820 by Scottish native Alexander Keith. After completing his brewer's apprenticeship and emigrating from Scotland to “New Scotland” (Nova Scotia), Keith created what is now one of the oldest beer brands in North America. The Nova Scotia brewery is still in operation today under the leadership of its brewmaster emeritus Graham Kendall.
The three new beers are brewed in Baldwinsville, N.Y., and Alexander Keith's will also continue to be brewed in Canada in Nova Scotia, British Columbia and Ontario.
“Alexander Keith's brands continue to be brewed under the guiding principles of our founder and the strong sense of adventure found in the people of Nova Scotia,” said brewmaster emeritus Graham Kendall. “The brewery and its brewmasters have been certified under our strict certification program, showing our unwavering commitment to our heritage.”
About Alexander Keith's
Alexander Keith's brands maintain the quality and heritage first introduced by Alexander Keith himself in 1820. Only the finest barley malt and select hops are used to brew these fine beers, which in the U.S. include Nova Scotia Style Lager, Nova Scotia Style Pale Ale and Nova Scotia Style Brown Ale.
The new Alexander Keith's brands will be available in the following locations: AZ, CA, CO, CT, DC, DE, FL, IN, MA, MD, ME, MN, ND, NH, NY, OR, PA, RI, VT, WA, WI and St. Louis (MO & IL).
# # #
Holy fuck, there is a "Nova Scotia Style" !?!? Good god, now where did I put my Propeller IPA.......
Wednesday, May 18, 2011
#Tastecamp Niagara - The Maritime Drinker Reports
There used to be a time when a trip to a wine region meant a very long flight, probably across water. Now, we can get in the car and pop over to the Annapolis Valley for a day of touring wineries, tasting wine, and eating very very well. In time, people are projecting that we will one day have many more wineries, and the economic activity that comes with being a mature wine region will be a boon to our overall economy.
Last week, I got the chance to visit two very different wine regions. Both with the same name, but in different countries. Niagara - both Canada and the USA.
This adventure represented a combination of four of the things I've already written about - wine, design, waste management, and Twitter. The wine part is obvious. The wineries, and their new architecture and adaptations provided the design part, observing how they dealt with their waste the third, and as for the Twitter part - the entire thing was basically organized and documented using Twitter.
The attendees were all people who blog or otherwise opine in writing about wine. Some professionals, some hobbyists, and many somewhere in between. The audience was a fun mix of American and Canadian participants.
The format was essentially a tour of large wineries, at which groups of other wineries also had tasting tables to show off their wares. This demonstrated very clearly the collegial cooperation that exists in this industry and I very much appreciated it.
The organizers, working as volunteers, had done an amazing amount of work in scheduling, arranging participating wineries, and logistics. They got some assistance from industry support organizations, and wonderful cooperation from the participating wineries.
What was most interesting to me, though, was the chance to explore and compare the relatively fledgling wine industry on the other side of Lake Ontario in New York State, specifically the area around Lockport stretching down to the lake. It turns out they have similar degree days to Long Island and are warmer than the Finger Lakes. The idea to make wine here on a commercial scale is relatively new, and there are not very many places going full tilt; yet.
We were treated to two packed days of Niagara, Ontario wine tastings. These wines ranged from some marginal but drinkable wines; to Burgundian quality Pinot Noir and Chardonnay, and Mosel-like Rieslings; to varying qualities of Bordeaux blends and varietals, with Cabernet Franc invariably providing the most interest among those. In some wineries, the quality is extremely high, and one can only wonder how they stay in business with the highly managed vineyards and low yields that result.
In New York we tasted tree and berry fruit wine, and hybrid and vinifera based wines, all well made. The status of this area is similar to Nova Scotia, with the exception that our sparkling wines are well ahead of them. But they have a climate that could be very good at growing vinifera grapes like Merlot, Pinot Noir, and the one that surprised me most, Syrah. I do worry about their susceptibility to a late frost, as their vines were well advanced and vulnerable when we visited. One had to admire the dedication of the owners of Arrowhead, as well as their Syrah.
More to come from me on the wines, but regardless of whether I liked them, the entire trip was a great experience and the food we shared was wonderful. The organizers could do this type of event management work for a living and be very well off.
Last week, I got the chance to visit two very different wine regions. Both with the same name, but in different countries. Niagara - both Canada and the USA.
This adventure represented a combination of four of the things I've already written about - wine, design, waste management, and Twitter. The wine part is obvious. The wineries, and their new architecture and adaptations provided the design part, observing how they dealt with their waste the third, and as for the Twitter part - the entire thing was basically organized and documented using Twitter.
The attendees were all people who blog or otherwise opine in writing about wine. Some professionals, some hobbyists, and many somewhere in between. The audience was a fun mix of American and Canadian participants.
The format was essentially a tour of large wineries, at which groups of other wineries also had tasting tables to show off their wares. This demonstrated very clearly the collegial cooperation that exists in this industry and I very much appreciated it.
The organizers, working as volunteers, had done an amazing amount of work in scheduling, arranging participating wineries, and logistics. They got some assistance from industry support organizations, and wonderful cooperation from the participating wineries.
What was most interesting to me, though, was the chance to explore and compare the relatively fledgling wine industry on the other side of Lake Ontario in New York State, specifically the area around Lockport stretching down to the lake. It turns out they have similar degree days to Long Island and are warmer than the Finger Lakes. The idea to make wine here on a commercial scale is relatively new, and there are not very many places going full tilt; yet.
We were treated to two packed days of Niagara, Ontario wine tastings. These wines ranged from some marginal but drinkable wines; to Burgundian quality Pinot Noir and Chardonnay, and Mosel-like Rieslings; to varying qualities of Bordeaux blends and varietals, with Cabernet Franc invariably providing the most interest among those. In some wineries, the quality is extremely high, and one can only wonder how they stay in business with the highly managed vineyards and low yields that result.
In New York we tasted tree and berry fruit wine, and hybrid and vinifera based wines, all well made. The status of this area is similar to Nova Scotia, with the exception that our sparkling wines are well ahead of them. But they have a climate that could be very good at growing vinifera grapes like Merlot, Pinot Noir, and the one that surprised me most, Syrah. I do worry about their susceptibility to a late frost, as their vines were well advanced and vulnerable when we visited. One had to admire the dedication of the owners of Arrowhead, as well as their Syrah.
More to come from me on the wines, but regardless of whether I liked them, the entire trip was a great experience and the food we shared was wonderful. The organizers could do this type of event management work for a living and be very well off.
Nova Scotia: We're Poor Because We Are Stupid (but maybe there's hope)
I have a story to tell.....
This scenario sounds pretty good. Start an Engineering firm outside of Halifax, in a market where there is no access to Professional Engineering, other than from people driving from Halifax. Start with 4 people, and in two years, grow it to 20, all with no help from any funding program, and almost no government work.
Once established as a member of the local economy, active in the community, with almost all your payroll going back into that economy, you decide you are ready to start asking for work from your governments. The places your taxes, and your employees' taxes go.
You've created about 8 new jobs without any help from government. No ACOA grants, no tax breaks, no subsidies. You've provided a place for local kids to work in a technical, highly trained group, without having to move away. If you were some foreign owned industry, the Province would be paying you hundreds of thousands of dollars. You really can't be blamed for expecting some sort of welcoming reception from government when you see publicly funded projects about to happen in your own community, and you'd like to be involved.
But here is where the stupidity begins.
Government purchasing seems completely disconnected with reality and with economic development of our region. The policies in place have evolved over the years to create a form of exclusion of local companies. This has happened in ignorance of the work actually being done, the economic benefits of buying local and keeping jobs in a community, and, sometimes, just to perpetuate the status quo. Remember, as a rule local companies will be smaller, and multinationals will be, well, multinationals.
Here are two real situations I've encountered in Nova Scotia since the fall. Tell me if you think the bureaucrats I have to deal with are spending your tax dollars wisely.
The first foray into government work was with the Province. We had someone who wanted to hire us, because we are one of the best firms at the specific task they needed done, and the job was close to our office. It was a job of small scale for us, routine. BUT in order to actually be hired to do this simple task, we first had to develop a safety plan (for our office, not for out on constructions sites), we had to double our insurance policy for general liability above what our insurance broker had already recommended and sold us, and we had to double, or, really, quadruple our coverage for Errors and Omissions Insurance. This cost us a fair amount of money, just to qualify to do government work.
All this had absolutely nothing to do with any real change in liability, people doing the work, the work itself, its outcome, or anything else. All it did was cost us money. The only reason we had to do this was that someone in government decided some time ago to set everything up the same way - the same liability for a multi-million dollar sewage treatment plant design as a $20,000 sewage system for a park. What is the real effect here? It means that sometimes the only firms who can afford the coverage and assorted bullshit for huge jobs get to do the small jobs (big wrench, small bolt). So we, as taxpayers, end up having our little routine jobs done by the big foreign or out of Province controlled firms, and not by the smaller firms that might be next door to the work. The smaller, more efficient local firms are shut out by our own governmental purchasing restrictions. Do you think this saves us money? If you do, you need to read a bit more economics.
If every engineering firm were the same size, this might be acceptable. But here's the reality in the consulting engineering business in Eastern Canada right now. With the exception of one firm, CBCL Limited, any company large enough for the Province to consider hiring them for a larger project is owned by out of Province interests. And to add to the problem, the Province is fixated on "Big Project = Big Firm" foolishness, despite the fact that even in a big firm, usually only 3 or 4 people do the work on a project.
A smaller, local firm is automatically thrown into the pit with these big multinationals, but it has all its advantages stripped away. Being able to move fast, charge less, and be close to home matters nothing. What matters is bulking up your overhead with useless government stipulated requirements designed for larger projects. This just costs the taxpayer more. The same thing applies for contractors building our designs. The best septic system installers usually can't get bonded enough to do government work. So we taxpayers pay more, for what may end up being a lesser quality job.
In the end, we used our profit from this job to pay for all the bullshit we had to go through to even be allowed to work for our own government. The fees and the construction all stayed in the local economy. And now we are ready for future work, if it comes along.
More recently, however, we have run into another bit of bureaucracy emanating from the Public Tenders Office. There is a fair amount of new road work planned for the part of Nova Scotia our offices are in. And we have first class expertise in road design now. So we asked the Province how we could compete for that work.
It turns out that all Provincial road design work is given out to firms already listed on a "Standing Offer". This is a list of firms who meet minimum qualifications to do certain kinds of work, from which a contracting officer (in this case someone who needs a road designed) must choose three to invite to compete, or, if the job is under $10,000 in fees, pick one. There are rates for staff associated with these standing offers, but they are not really judged in a competitive manner. It's just a list of qualified people from which the government can buy services at a set, pre-stated rate.
So here we are, the only engineering firm at all in our part of Nova Scotia, and one of the few locally owned companies even capable of designing roads, and we are told that this standing offer is closed to us until April 2012 when it will be opened again to new firms. No reason is given why this cannot simply be something you apply to be registered under. No, they just say, "no, you have to wait a year".
The apparently open it once every two years. In two years, we have gone from 4 to 20 employees. Two years is a long time in our business.
To add insult to injury, however, two local firms that were on the list were recently taken over by out of Province firms. But these new to Nova Scotia firms from away did not have to wait a year, they simply got to enjoy the rights of the firm they bought, and they are among the dominating firms on the list of suppliers. So the system allows firms from outside to get on a list because they have deep enough pockets to buy out local businesses, but discriminates against local firms wanting to work in their own neighbourhoods.
This purchasing policy encourages the shipping out of our tax dollars from our economy, and discourages the hiring of locally owned companies that are an integral part of our economy. There is preferential treatment, alright, but it's to the companies NOT owned locally. This is just plain stupidity for which there can be no excuse, and for which there has to be a remedy.
This is a basic, ill conceived policy designed and implemented by people who apparently know nothing about the industry from which they are buying services. It runs contrary to every fundamental economic development principle. As Jane Jacobs said, import substitution is the most powerful economic development tool. In Nova Scotia, we are stupid, and we do the opposite. We encourage imported services over those provided from within our already weak economy. And that is one reason why it stays weak.
We are waiting to hear back from the Public Tenders Office. They seemed very understanding, and are "looking into it". But they seem so caught up in their own role, and in some fear of NAFTA (like we are going to be stealing from American firms), that I will be very surprised, but happy, if they find a workaround. Remember, I'm not asking for work, just the right to compete for it fairly.
In the end, until we can allow our own entrepreneurs fair and equal access to our own governments' work, we'll remain the Upper Canada-dependent, second class Province we are now. No matter how much spin you put on this, the only spin is a money sucking vortex taking those fees all the way back to Ontario and Quebec instead of keeping them here to be of great benefit to our economy.
----> Late breaking news: After being a little bit of a pain, I have found someone who seems to understand what I am saying, and they are in a position to do something about it. So, my Civil Servant of the Year Award (so far in 2011 anyway) goes to Mr. Robert Salah, the head of Procurement. He managed to interpret a clause in the Standing Offer in a manner that was "open for business" instead of "closed to business". For this, he becomes that rare Civil Servant - one who makes a judgement call that may end up causing him more work, but more fully satisfies the reason he is there for.
----> Later breaking news: The RFP was re-released as an interim registration offering. I dropped a proposal for providing services yesterday. It was amazing how many minutiae were involved in even registering to be considered for work. If I showed you, you would not believe it. It is a lesson in how something so simple as hiring expertise to do something for you can be turned into a horribly complicated and bureaucratic process.
So now we may soon win back our right to compete. We may lose every time we try, but at least we'll have a fair shot. I hope.
This scenario sounds pretty good. Start an Engineering firm outside of Halifax, in a market where there is no access to Professional Engineering, other than from people driving from Halifax. Start with 4 people, and in two years, grow it to 20, all with no help from any funding program, and almost no government work.
Once established as a member of the local economy, active in the community, with almost all your payroll going back into that economy, you decide you are ready to start asking for work from your governments. The places your taxes, and your employees' taxes go.
You've created about 8 new jobs without any help from government. No ACOA grants, no tax breaks, no subsidies. You've provided a place for local kids to work in a technical, highly trained group, without having to move away. If you were some foreign owned industry, the Province would be paying you hundreds of thousands of dollars. You really can't be blamed for expecting some sort of welcoming reception from government when you see publicly funded projects about to happen in your own community, and you'd like to be involved.
But here is where the stupidity begins.
Government purchasing seems completely disconnected with reality and with economic development of our region. The policies in place have evolved over the years to create a form of exclusion of local companies. This has happened in ignorance of the work actually being done, the economic benefits of buying local and keeping jobs in a community, and, sometimes, just to perpetuate the status quo. Remember, as a rule local companies will be smaller, and multinationals will be, well, multinationals.
Here are two real situations I've encountered in Nova Scotia since the fall. Tell me if you think the bureaucrats I have to deal with are spending your tax dollars wisely.
The first foray into government work was with the Province. We had someone who wanted to hire us, because we are one of the best firms at the specific task they needed done, and the job was close to our office. It was a job of small scale for us, routine. BUT in order to actually be hired to do this simple task, we first had to develop a safety plan (for our office, not for out on constructions sites), we had to double our insurance policy for general liability above what our insurance broker had already recommended and sold us, and we had to double, or, really, quadruple our coverage for Errors and Omissions Insurance. This cost us a fair amount of money, just to qualify to do government work.
All this had absolutely nothing to do with any real change in liability, people doing the work, the work itself, its outcome, or anything else. All it did was cost us money. The only reason we had to do this was that someone in government decided some time ago to set everything up the same way - the same liability for a multi-million dollar sewage treatment plant design as a $20,000 sewage system for a park. What is the real effect here? It means that sometimes the only firms who can afford the coverage and assorted bullshit for huge jobs get to do the small jobs (big wrench, small bolt). So we, as taxpayers, end up having our little routine jobs done by the big foreign or out of Province controlled firms, and not by the smaller firms that might be next door to the work. The smaller, more efficient local firms are shut out by our own governmental purchasing restrictions. Do you think this saves us money? If you do, you need to read a bit more economics.
If every engineering firm were the same size, this might be acceptable. But here's the reality in the consulting engineering business in Eastern Canada right now. With the exception of one firm, CBCL Limited, any company large enough for the Province to consider hiring them for a larger project is owned by out of Province interests. And to add to the problem, the Province is fixated on "Big Project = Big Firm" foolishness, despite the fact that even in a big firm, usually only 3 or 4 people do the work on a project.
A smaller, local firm is automatically thrown into the pit with these big multinationals, but it has all its advantages stripped away. Being able to move fast, charge less, and be close to home matters nothing. What matters is bulking up your overhead with useless government stipulated requirements designed for larger projects. This just costs the taxpayer more. The same thing applies for contractors building our designs. The best septic system installers usually can't get bonded enough to do government work. So we taxpayers pay more, for what may end up being a lesser quality job.
In the end, we used our profit from this job to pay for all the bullshit we had to go through to even be allowed to work for our own government. The fees and the construction all stayed in the local economy. And now we are ready for future work, if it comes along.
More recently, however, we have run into another bit of bureaucracy emanating from the Public Tenders Office. There is a fair amount of new road work planned for the part of Nova Scotia our offices are in. And we have first class expertise in road design now. So we asked the Province how we could compete for that work.
It turns out that all Provincial road design work is given out to firms already listed on a "Standing Offer". This is a list of firms who meet minimum qualifications to do certain kinds of work, from which a contracting officer (in this case someone who needs a road designed) must choose three to invite to compete, or, if the job is under $10,000 in fees, pick one. There are rates for staff associated with these standing offers, but they are not really judged in a competitive manner. It's just a list of qualified people from which the government can buy services at a set, pre-stated rate.
So here we are, the only engineering firm at all in our part of Nova Scotia, and one of the few locally owned companies even capable of designing roads, and we are told that this standing offer is closed to us until April 2012 when it will be opened again to new firms. No reason is given why this cannot simply be something you apply to be registered under. No, they just say, "no, you have to wait a year".
The apparently open it once every two years. In two years, we have gone from 4 to 20 employees. Two years is a long time in our business.
To add insult to injury, however, two local firms that were on the list were recently taken over by out of Province firms. But these new to Nova Scotia firms from away did not have to wait a year, they simply got to enjoy the rights of the firm they bought, and they are among the dominating firms on the list of suppliers. So the system allows firms from outside to get on a list because they have deep enough pockets to buy out local businesses, but discriminates against local firms wanting to work in their own neighbourhoods.
This purchasing policy encourages the shipping out of our tax dollars from our economy, and discourages the hiring of locally owned companies that are an integral part of our economy. There is preferential treatment, alright, but it's to the companies NOT owned locally. This is just plain stupidity for which there can be no excuse, and for which there has to be a remedy.
This is a basic, ill conceived policy designed and implemented by people who apparently know nothing about the industry from which they are buying services. It runs contrary to every fundamental economic development principle. As Jane Jacobs said, import substitution is the most powerful economic development tool. In Nova Scotia, we are stupid, and we do the opposite. We encourage imported services over those provided from within our already weak economy. And that is one reason why it stays weak.
We are waiting to hear back from the Public Tenders Office. They seemed very understanding, and are "looking into it". But they seem so caught up in their own role, and in some fear of NAFTA (like we are going to be stealing from American firms), that I will be very surprised, but happy, if they find a workaround. Remember, I'm not asking for work, just the right to compete for it fairly.
In the end, until we can allow our own entrepreneurs fair and equal access to our own governments' work, we'll remain the Upper Canada-dependent, second class Province we are now. No matter how much spin you put on this, the only spin is a money sucking vortex taking those fees all the way back to Ontario and Quebec instead of keeping them here to be of great benefit to our economy.
----> Late breaking news: After being a little bit of a pain, I have found someone who seems to understand what I am saying, and they are in a position to do something about it. So, my Civil Servant of the Year Award (so far in 2011 anyway) goes to Mr. Robert Salah, the head of Procurement. He managed to interpret a clause in the Standing Offer in a manner that was "open for business" instead of "closed to business". For this, he becomes that rare Civil Servant - one who makes a judgement call that may end up causing him more work, but more fully satisfies the reason he is there for.
----> Later breaking news: The RFP was re-released as an interim registration offering. I dropped a proposal for providing services yesterday. It was amazing how many minutiae were involved in even registering to be considered for work. If I showed you, you would not believe it. It is a lesson in how something so simple as hiring expertise to do something for you can be turned into a horribly complicated and bureaucratic process.
So now we may soon win back our right to compete. We may lose every time we try, but at least we'll have a fair shot. I hope.
Sunday, January 02, 2011
The Poop on Poop - Halifax and its Harbour History
Slowly the "debate" we have been having on "biosolids", mostly played out in the media (churning) has been moving from what was a scientific environmental discussion into an absurd hysteria driven emotional miasma of illogic.
Let's set a few things straight here.
1. The best place, with no doubt whatsoever, to direct treated sewage, both liquid and solids types of waste, is back on to the land from which the nutrients in the waste originally came.
2. It is not just possible, but quite easy to treat sewage sludge so that it is safe for use on agricultural lands. This happens now all over the world, and is already common in Nova Scotia.
3. There are some sewage sludges that are probably not suitable for use for agricultural purposes because the sludge is the residual from more than simple domestic sewage (poop) and includes some industrial waste streams that contain heavy metals.
4. Not all sanitary sewage contains industrial waste. Parts of Halifax only produce domestic sewage, or organic waste that can be safely treated to return to replace nutrients stripped from that land by food or forestry production.
5. We do not have very much topsoil in Nova Scotia.
6. Anyone who eats rice eats food grown directly in untreated sewage that is probably from a third world country.
7. In case you've heard otherwise, the solution to pollution IS dilution, IF you can achieve a suitable level of dilution.
Let's take a more careful look at things. The real culprit in this story is the prehistoric (OK, Roman era) gravity sewage collection systems we have been saddled with, and continue to be subjected to by the engineering community and bureaucratic status quo. We have become addicted to these systems, allowing them to grow to unreasonable size, collecting waste from huge tracts of land, to one or two focal points. I've always simply referred to this as tearing a hole in the fabric of the environment. We go to a lot of expense to move all of our small problems to one place where it then becomes one huge problem.
A gravity sewer does several things very poorly. It concentrates what are initially small amounts of heavy metals, and other undesirable elements to a level where they actually become toxic. I hate to use that word because it has been so abused by the media and even some scientists, but lets just say that too much pure water can be toxic. A large gravity sewer collection system has the unfortunate side effect of collecting all the bad things to one place, and in doing so, allowing the sewage from the places that generate most of the nasties to contaminate the sewage that is relatively benign. Can anyone argue that the sewage from Burnside Industrial Park would not be vastly different from that coming from Highfield Park, just across the 111?
The second thing large gravity sewers do is allow water that is not dirty to enter the sewage flow. This is because sooner or later, they all leak. In much of the older parts of Halifax and Dartmouth, our sewers are combined sewers, which means they also carry water that falls as rain and enters catchbasins, footing drains, roof drains and so on. During a rain storm, flow in these old pipes is mostly rainwater. Sometimes 20 or more times what is coming from toilets and sinks and dishwashers. This extra flow added to the large regional collection system causes several environmental and engineering problems. First, it means that the pipes have to be large enough to carry it. When we engineers design gravity sewers, we allow a very large portion of that pipe's capacity for future infiltration or inflow of what would otherwise be clean water. We assume that it will get in, because it does. Manholes, in particular, are a major culprit - I refer to them as water induction devices. This is probably the single largest source of water pollution in Nova Scotia - it happens constantly all day and all night - water that is clean to begin with, leaks into sanitary sewers and is immediately turned to sewage.
Second, this extra capacity is inherently wasteful because it does not always rain, so the large (more expensive) pipes can wait with only a small flow for a while, and are only fully used when it rains. There is capacity that might carry more sewage, but it is used for conveying stormwater when it has to.
When it does rain, we see yet another major problem. If we try to treat what comes out of the end of pipe, we are confronted with a wastewater that does not exhibit the ideal characteristics for biological treatment. Ideally, in a typical traditional wastewater treatment facility, the process works best when the inflow is relatively constant, the temperature is higher, and the organic strength of the sewage is concentrated. These three parameters allow the biology we cultivate in a treatment plant to live and breed at a high rate, consuming all that nutrient our more inefficient digestive processes could not. But when we allow water to enter the collection system, we get three effects that are the opposite of what we want. The flow becomes highly variable - the rain causes peak flows which decrease the time sewage can stay in a treatment facility; the extra water is almost always cold, which lowers the overall sewage temperature and slows the biology working in the sewage treatment plant; and the extra water dilutes the waste stream, making it harder for the bacteria we want to be living in the treatment plant to find food. When it rains, it's as if those good bacteria we want to work for us are being abused - they are given less time to do the job, it is cold and they are slowed down by that, and it is harder to find the food to eat.
Finally, when we try to separate out solids so that they can be composted and otherwise treated for return to the soils from which they were initially taken, all that extra water makes it a very much more difficult task to do.
Large collection systems are a mistake. But we have them because we have always had a reflex reaction to the sewage we generate. Nova Scotians are fixated on flushing all our poop to the ocean, or to some bit of natural water somewhere. We are so tunnel visioned in this regard that we continue to build new outfalls to our lakes and streams and bays and estuaries, even when a less expensive option for returning the treated effluent to the land exists (read about drip irrigation dispersal of treated sewage effluent). Our history is terrible when we look back at the sewage systems operating in Nova Scotia today, from an overall environmental view. Why is sewage that is generated out by Kearney Lake being dumped into Halifax Harbour, miles away? This when the community generating that waste stream brings in treated water to irrigate its parks, and fertilizer (some of it from human waste in Milwaukee) to keep them green?
Why do we go to all the trouble and expense to create a huge concentrated point loading on the environment in the harbour, when the initial dilution of the pollution was not nearly so bad, and, close to the place where it was generated, comparatively simple to treat to tertiary levels, as compared to the basic screening and semi-digestion now practiced by our already out of date treatment plants? Why? The answer to that, when I asked back in 1992 was "Because that's the way we've always done it." Is that good enough for you?
Back to the sludge (I dislike the term biosolids, as it is not specific enough) from treated sewage. These large collection systems guarantee that people's objections to the reliability of the quality of the sludge produced from the waste at the end of these large collection areas will be valid. Heavy metals are fine in low concentrations - they exist in nature in low concentrations. In fact some metals exist in our native soils in fairly high concentrations (copper in the soils in Halifax, for instance is usually above CCME flagging levels, naturally). But when we go to the trouble to bring all the bad stuff to one place, then filter it all out from the water, concentrating it even more, we create a new material that may have more than is safe for use on crops we plan on eating.
So why don't we treat our sewage in smaller batches, closer to where the waste is generated, "at source" so to speak, where we can identify what sub-sections of our community generate solids that are safe, and can be safely used, while making sure that other waste streams are not included in that dispersal path?
If we used some careful public health engineering (by the way, Nova Scotia has no Public Health Engineer - the position was eliminated in a government restructuring back in the 90's) we could achieve a safe and secure supply of sewage sludge that could be treated to produce a composted land amendment or fertilizer that was safe from industrial contamination. Instead, we try to rely on diluting the industrial wastes back into our domestic wastes, with no reliable way of knowing on which day there is too much industrial contamination happening.
Back when the Harbour Cleanup was being proposed, I was one of a few people advocating for a solution based on a distributed form of sewage treatment. My point was that if the Harbour had not gotten dirty all at one time, it need not be cleaned up in an instant either. We could address the sewage treatment one community, one neighbourhood at a time. Treating the sewage before the massive inflow from rainfall and the contamination for industrial sources complicated the problem to the point where we could never afford to ever do tertiary treatment. All that was needed were treatment plant solutions that a community could accept as suitable in scale and nuisance, to host in their neighbourhood. That could take the form of underground/basement Sequencing Batch Reactors, community greenhouse based Solar Aquatics™ systems, or anything else that modern technology presented us with. Once that neighbourhood was served by a tertiary treatment plant, it would no longer be a part of the problem - the STP could simply discharge into the nearest major trunk sewer, which was probably originally a brook, making it that much cleaner, and the harbour subsequently that much cleaner as a result.
This approach had other advantages over the mega project that Halifax was hurtling towards. It was predicated on the idea that it did not all have to happen at one time. So the project might be funded out of an annual capital works budget, not some mega borrowing that we will owe money on forever. And the work could be designed and built by local engineering and construction firms, not by huge multinational corporations, meaning that we could create a centre of excellence in small to medium scale urban sewage treatment here in Halifax. Perhaps the best thing was that we could go out and solve the easy problems first - cherry-pick the places where the sewage was least dilute, where a location for a STP was available, and just clean that up. But do it so that 99% of the sewage was treated, as opposed to the +/- 40% we have now. We only really need to treat half the sewage going to our harbour to tertiary levels to remove the same amount of pollution as is now being done by treating it all to 40% removal! And the tough parts? Maybe by the time we had gotten all the easy parts done, a new technology will have been developed that can handle those (and this appears to be on the horizon now, with advances in microfiltration).
At the time, the absurd criticism we got from the old engineers in HRM was that there would be too many plants to operate - they would require too many people to run. This when NSPI runs all its hydro stations all over Nova Scotia from one control centre in Ragged Lake. And when the idea of a few good paying local jobs instead of cash sent to France for mega-project gear made some economic sense.
Of course, also at the same time, our rational arguments were hijacked by some well meaning, but ill informed eco-socialites who thought it a dreamy idea that a Solar Aquatics greenhouse system for Halifax would be just peachy! In fact they were advocating that the main treatment plant for all that dilute cold sewage in Halifax be treated in one greenhouse. I worked it out one day - the greenhouse would have to cover all of the Dockyards from Pier 9 to Purdy's Wharf to even have a chance at treating all the sewage in one place. But about 35 small to medium size treatment plants could do all of the metro area. This because the smaller plants would not be treated the huge peak flows that exist at the bottom of THE BIG PIPE. And we would not need any tunnels or outfalls - we'd just let the treated effluent flow out via the existing outfalls. Sure, a few could be consolidated or extended, but there would be no need to put it all in one place like we do now. And sooner or later, we'd have it all done. One bit at a time, the same way the harbour got dirty in the first place.
If this makes some sense to you, then you understand the concept of loading. See here for more on that if you don't. But this approach might have been impossible to get regulatory approval form because the regulators cannot apply common sense, they have to apply old standards based on the concentration of flow to the Harbour. They might not be able to look the other way when three pipes are say, 95% treated, but the one beside it isn't treated at all. Despite the net removal of pollutant being the same as what wold exist if they were all treated to a 75% removal. What they have accepted is a concentration based effluent discharge permit where it is possible that nothing is actually removed from the sewage, but enough water is added to it to dilute the concentration below some theoretical level. No one really cared about whether the harbour was being cleaned up, they cared about whether the stuff leaving one or two pipes was diluted enough to pass a concentration test, no matter how many thousand kilos of waste actually got to the harbour.
And that is where we now sit. We have a brand new, tunnelled at great expense, BIG PIPE that conveys all our little problems to three places where they each instantly become BIG PROBLEMS. So big in fact that we probably will never be able to remove the solids and nutrients in the sewage to even a secondary level of treatment, when it rains. But now the Federal Government is telling us we have to be more responsible, when we built a system that cannot really do any better than it does now.
The question remains as to whether it still might be of use to examine the distributed treatment approach again, instead of spending millions and millions of dollars to try to fix our current out of date treatment plants at their sites. Maybe there is a way that by strategically locating some small and medium size treatment plants we can reduce the loading to the plants we are now saddled with such that they, one day, might be convertible to processes that can actually reduce the loading on the Harbour. Time will tell, I suppose, but perhaps the first thing we should be doing is looking at where in that huge web of a collection system there might be places where the sludge collected could be safe for use in agriculture. And that location might be where we could look at both extracting that resource, and reducing the load on the central big old style STP's so that they might actually do something beside pass dilute sewage when it rains.
The best thing we can do now, though, because it costs so little, is to start looking at our older residential areas and seeing where we can get more stormwater to soak into the ground, or be used by trees, grass and other plants. Every bit of water we keep out of the pipes means less flow to the treatment plants, and gives them more of a chance to do the meagre job they can do. Rain barrels, tree wells that connect to gutters, snow piled on grass or earth instead of asphalt, dry ponds that fill up and hold water until it soaks in or evaporates, roof drains spun off to back yards instead of into storm drains, permeable paving, and anything that allows water to soak into the ground. These will all pay back continually in terms of helping the infrastructure we do have, whether ill conceived or not, perform as best it can for us, and for our environment.
Let's set a few things straight here.
1. The best place, with no doubt whatsoever, to direct treated sewage, both liquid and solids types of waste, is back on to the land from which the nutrients in the waste originally came.
2. It is not just possible, but quite easy to treat sewage sludge so that it is safe for use on agricultural lands. This happens now all over the world, and is already common in Nova Scotia.
3. There are some sewage sludges that are probably not suitable for use for agricultural purposes because the sludge is the residual from more than simple domestic sewage (poop) and includes some industrial waste streams that contain heavy metals.
4. Not all sanitary sewage contains industrial waste. Parts of Halifax only produce domestic sewage, or organic waste that can be safely treated to return to replace nutrients stripped from that land by food or forestry production.
5. We do not have very much topsoil in Nova Scotia.
6. Anyone who eats rice eats food grown directly in untreated sewage that is probably from a third world country.
7. In case you've heard otherwise, the solution to pollution IS dilution, IF you can achieve a suitable level of dilution.
Let's take a more careful look at things. The real culprit in this story is the prehistoric (OK, Roman era) gravity sewage collection systems we have been saddled with, and continue to be subjected to by the engineering community and bureaucratic status quo. We have become addicted to these systems, allowing them to grow to unreasonable size, collecting waste from huge tracts of land, to one or two focal points. I've always simply referred to this as tearing a hole in the fabric of the environment. We go to a lot of expense to move all of our small problems to one place where it then becomes one huge problem.
A gravity sewer does several things very poorly. It concentrates what are initially small amounts of heavy metals, and other undesirable elements to a level where they actually become toxic. I hate to use that word because it has been so abused by the media and even some scientists, but lets just say that too much pure water can be toxic. A large gravity sewer collection system has the unfortunate side effect of collecting all the bad things to one place, and in doing so, allowing the sewage from the places that generate most of the nasties to contaminate the sewage that is relatively benign. Can anyone argue that the sewage from Burnside Industrial Park would not be vastly different from that coming from Highfield Park, just across the 111?
The second thing large gravity sewers do is allow water that is not dirty to enter the sewage flow. This is because sooner or later, they all leak. In much of the older parts of Halifax and Dartmouth, our sewers are combined sewers, which means they also carry water that falls as rain and enters catchbasins, footing drains, roof drains and so on. During a rain storm, flow in these old pipes is mostly rainwater. Sometimes 20 or more times what is coming from toilets and sinks and dishwashers. This extra flow added to the large regional collection system causes several environmental and engineering problems. First, it means that the pipes have to be large enough to carry it. When we engineers design gravity sewers, we allow a very large portion of that pipe's capacity for future infiltration or inflow of what would otherwise be clean water. We assume that it will get in, because it does. Manholes, in particular, are a major culprit - I refer to them as water induction devices. This is probably the single largest source of water pollution in Nova Scotia - it happens constantly all day and all night - water that is clean to begin with, leaks into sanitary sewers and is immediately turned to sewage.
Second, this extra capacity is inherently wasteful because it does not always rain, so the large (more expensive) pipes can wait with only a small flow for a while, and are only fully used when it rains. There is capacity that might carry more sewage, but it is used for conveying stormwater when it has to.
When it does rain, we see yet another major problem. If we try to treat what comes out of the end of pipe, we are confronted with a wastewater that does not exhibit the ideal characteristics for biological treatment. Ideally, in a typical traditional wastewater treatment facility, the process works best when the inflow is relatively constant, the temperature is higher, and the organic strength of the sewage is concentrated. These three parameters allow the biology we cultivate in a treatment plant to live and breed at a high rate, consuming all that nutrient our more inefficient digestive processes could not. But when we allow water to enter the collection system, we get three effects that are the opposite of what we want. The flow becomes highly variable - the rain causes peak flows which decrease the time sewage can stay in a treatment facility; the extra water is almost always cold, which lowers the overall sewage temperature and slows the biology working in the sewage treatment plant; and the extra water dilutes the waste stream, making it harder for the bacteria we want to be living in the treatment plant to find food. When it rains, it's as if those good bacteria we want to work for us are being abused - they are given less time to do the job, it is cold and they are slowed down by that, and it is harder to find the food to eat.
Finally, when we try to separate out solids so that they can be composted and otherwise treated for return to the soils from which they were initially taken, all that extra water makes it a very much more difficult task to do.
Large collection systems are a mistake. But we have them because we have always had a reflex reaction to the sewage we generate. Nova Scotians are fixated on flushing all our poop to the ocean, or to some bit of natural water somewhere. We are so tunnel visioned in this regard that we continue to build new outfalls to our lakes and streams and bays and estuaries, even when a less expensive option for returning the treated effluent to the land exists (read about drip irrigation dispersal of treated sewage effluent). Our history is terrible when we look back at the sewage systems operating in Nova Scotia today, from an overall environmental view. Why is sewage that is generated out by Kearney Lake being dumped into Halifax Harbour, miles away? This when the community generating that waste stream brings in treated water to irrigate its parks, and fertilizer (some of it from human waste in Milwaukee) to keep them green?
Why do we go to all the trouble and expense to create a huge concentrated point loading on the environment in the harbour, when the initial dilution of the pollution was not nearly so bad, and, close to the place where it was generated, comparatively simple to treat to tertiary levels, as compared to the basic screening and semi-digestion now practiced by our already out of date treatment plants? Why? The answer to that, when I asked back in 1992 was "Because that's the way we've always done it." Is that good enough for you?
Back to the sludge (I dislike the term biosolids, as it is not specific enough) from treated sewage. These large collection systems guarantee that people's objections to the reliability of the quality of the sludge produced from the waste at the end of these large collection areas will be valid. Heavy metals are fine in low concentrations - they exist in nature in low concentrations. In fact some metals exist in our native soils in fairly high concentrations (copper in the soils in Halifax, for instance is usually above CCME flagging levels, naturally). But when we go to the trouble to bring all the bad stuff to one place, then filter it all out from the water, concentrating it even more, we create a new material that may have more than is safe for use on crops we plan on eating.
So why don't we treat our sewage in smaller batches, closer to where the waste is generated, "at source" so to speak, where we can identify what sub-sections of our community generate solids that are safe, and can be safely used, while making sure that other waste streams are not included in that dispersal path?
If we used some careful public health engineering (by the way, Nova Scotia has no Public Health Engineer - the position was eliminated in a government restructuring back in the 90's) we could achieve a safe and secure supply of sewage sludge that could be treated to produce a composted land amendment or fertilizer that was safe from industrial contamination. Instead, we try to rely on diluting the industrial wastes back into our domestic wastes, with no reliable way of knowing on which day there is too much industrial contamination happening.
Back when the Harbour Cleanup was being proposed, I was one of a few people advocating for a solution based on a distributed form of sewage treatment. My point was that if the Harbour had not gotten dirty all at one time, it need not be cleaned up in an instant either. We could address the sewage treatment one community, one neighbourhood at a time. Treating the sewage before the massive inflow from rainfall and the contamination for industrial sources complicated the problem to the point where we could never afford to ever do tertiary treatment. All that was needed were treatment plant solutions that a community could accept as suitable in scale and nuisance, to host in their neighbourhood. That could take the form of underground/basement Sequencing Batch Reactors, community greenhouse based Solar Aquatics™ systems, or anything else that modern technology presented us with. Once that neighbourhood was served by a tertiary treatment plant, it would no longer be a part of the problem - the STP could simply discharge into the nearest major trunk sewer, which was probably originally a brook, making it that much cleaner, and the harbour subsequently that much cleaner as a result.
This approach had other advantages over the mega project that Halifax was hurtling towards. It was predicated on the idea that it did not all have to happen at one time. So the project might be funded out of an annual capital works budget, not some mega borrowing that we will owe money on forever. And the work could be designed and built by local engineering and construction firms, not by huge multinational corporations, meaning that we could create a centre of excellence in small to medium scale urban sewage treatment here in Halifax. Perhaps the best thing was that we could go out and solve the easy problems first - cherry-pick the places where the sewage was least dilute, where a location for a STP was available, and just clean that up. But do it so that 99% of the sewage was treated, as opposed to the +/- 40% we have now. We only really need to treat half the sewage going to our harbour to tertiary levels to remove the same amount of pollution as is now being done by treating it all to 40% removal! And the tough parts? Maybe by the time we had gotten all the easy parts done, a new technology will have been developed that can handle those (and this appears to be on the horizon now, with advances in microfiltration).
At the time, the absurd criticism we got from the old engineers in HRM was that there would be too many plants to operate - they would require too many people to run. This when NSPI runs all its hydro stations all over Nova Scotia from one control centre in Ragged Lake. And when the idea of a few good paying local jobs instead of cash sent to France for mega-project gear made some economic sense.
Of course, also at the same time, our rational arguments were hijacked by some well meaning, but ill informed eco-socialites who thought it a dreamy idea that a Solar Aquatics greenhouse system for Halifax would be just peachy! In fact they were advocating that the main treatment plant for all that dilute cold sewage in Halifax be treated in one greenhouse. I worked it out one day - the greenhouse would have to cover all of the Dockyards from Pier 9 to Purdy's Wharf to even have a chance at treating all the sewage in one place. But about 35 small to medium size treatment plants could do all of the metro area. This because the smaller plants would not be treated the huge peak flows that exist at the bottom of THE BIG PIPE. And we would not need any tunnels or outfalls - we'd just let the treated effluent flow out via the existing outfalls. Sure, a few could be consolidated or extended, but there would be no need to put it all in one place like we do now. And sooner or later, we'd have it all done. One bit at a time, the same way the harbour got dirty in the first place.
If this makes some sense to you, then you understand the concept of loading. See here for more on that if you don't. But this approach might have been impossible to get regulatory approval form because the regulators cannot apply common sense, they have to apply old standards based on the concentration of flow to the Harbour. They might not be able to look the other way when three pipes are say, 95% treated, but the one beside it isn't treated at all. Despite the net removal of pollutant being the same as what wold exist if they were all treated to a 75% removal. What they have accepted is a concentration based effluent discharge permit where it is possible that nothing is actually removed from the sewage, but enough water is added to it to dilute the concentration below some theoretical level. No one really cared about whether the harbour was being cleaned up, they cared about whether the stuff leaving one or two pipes was diluted enough to pass a concentration test, no matter how many thousand kilos of waste actually got to the harbour.
And that is where we now sit. We have a brand new, tunnelled at great expense, BIG PIPE that conveys all our little problems to three places where they each instantly become BIG PROBLEMS. So big in fact that we probably will never be able to remove the solids and nutrients in the sewage to even a secondary level of treatment, when it rains. But now the Federal Government is telling us we have to be more responsible, when we built a system that cannot really do any better than it does now.
The question remains as to whether it still might be of use to examine the distributed treatment approach again, instead of spending millions and millions of dollars to try to fix our current out of date treatment plants at their sites. Maybe there is a way that by strategically locating some small and medium size treatment plants we can reduce the loading to the plants we are now saddled with such that they, one day, might be convertible to processes that can actually reduce the loading on the Harbour. Time will tell, I suppose, but perhaps the first thing we should be doing is looking at where in that huge web of a collection system there might be places where the sludge collected could be safe for use in agriculture. And that location might be where we could look at both extracting that resource, and reducing the load on the central big old style STP's so that they might actually do something beside pass dilute sewage when it rains.
The best thing we can do now, though, because it costs so little, is to start looking at our older residential areas and seeing where we can get more stormwater to soak into the ground, or be used by trees, grass and other plants. Every bit of water we keep out of the pipes means less flow to the treatment plants, and gives them more of a chance to do the meagre job they can do. Rain barrels, tree wells that connect to gutters, snow piled on grass or earth instead of asphalt, dry ponds that fill up and hold water until it soaks in or evaporates, roof drains spun off to back yards instead of into storm drains, permeable paving, and anything that allows water to soak into the ground. These will all pay back continually in terms of helping the infrastructure we do have, whether ill conceived or not, perform as best it can for us, and for our environment.
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