LETTER – Turtle Valley biosolids project meets rigorous regulatory standards

(Image: Screengrab, CFJC TV)

Re: Turtle Valley biosolids project

We recognize there will always be a diversity of opinions on innovative initiatives like the project at the Turtle Valley Bison Ranch.

We respect people’s rights to express their views, even if they’re not ones we share. However, Ms. Fryatt and those who actively oppose the project continue to make statements and claims we would like to address.

Arrow regularly evaluates biosolids opportunities, looking at things like topography, water and air quality and transportation impacts to determine whether the proposed project is a good fit.

Most are not. The company does not take on projects that cannot be done responsibly and safely.

Many Arrow employees live in this community and region, too, and share Turtle Valley residents’ interest in ensuring the health and wellness of land, water and people.

Let us clear up confusion about our 777-dry-tons-per-hectare application rate.

Ms. Fryatt and others speculate we are planning to apply biosolids in amounts that greatly exceed those permitted in other jurisdictions.

This ongoing apples-to-oranges comparison implies our project and B.C.’s regulations governing the beneficial reuse of biosolids are irresponsible, inadequate, and unsafe.

So why is there a 22-dry-tons-per-hectare limit in Ontario and we’re planning to apply 777-dry-tons-per-hectare at Turtle Valley?

Because the type of biosolids project determines the application rate.

The often-cited limits for Ontario, Holland, Denmark, and Manitoba are for year-after-year, direct-surface applications where the project objectives are to fertilize crops and improve the soil’s organic matter and suitability for sewing seeds.

At the Turtle Valley site, our objective is to build a productive soil on land that is rocky glacial till, was previously forested and recently logged, and is low in organic matter and fertility.

We are not fertilizing an existing crop through direct surface application of biosolids on a regular basis. Instead, we are turning disturbed, non-agricultural land into healthy agricultural land, by making and applying a fabricated soil.

This soil, comprising nine-per cent biosolids, will provide nutrients and organic matter to the existing mineral soil in order to establish and sustain a perennial grass pasture.

This fabricated soil enables nutrients to release slowly over time, meaning the site will not require additional fertilization for five or more years.

This is a responsible and safe biosolids project with significant support.

Our project at Turtle Valley Bison Ranch is designed to meet rigorous regulatory standards and has the backing and support of many.

We continue to work diligently to keep the community informed about what we are doing and produce a project newsletter which anyone can access at

We want open and constructive dialogue about our biosolids projects and encourage anyone with questions and comments to reach out to us at

TIM BELL, Arrow Transportation
JEFF MAYER, Arrow Environmental
CONRAD SCHIEBEL, Turtle Valley Bison Ranch

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6 Comments on LETTER – Turtle Valley biosolids project meets rigorous regulatory standards

  1. Thomas Maler // May 6, 2019 at 1:01 PM // Reply

    I would like to dispute the claim that this practice is “rigorously regulated” in this article, but the best way to respond will be to quote my recent LTE in the Salmon Arm observer:
    In response to your article “ Effectiveness of human waste as fertilizer examined during community meeting” on March 26th 2019 by Jody Brak.

    Your article included the following quote: “The company also provided some clarity as to how biosolids differ from more commonly used manure during the meeting, and spoke to how the harmful contaminants in sewage sludge are removed.” Well, it is NOT possible to remove harmful contaminate from the sewage sludge, otherwise called biosolids and I will try to explain why that is not possible, and it will become more clear once we understand (see list below) what’s in the sewage sludge/biosolids. Other misinformation coming from the sewage sludge purveyors Arrow Transport, is also easy to refute, like claiming that bacteria and high temperatures will deal with the bad stuff in the sludge. Bacteria used in the treatment process and in the anaerobic digestion that produces the biosolids cannot possibly destroy or degrade even a small fraction of the toxic and pathogenic goulash that’s in the biosolids/sludge and 70 degrees used in anaerobic digesters is not nearly enough to do anything except to grow the bugs. A temperature of 700 degrees would be needed to do any significant damage to this toxic soup.

    But let’s look what’s in this toxic sludge sometimes called by the “greenwashed” term biosolids:

    it contains all the industrial and domestic waste that goes into our sewers – which includes approximately 85,000 chemicals in circulation today,
    Superbugs (multi drug resistant bacteria that get amplified in all sewage treatment plants) and their the drug resistance genes,
    micro plastics that don’t get degraded but get washed into our streams, rivers and the ocean where they get eaten by fish and other marine creatures and subsequently end up back on our plates
    micro fibres that don’t get degraded but get washed into our streams, rivers and the ocean where they get eaten by fish and other marine creatures and subsequently end up back on our plates
    scores of other pathogenic organisms including the deadly prions that cause a number of lethal diseases in humans and in animals.

    None of these chemicals, superbugs, prions, micro-plastics and micro-fibres will get destroyed by any of the processes used to make biosolids because the bacteria and the low temperatures used in the process cannot destroy these toxic and lethal substances and organisms.

    Most Canadian and US municipalities choose the cheapest (and most environmentally damaging) way to get rid of this toxic soup (unwisely allowed by both the federal and provincial governments) – spreading it on the land under the guise of “beneficial reuse” where it is most often called fertilizer, compost etc. Once applied on the land, it is there forever except for the part that gets washed away by rains into streams, rivers and the ocean where it pollutes every body of water that it comes into contact with. Sadly it also pollutes the air during drier seasons when winds pick it up and spread it around. Once the land is polluted with these sewage residuals or “biosolids”, crops grown on it take up varying amounts of these tens of thousands of chemicals and we end up eating them and polluting our bodies with these toxins.

    There are much safer and environmentally friendlier ways of getting rid of this toxic sludge – a gasifier or pyrolysis unit could generate syngas that can in turn be converted into electricity. Municipal solid waste including all plastics, scrap wood and even kitchen scraps could be used along with the sludge to generate electricity! Why all 3 levels of government are ignoring this sustainable and truly green option escapes me!

    For much more comprehensive and up-to-date review see “Polluting for Profit – the “biosolids” business model:

    Also, you can read my more comprehensive review on the subject called
    An Overview of the Dangers of Sewer sludge (Biosolids)

    Thomas Maler, Ph.D.

  2. alan horne // May 4, 2019 at 11:31 PM // Reply

    Let’s clear out the nonsense in the Arrow letter.

    The authors expend eight paragraphs trying to convince you that their Bison Ranch operation is different from other biosolids applications, and that therefore the voiced concerns and criticisms don’t apply.

    But in a cursory examination, you see that the only real difference between Arrow’s proposed bison-farm sludge-fest and other biosolids applications is that whereas in other locales the biosolids are supposed to be applied in stages over years, in the Turtle Valley scheme the biosolids are all to be dumped in one huge amount in one short season. Any rational person will see that this is a compelling reason to cancel this project immediately, since obvious concerns such as leachate, odour, aerosol pollution and runoff can only be compounded by concentrating a toxic substance in immense quantities in a small place.

    Continuing in their denial of common sense and objective reality, they insist that to criticize their bison sludge dump is to “imply” that “B.C’s regulations governing the beneficial reuse of biosolids are irresponsible, inadequate and unsafe.”

    Well, I’m not “implying” anything. They ARE exactly that. And no one can say different. You know why? Because the USEPA, which invented the biosolids science and which wrote the rules under which it is applied, just confessed, (last November) that it does NOT have the science to say that biosolids are “safe.” Let me be perfectly clear: the USEPA 503 ‘sludge rule,’ which is followed in Canada, the US and world-wide, and which forms the basis for biosolids applications in BC under the OMRR , is not founded on solid science. There is no such thing as a “beneficial reuse of biosolids”, as the agency which concocted and marketed the product has finally come clean and admitted.

    If you wish to see some valid, arms-length science on what is actually contained in all biosolids, and why their application to our lands is dangerous and reckless, start by googling Harrison and McBride, Cornell, (2008/9,) Venkatesan and Halden, Arizona State, (20013-) or see Luca Vincent’s summation, above.

    Or simply consider this: if the authors think their product is safe and “beneficial”, why won’t they prove it? All they have to do is have it tested. They have apparently said they will, but they haven’t.

    So here’s how we quit arguing, and settle this whole issue around biosolids right now, once and for all. Identify a dozen sites in BC where biosolids have been consistently applied for years, and have the soil, water and plants tested for chemicals (CEC’s –“Contaminants of Emerging Concern”), metals, plastics, microfibres, pathogens and prions. Have them independently sampled and independently analyzed, and make the results public.

    That way nobody has to fight, and everybody will know the truth.

    Go ahead, MOE, Kamloops and Arrow.

    I dare you.

  3. Georgia Clement // May 3, 2019 at 7:40 PM // Reply

    Let’s simply state the obvious here gentlemen….there is a contract valued at 4.4 MILLION dollars. You are financially invested in spewing forth your support for what you do. The public is getting more and more educated in what the real science is telling us about sewer sludge. The impartial, credible science tells us sewer sludge contains any number of the known 90,000 chemicals available on the market today. You guys make is sound like muffin mix….it is far from it and you all know this, but you have to make a living and you have to have a profitable company and we all get that….you see, at some point in the very near future the credible science will eventually win, it always does…you can hide behind your bought and paid for science but the times will change. Why on earth don’t you invest your millions in a Gasification Facility??? You can keep your trucking business, you won’t enrage the public, you will do the earth a favor and we will all actually like you! Right now you are enemy No 1 to us, the earth, the water and the air.

  4. There is not enough long term evidence to support any of the claims made in this opinion piece. Considering the unmeasurable amounts of harmful chemicals within the stuff I would be seriously reconsidering the widespread application of it. The stuff is proven serious poison. Like the opioid crisis…sales tactics got us into some pretty serious trouble. And by the way, what about telling the drivers a yellow light means prepare to stop not to accelerate the large mega-truck through a red in the downtown?
    I have seen it happening way too many times with them yellow trucks. Time to play nice boys!

  5. Tony Brumell // May 3, 2019 at 3:41 PM // Reply

    According to Arrow transport everything is perfect.As in other corporate endevours evrything is just perfect when in fact it usualy isn’t.The folks of Turttle valley simply don’t accept the implied limited impact that this much biosolids will have on the surrounding ecosystems. The slope of
    much of the area is conducive to runoff during freshette and the streams in the area will be loaded with licquid biosolids. This product is not a number one biosolid. Yet Arrow has not (to my knowledge ) released any information regarding metal content or pathogenic or drug residuals. The product is supposed to be purley from the Kamloops plant but we don’t know that for sure.Arrow has hauled biosolids from other sources in the past. The people of the area need proof that that runoff will be minimal and non toxic. Arrow has failed to meet that level of assurance..Arrow has not indicated that it is willing to cover the 777 tons per hectare with 777 milimeters of clean top soil.To mask the horrific oder . A little co operation and consultation would go a long way to solving the problem.

  6. Sorry but 777 per hectare is 777 per hectare – whether it is top-dressed, injected or mixed deeply into the soil. The result is the same – thousands of toxins that will “release slowly over time” leaching into the surrounding soils and waterways.
    The claim that this practice is “rigorously regulated” is laughable. (The guidelines actually allow the employees of Arrow to take samples themselves and send them in for testing – fox guarding the hen house ….) Out of the thousands of pollutants in “biosolids” they test for about a dozen items – mainly metals. It is rather like buying a car after merely kicking one tire. It is the very opposite of rigorous regulation. Adding some sawdust, and mixing in the sludge will do nothing to the problematic content of this material. Microplastics? – Still present – ( “43% of microplastics that go down the drain eventually end up applied to agricultural land as biosolids.” ) Nanomaterials? -Still present – (Uptake of Nanomaterials see – ). Endocrine disruptors like flame retardants? – Still present – (The U.S. Geological Survey scientists confirmed that rainfall mobilized chemicals (including detergents, fire retardants, plasticizers, and antibacterials) from municipal biosolids-amended agricultural fields, directly to runoff. Most (14 of 17) of the chemicals examined were present in edge-of-the-field runoff and not depleted in concentration after three 100-year rainfall events For more on this see – ). Prions? – Still present – ( “if prions were to enter municipal wastewater treatment systems, most of the agent would partition to activated sludge solids, survive mesophilic anaerobic digestion, and be present in treated biosolids.” see – ) In fact some problems like superbugs – antimicrobials, may even get worse through these processes (Antibiotic residues and antibiotic-resistant bacteria – – “spreading of sewage sludge leads to a significant increase of ARG in the soil” )
    Many countries are ending this practice of disposing of our cities’ sewage waste on land. Yet you call it safe. You proport to know more about toxicology than the scientists in Germany, Switzerland, and Sweden? Many European countries are making great strides to shift away from this reckless practice. Switzerland has completely banned the use of biosolids on agricultural soils because of “the risk of irreversible damage to the soil, the danger to public health and possible negative effects on the quality of the food farmers produce”
    The Swedish Government has recently noted that – “since biosolids contain environmental and health hazardous substances, drug residues and microplastics, our task force will propose a ban on spreading sewage sludge on farmland”
    So too, the German Environment Agency recently stated that – “With the precautionary principle and in light of the pollutants found in biosolids, we deem the agricultural use of biosolids to be a serious public health & environmental hazard & advocate that this practice be phased out”
    Think for a moment about just how absurd this “biosolids” business model really is. The wastewater treatment facilities have spent a great deal of time and effort collecting, concentrating, and segregating the pollutants out of the water … so why on earth would we turn around and put those piles of toxins back into the environment we just eliminated them from? That is truly a short-sighted practice that merely supports a business model based on “pushing” pollution. Situating a gasification / pyrolysis (or clean incineration) plant directly beside the water facility would dramatically cut trucking costs, and cut the huge carbon emissions this constant transport inevitably involves.

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