Adoption for the "traditional" delivery method for the Whistler WWTP Upgrade, and the continuation of an improved RMOW operation will ensure the highest value, the best environmental protection and the most appropriate short and long term solutions for protection of the community well being and tourist industry.

The above is proven through the following:

1. The RMOW has prepared a staged program for the traditional approach, that provides the transparent checks and balance needed to complete the wastewater treatment program through maximizing value both in operations and facility design.
2. The approach using Dayton & Knight Ltd. (traditional approach) offers competitive treatment solutions that for Whistler, will exceed the opportunities for maximizing value when compared to those offered by a DBO delivery
3. The current Whistler WWTP operation and maintenance provide effective cost and environmental accountability, relative to the Canadian norm, confirming the viability of the public operation over a need to risk the uncertainty of cost reductions in a DBO operation.
4. The "traditional" approach allows the RMOW to better respond to treatment needs that can be provided in a DBO approach, to protect the RMOW's natural status, where rests the ultimate accountability for overall environmental protection, public welfare, tourism and community well being.
5. The RMOW has a responsive planning and engineering process that has proactively determined wastewater design objectives for the Whistler WWTP, eliminating the opportunity of DBO proponents to change design standards and reduce cost.
6. The "traditional" approach maintains the balance and consistency needed in Whistler's design and operating practice for its water and wastewater treatment, to secure continued desirability as a year round tourist destination resort and remain a number one resort in North America.
7. Selection of Dayton & Knight Ltd. as the designer (conforming to the traditional approach) aids in the speed at which the treatment options are explored and developed to maximize facility value.
The following discussions refers numerically to the conclusions and comments regarding the PBC report.


Discussion


1. RMOW Staged Program and Dayton & Knight Predesign Reports


The RMOW Staged program includes 9 stages that provide the checks and balance needed for updating the pre-design work (including provision of new process alternatives), undertaking design reviews, project management, value engineering, derailed design and completing construction and post-construnction services to ensure that the key goals of the wastewater treatment program are met.
In review of the PBC reports, we conclude that the PBC analysis reflects an incomplete understanding of the 2000 and 2003 Pre-design reports by Dayton & Knight Ltd.; it is important to clarify these issues. For example, PRC reports that the capital cost estimate of $19 million presented in the 2000 predesign report was "revised" to $25.92 million in the 2003 report, but no further explanation is given. In fact, as described in detail in the 2003 report, the increase in estimated capital cost was due to sharp increases in construction costs over the preceding 2-3 years (which applies no matter what method of project delivery is used), and more significantly to changes in the liquid treatment processes. PBC increased the Pre-design report costs by about 11 %.



The process layout described in the 2000 Pre-design report retains the existing trickling filter, while adding supporting activated sludge tanks to allow operation as a biological nutrient removal (BNR) process; this process has been well-proven at the full-scale facility at Salmon Arm. The process layout described in the 2003 predesign report is based on replacement of the trickling filter with equivalent additional activated sludge tankage, replacement of chlorination with UV light for disinfection, and a number of other process changes, all of which were made in consultation with RMOW staff while recognizing that the original (2000) process configuration might still be used in light of budget constraints. Appendix 1 provides a comparison of various treatment options from the Pre-design report with adjusted values for the PBC proposal.



It is important to note that these process selections were based on the 1993 RMOW Liquid Waste Management Plan (LWMP) the 2000 Pre-design processes. The 2003 draft update was to provide an update for costs only. Preassessments in design process options were not requested or undertaken. For example, new processes such as Integrated Fixed Film Activated Sludge (IFAS) are now in use in North America. The IFAS process can reduce tank size, and should be considered for Whistler. In November 2003 the Squamish composting option was not available. Today it is and should be explored, but why not consider one closer to Whistler? The Squamish operation is now at capacity and an expansion would be needed to meet Whistler's needs in any case. Air dispersion studies to ensure success of any odour treatment upgrade, should be undertaken to confirm the odour treatment solutions. These studies and re-examination of other facilities, which could include Jasper are part of the Basis of Design process.



The 2004 RMOW Staged Program includes nine stages, is established for the traditional delivery and is transparent to all stakeholders. In the Staged Program, a project control plan in Stage 1 is used as an open document to manage the project deiiverables for its subsequent stages. This includes the Stage 2 work that dcvelops (with the RMOW and other professionals), a revised upgrade solution that meets the financial, social and environmentai needs of the community. The addition of a project manager (Stage 3) with construction as well as operational expertise in the Stage 2 work, secures the balance needed to meet a key RMOW goal of balanced design. Stage 4 includes a "value engineering" exercise that refines the program to confirm the goals are met. The subsequent 5 stages of design, checking, tendering, construction and post-construction complete the delivery. The last stage includes training and is recommended to further include a process audit to increase the operational effectiveness and value received. Stage 1 of this work is currently in progress.



Further, the assertion in the PBC report that the RMOW will not have access to market innovation and best practices under the traditional method of delivery is false. The consulting business is highly competitive, and as a consequence Dayton & Knight Ltd. engineers must maintain an up-to-date knowledge of developing and proven methods of wastewater treatment, and continually strive to stay at the forefront of innovation, (See our list of innovative designs attached as Appendix 2). Alternative processes to those recommended in the predesign reports were evaluated at the time those recommendations were developed. The recommended processes were selected in light of evaluation criteria that included, capital and operating costs, performance capabilities, reliability, simplicity of operation, community needs, LWMP goals and regulatory requirements. Review and finalization of the process layout and components in light of budget constraints and other factors are included in the "traditional" project delivery during method in the Stage 2 Basis of Design.



The RMOW 9 Stage process secures the innovative approaches needed to maximize value using the "traditional" project delivery method. This is not available as an open process in a DBO.


2. Competitive Treatment Solutions, Process Selection and Cost Estimates


The Dayton & Knight Ltd. (traditional) approach offers competitive treatment solutions that for Whistler, will exceed the opportunities for maximizing value over cost when compared to a DBO delivery.



The cost estimates presented in the 2000 and 2003 Dayton & Knight predesign reports were developed by a specialized team of engineers, each of whom has decades of experience in all aspects of wastewater treatment plant design, construction, and operation. Engineering analysis used to develop the D&K cost estimates included process design for sizing of treatment units, estimates of materials quantities, unit prices based on recent construction experience, and price quotes from suppliers for major equipment; these and other details were presented in a spreadsheet and summed to develop comprehensive cost estimates for each process unit.



In contrast, Appendix C of the PBC report provides a "shadow bid" to support theoretical cost savings. This "shadow bid" is a cursory estimate of costs, with no supporting documentation or engineering analysis. Process design is not fully developed or clearly explained. No sizing of treatment units is mentioned, and cost estimates are presented simply as lump sums. Nearly ail of the odour control facilities described in the D&K predesign report have been arbitrarily dropped; in spite of the fact that the proposed DBO approach includes activities that will generate strong objectionable odours such as fermenting of crude sludge, belt press dewatering of fermented sludge, loading and truck transport of untreated dewatered sludge, and handling and treatment of high-strength pressate from dewatering operations. The comment included in the PBC report that the processes proposed for the DBO shadow bid "will eliminate and/or minimize odour generation potential" is not substantiated by sufficient descriptions or reference. (The Jasper operation is referenced and suggests that a soil biofilter would be constructed. This system, while effective is not necessarily suited to Whistler as discussed below). Enclosure of all solids handling, dewatering and loading facilities will be required, with multi-stage treatment of captured foul air.



There is no evidence that the costs for the level of odour control needed to meet RMOW requirements have been included in the DBO analysis. The soil biofilter proposed for the DBO approach as the sole means of odour control is not a practical or effective solution for this application. No descriptions of redundancy for process reliability are given, and a size is not provided. A cost estimate of $334,000 is provided, which equates to a biofilter with a foul air treatment capacity of about 12,000 standard cubic feet per minute. This alone would not be adequate for the existing headworks, primary tanks and dewatering plant. There is no mention of the costs for covering the biofilter with a roof, which would be required for moisture control and would have to meet building code requirements for snow load among other things. No mention is made of expected biofilter performance under severe winter conditions. We conclude that replacement of the key odour control works described in the D&K predesign report with a simple soil biofilter for the DBO model is neither justified nor advisable, and that objectionable odours will result, regardless of the liquid treatment processes used. The importance of this cannot be overemphasized, since the wastewater facilities are located adjacent to the Sea to Sky Highway at the entrance to the Whistler area, and odour has proven to be an extremely sensitive issue to the community.



In addition to deletion of key components for odour control, the PBC cost reduction measures also include deletion of the existing trickling filter with no compensating increase in the cost to increase activated sludge reactors. No mention is made of the use of the existing three final clarifiers, and replacement of these units with circular concentric bioreactorlclarifier combination units is apparently proposed. The comment that the reactors will use common wall construction to save costs is not significant, since this is a standard in the industry. The following items, specifically or by implication of cost reduction, are shown to be removed from the PBC program and the "shadow bid":


• Odour upgrade at WBS and Dewatering Building
• Trickling filter odour treatment
• Trickling filter modifications
• Digesters improvements
• Overall odour control for digesters
• Provisional activated carbon (exchanged for small soil biofilters)
• All BNR reactors
• Reclaimed water provisions


The PBC concentric design is only economical where construction of new clarifiers is needed. Three clarifiers already exist at the RMOW plant, and pipe work for the Contract 2 upgrade is already in place. It would be dificult to obtain savings by rebuilding concentric tanks to replace the existing clarifiers and bioreactors. The Jasper BNR plant appears to have been used as a model for estimating costs. The 2002/03 cost of the Jasper BNR activated sludge concentric tank process was about $5.5 million for a design capacity of 7,500 m3/d (total construction $8.4 million less estimated costs for sludge handling and primary 3 fermentation tank). For a Whistler requirement of 24,500 m3/d, we estimate the cost for equivalent concentric tanks would be about $12.1 million (year 2002/03 dollars), which is significantfy higher than the PBC estimate of $7.2 million (year 2005 dollars) used to support the DBO case.



In the DBO proposal, untreated primary and waste biological sludge is to be hauled in sealed containers to Squamish for composting by a private contractor. This reflects an annual cost in the range of $700,000 to $1,690,000 per year, depending on chemical use (capitalized cost about $8 million to $16 million). This is significantly higher than the PBC suggestion for solids disposal that was used to support the DBO case. (See operations below).



In light of the above points, the cursory cost estimate presented in the PBC report lacks credibility, and it cannot be used with any confidence for budgeting purposes or as a valid comparison to support a DBO project delivery.



At the pre-design stage the design and construction is open to review and the RMOW program Stages 2, 3 and 4 allow flexibility in determining new solutions that may be better under the current circumstances. These could include reduction in odour treatment pending air dispersion studies or a desire to defer, or change standards, a change to review the sludge program, and a reconsideration of the method of treatment (i,e. retention of chemical treatment or use of smaller reactor design by incorporating high density media, etc.) These selections would be an open process meets accepted LWMP goals, and secures the most appropriate solutions for the benefit of the community. Appendix 1 provides several comparisons of options that could be explored, but is not limited to these alone.



The WWTP work undertaken in the 1996 upgrade provided considerable underground infrastructure that is availabie for the Contract 2 expansion. The knowledge of this work is not limited to its existence only, but includes our understanding of process design that is not possible to transfer in the time required for a DBO selection process. The DBO learning curve is steep and inherently fraught with risks of inadequate investigation, especially for existing facility expansions. This is why a DBO is not used for existing treatment works unless the new facilities are distinct from the other plant operations, such as Squamish and Jasper. Furthermore, two only DBO consortia have at this time provided DBO serices for similar projects and are available to provide responsetro a Whistfer request for proposals.


3. Operations


The Whistler WWTP operation is effective and can be made more effective in cost and environmental accountability relative to the Canadian norm, confirming the viability of the public operation and ownership over a need to risk the uncertainly of cost reductions in a contract operation.



Of 17 Canadian WWTP facilities, including Whistler, the Whistler WWTP operating cost per unit of flow treated was less than the average and was marginally less than the Banff WWTP contract operation. The Whistler WWTP unit cost was equal to the median. Lower unit rates tended to be for plants that were not well maintained such as Vernon and Merritt or a plant that was able to pass off costs to other operations such as the GVRD NW Langley plant. Higher unit rates tended to be for plants that paid for chemicals to remove phosphorus. Whistler chemical cost is a low since it gets the pickling liquor for free, and its power cost is low, since the use of trickling filters reduces dependency on costly blower energy. (Trickling filter treatment consumes about 300 kWhr/MLD versus activated sludge treatment at 500 kWhr/MLD. Taken from David Reardon, "How Energy Audits can be Used to Achieve Demand Side Management at Wastewater Treatment Plants", WEFTEC.)



The following Table 1 illustrates the existing 2004 budget. The table illustrates the percentages of costs relative to each O&M component. The percentages are indicators of potential cost reduction opportunities. These percentages have not changed significantly in five years of record. The Whistler WWTP annual cost is about 0.29/m3 treated. This will reduce as flows increase.



TABLE 1
WHISTLER WWTP OPERATIONS COSTS



	Component	%	Cost 2004 Budget
1	Labour	47.4	$592,940
2	Power	12.5	$156,000
3	Gas	4.6	$58,000
4	WWTP Maintenance	24.9	$310,936
5	Bulk Chemicals	9.7	$121,500
5	Miscellaneous	0.9	$10,700
	Total	100	$1,250,076




We note that annual labour is about $70,000 to $100,000 per staff. Annual power is about $40,000 per 100 kW/load. Maintenance is on average about 4% to 6 % of the capital investment per annum. Lower percentages indicate a preference to replace older equipment with capital improvement work. Very low percentages less that 2% of the capital investment indicate that the facility is not being maintained.



The PBC Operating Costs identify "innovative operations and maintenance planning" will reduce the O&M budget, but that employees would be reduced after the second year of operation and power costs would be reduced for sludge stabilization. PBC indicate the following comparative operations costs as shown in Table 2.



TABLE 2
PBC PROJECTED OPERATIONS COSTS BNR TREATMENT, $1000's



Year of O&M $	2004	2005	2006	2007	2008
PBC O&M	$1,240	$1,273	$1,617	$1,332	$1,359
2000 Pre-design	$1,240	$1,291	$1,629	$1,662	$1,696




By 2007 the annual PBC O&M costs drop by $330,000 below the projected pre-design costs. Whistler currently uses replacement and general maintenance of about 2.3%. This is close to the basic minimum below which infrastructure is in decay. A drop in chemical cost for chlorine ($20,000-25,000 l/yr) is offset by UV disinfection power and bulb replacement cost. (Note, the balance of the chemical cost is for polymer use, and would not decrease but could increase if no digestion is undertaken). The PBC proposed reduction in power for the digestion facility is about 120 kW which is about $48,000 per year. This means that the remaining annual O&M drop of $280,000 must be found elsewhere. This difference can be made up of a loss in up to 3 staff and/or a drop in maintenance below an already minimum value. This is not likely a sustainable solution. (When adjusted for flow equivalency and treatment capability with Whistler, the City of Chilliwack has an equivalent unit cost of $0.31/m3. The Chilliwack operation has been tested in the market and is shown to be too low for a competitive contract operation. Whistler is slightly below the flow and process adjusted Chilliwack value.)



Sludge treatment. In the PBC proposal, the primary and waste biological sludge is to be hauled in sealed containers to Squamish. We can only assume that the untreated sludge will be dewatered on the existing belt filter press. No provisions for this are however, identified. The use of the existing digesters is not identified. If permission can be obtained to haul untreated sludge (there is no precedence of approval for this in BC), the current receiving cost at the Squamish Composting facility is $60/wet tonne. (Note this is low relative to the Nanaimo BC compost operation at $69/wet tonne.) Haul cost for each 10 tonne container is $200. For Whistler, if it achieves an 11 % cake as in Squamish, the daily wet tonnes would be about 40 to 58 wet tonnes per day. If fortunate, 18% solids content might be achieved and would reduce the amount to about 24 to 35 wet tonnes per day. This reflects annual costs of a low of $700,000 per year to a high of $1,690,000 per year depending on sludge dryness and chemical use. A 20 year capitalized cost of this, using Partnerships BC discount rates would be about $8 million to $26 million.



lf the sludge hauling and compost solution is used as part of a sludge management plan, the digesters could be retained and used as is or the expansion made and paid for by the savings. Digestion would reduce the mass of sludge by 40% and through better dewatering (to 30% solids) the weight could be reduced to 15 to 21 wet tonnes per day, The predicted savings of $4 to $10 million over 20 years would pay for the improvements plus operating costs. More likely the product would not need to be all hauled to Squamish, allowing local use and sales as presently done. This would increase the savings. PBC has not included the cost of the sludge transport and processing cost at over $700,0OO/year for the Squamish disposal. When included, the PBC annual O&M is therefore closer to $2 million.



Operating Costs Elsewhere. Operating costs are higher for contract operations since for the same effort to meet regulations, private operations increase rates to meet profit expectations. This is a key reason why the UK contract operations cost per unit of water treated is $1.60/m3 versus the Canadian average of $1.05/m3 (D. Taylor, et al., Sustainability Through Increased Water Rates, Earthtech, presentation to YWWA, Whitehorse, YK, Nov 24,2004, and Karen I. Bakker, "From public to private: to..mutual? Restructuring water supply governance in England and Wales", Geofomm 34, Pergamon Press, (2003), pp 359-374.) The UK was forced to increase regulations dramatically after the purchase of the public utilities by private operators since water treatment requirements were not being met. This has resulted in the higher costs to meet profit expectations and compares with lower costs to meet similar effort provided by public utilities in Canada. Neither Canada, BC nor Whistler has the current regulations to manage a private operator for water and wastewater. The Province of BC through the Ministry of Water, Land and Air Protection, promulgated the Municipal Sewage Regulations with specific provisions to limit or eliminate private operating companies from managing wastewater systems in favour of municipal or regional government management. We understand that the BC Ministry of Finance is supportive of the DBO as they see it as a means of reducing public expenditure. This is a false premise based on insufficient study.



A benchmarking exercise has shown that the current Whistler WWTP operations operates below the national average in cost per unit of flow treated and was shown to be below the cost for a DBO facility of similar design and complexity. To achieve the PBC O&M cost savings, cost reductions must cut labour and maintenance. Maintenance is already at a level that just sustains normal replacement levels at the plant.



An IS0 14001 process audit initiated by RMOW and undertaken by a third party would provide a review of the labour requirements. The audit would determine the appropriate level of operating effort and accountability as well as other operational costs. A Life Cycle Analysis (LCA), to achieve the desired value, as opposed to hoping that a DBO will provide the right balance of effort needed. Vail Colorado, Summerland BC and ultimately Chilliwack, BC have tested the use of Contract Operations, and are continuing to operate as a public entity. The Regional District of Nanaimo (RDN) BC is initiating an Environmental Management System (EMS) that is part of the IS0 14001 program. RDN too has rejected the DBO process as less favourable than the "traditional" approach.


4. Accountability


The current approach of design, construction and operation allows the RMOW to better respond to treatment needs than provided in a DBO approach, since the municipaIity is ultimately accountable for overall environmental protection and cost.



The RMOW retains overall accountability, which is not transferable in a DBO contract, for managing the treatment solutions and accepting responsibility for environmental impacts and LWMP goals. The current responsibility, through involvement with the design and operations processes, provides greater assurance that systems are adequately evaluated for best performance than can be obtained in a DBO. Once entrenched, a DBO has its own bureaucracy and self determining structure that does not respond to issues other than the bottom line costs.



The PBC business case presented in support of the DBO approach relies heavily on deletion of key treatment units described in the pre-design reports by Dayton & Knight. The principal cost-saving measure is based on deletion of all solids digestion, facilities and associated odour control works, with export of untreated wastewater solids generated at the Whistler wastewater treatment plant to the Squamish area for composting by a private contractor.



Trucking of untreated solids to a composting plant in Squamish is a high risk solution from a financial, environmental or political perspective. This approach would have to be developed in much greater detail before being proposed as a method of significant cost reduction for a DBO bid.



If the private composting facility at Squamish becomes unavailable for any reason, (e.g., closing or relocation of the business, public protest, change in environmental regulations), the RMOW will be left without a means of dealing with untreated solids. This has happened with the Capital Regional District (Victoria). Also truck spills of untreated sludge in an environmentally sensitive area along the Sea to Sky highway is not acceptable. (See Vail CO prior to installing digestion treatment.) It is noteworthy that several composting facilities in the USA have been shut down within a short time of being constructed, mainly due to odour concerns and public protest. This risk can be reduced by constructing a municipally owned composting facility, provided that the capital and operating costs for the facility are included in the analysis or having Carney construct a facility in Whistler. Location of a site for a publicly owned composting operation would be controversial and could take several years to complete. This risk is not transferable. The RMOW would retain responsibility for change and costs in a sludge handling options of this magnitude.



In general, solids handling schemes that rely on a single end user that is beyond the control of the Municipality are at high risk of failure and are inadvisable. It is strongly recommended that the RMOW retain solids digestion at the WWTP, to maximize the potential for a multi-pronged approach for beneficial use of treated biosolids over the long-term future. Other complications associated with the proposed DBO approach for solids handling are further discussed in the items below.



A DBO approach to reduce cost will develop limited low cost solutions, which limit flexibility. This finds its way in the DBO argument as a redistribution of risk. The shuffle of risk and responsibility away from the municipality to those presumed to best manage them is the false argument of reductionism, since the global risk is not reduced and the accountability remains with the RMOW. To pass off this responsibility increases the liability of the municipality since Whistler still guarantees the environmental protection and amenities that brings wealth to Whistler in tourist dollars, but allows a DBO contractor to control the means of production and criteria for managing them, purely on equity (bottom line) based objectives. Those who control the risks for profit need to be carefully watched. This is the case in DBO - public partnerships. This is always the case in a DBO-public partnership. Banff AB is an example when the DBO operations arm had control over thc process and not the Owner. The DBO operation was fined for falsifying records but many of the problems were unreported.


5. Wastewater Characteristics and Design Criteria Cost Impact


The RMOW has a responsive planning and engineering process that has proactively confirmed wastewater design objectives for the Whistler WWTP over a period of many years, eliminating the opportunity of DBO proponents to jeopardize standards.



The PBC document appears to imply that the wastewater characterization and criteria are not sufficiently advanced to undertake design. The 2000 pre-design criteria represent data assembled from over 15 years of involvement with the municipality and over time, minor changes in the influent characteristics have been documented and corrected for the past design stages. The design criteria in the 2000 Pre-design report were obtained from RMOW Official Community Plan, and were reviewed by the RMOW planning and engineering. The build-out capacity is within a few years of completion. The growth criteria are included in the current Liquid Waste Management Plan Update, (2004) and are the benchmark for the wastewater treatment plant loading criteria. In the Stage 2 Basis of Design investigation, the RMOW would require that design population loading be reviewed, and the design account for 2010 Olympic needs. This review will also necessitate an update of influent loading trends and magnitudes. This is understood, but is not anticipated to significantly affect the treatment unit sizing.



In Jasper, AB, the original design was changed several times to accommodate the Town's projections and Parks Canada revisions. The original plant design undertake by Stantec was based on a higher contribution for about 26,000 people. This was later reduced to 20,000 people for the DBO project. The PBC however, compare the savings demonstrated for the DBO for these two differing design levels. Similarly, the design standards were reduced. This flexibility in standards reduction should be applied to Whistler, where the planning and engineering for the community have been developed to meet known growth requirements and the treatment expansion represent only a small part of the whole design. Changes in design criteria should be assessed and can be undertaken but should be done with the full community needs considered.



This is similarly the case for other facilities including Squamish BC, Chilliwack BC and Banff AB. Squamish was a new stand-alone project. Banff however, was already constructed to allow the expansion as a logical final step, but did include some change to suit advances in process design. Chilliwack improvements are being undertaken by addition of unit processes of known standard. These projects cannot demonstrate cost savings over traditional design where standards are not permitted to be reduced.


6. Environmental and Other Factors


To remain as a number one resort in North America and protect the tourist industry of the community, the RMOW while remaining imaginative in its administrative, planning and engineering activities, will need to maintain balance and consistency in approaching its wastewater and water treatment cesponsibitities. This consistency is essential to avoid unwelcome controversy and criticism in securing its desirability as a year round destination resort.



The analysis contained in the PBC report is focused almost entirely on cost reduction, which is variously referred to in the report as "efficiency" and/or "innovation," which are said to be unique to the DBO approach and not accessible to the RMOW if the traditional approach is used. We point out that deletion of one or more components of a proposed construction project to reduce total project costs is routinely used throughout the engineering and architectural communities on an as-needed basis in light of budget restraints regardless of the method of project delivery. The DBO approach has no inherent advantage in this regard.



The PBC program contains a media and public propaganda campaign that will cost time and energy to allay public and media concerns to the DBO process. An approval campaign is not needed for the current traditional approach since the program would be undertaken by the RMOW and the project has already been through a public process. Rather an information web site would be used to keep Council and the Whistler community informed of project progress. Public distrust in the DBO process was a key reason for not proceeding with a DBO for the much more expensive GVRD Seymour Water Treatment Plant.



The DBO focus on cost reduction does not present a balanced comparison of this approach with the traditional method of project delivery. Components absent in the DBO analysis, which have no means of measure or inclusion, are environmental protection and tourist industry value. These aspects of the project are doubly important in light of the approaching 2010 Olympic Games. While it is true that the costs of the project can be significantly reduced by deleting key process components such as odour control and equipment redundancy for process reliability, and by reducing operating staff, the cost savings must be balanced with the resulting increased risk of environmental damage, generation of nuisance odours, and public protest (e.g., labour disputes associated with contracting out of public sector jobs and layoffs, transport of untreated sludge along a sensitive river corridor, export of untreated waste to Squamish, etc.).


7. Regulatory Issues and Project Schedule


Selection of Dayton & Knight Ltd. as the designer that conforms to the traditional approach would greatly aid in the speed at which the various options could be explored and developed to maximize value for cost.



The PBC proposed approach for solids handling (i.e., deletion of all digestion facilities at the treatment plant with export of dewatered untreated waste solids to the Squamish area for composting by a private contractor) represents a major departure from the RMOW's updated Liquid Waste Management Plan (LWMP), which was recently approved by the Minister of Water, Land and Air Protection. The RMOW is legally bound to follow the approved LWMP. Before the PBC method of solids handling can be adapted, the LWMP will have to be reopened and revised to reflect the proposed change in direction for management of waste solids.



According to Provincial guidelines, revision of the LWMP requires striking of Technical and Local Advisory Committees to represent government and community interests (this approach was followed in the recent updating of the RMOW LWMP). The proposed DBO approach will then have to be developed in sufficient detail to allow comparison with the LWMP solutions as currently written (including a much more detailed and credible cost estimate as well as other potential advantages and disadvantages). This information will then be presented to the Advisory Committees for discussion and comment. Once approved by the Committees, the proposed new approach is presented for public/stakeholder consultation and feedback.



Based on past experience, the RMOW can expect revision of the LWMP to take at least one year to complete. The time frame cAN be considerably longer if significant public opposition to the proposed new method of solids management is encountered. Public opposition can be expected, since residents of squamish have shown in the pasT that they strongly object to accepting wastes from the Whistler area. The time frame for revising the LWMP has not been allowed for in the schedule for the DBO approach, and the claimed completion of construction and commissioning of the treatment works by April 2006 is completely unrealistic.



The proposal to haul untreated sludge to the compost operation in Squamish is not allowed as part of the Province of BC sludge composting regulation. If permission can be obtained to haul untreated sludge (there is no precedence for this in BC), it is likely that the RMOW would be better to negotiate this agreement that a DBO contractor.


RECOMMENDATION


The analysis presented in the Partnerships B.C. report to support the DBO method of project delivery reflects a poor understanding of the design and construction of wastewater treatment facilities, of the needs of the RMOW and other stakeholders, of regulatory requirements in British Columbia, and of history of the infrastructure already in place at the WWTP. Consequently, the PBC exercise in support of DBO lacks credibility, because it rests on unrealistic and erroneous assumptions.


The RMOW will still be held accountable by the members of the community for the end result of the project, which must include comprehensive environmental protection, greatly reduced risk of nuisance odours, and regulatory compliance in addition to responsible expenditure of public funds. Support for a DBO can be made only for political or self serving reasons. Its selection over the current traditional approach lacks or excludes common sense, ethics, imagination, history and reason.


For this project, the RMOW would best be served by the traditional method of project delivery, where the RMOW's interest is represented throughout by the Municipality's consultant through ongoing communication and consultation, and crucial decisions that affect the public good rest with the Municipality.


Thank you for providing us with an opportunity to comment on the PBC report. We would be pleased to elaborate on the above discussion and provide additional details and comment if needed.



Yours truly,

Dayton & Knight Ltd.

Signed by Harlan G. Kelly, P.Eng.

Cc:John Nelson, P.Eng.

Brian Barnett, P.Eng.