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The story of the Veins of Life Watershed Society

From a Rowboat on the Gorge to the Salish Sea

  From a Rowboat on the Gorge to the Fight for the Salish Sea The story of the Veins of Life Watershed Society, the Dead Boats Disposal Soci...

Protecting and restoring the Salish Sea through cleanup, research, source control and action.

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Victoria, British Columbia _ In the Salish Sea www.slaishsea.ca, Beautiful British Canada , Canada
Veins of Life Watershed Society and the Dead Boats Disposal Society are community organizations protecting and restoring the Salish Sea. Our work began in 1994, when John Roe and his son Wesley started removing garbage from the Gorge Waterway in a small rowboat. That effort grew into decades of restoration, youth training, pollution investigation, shoreline cleanup and abandoned-vessel removal. Our work now reaches beyond the Gorge to Victoria Harbour, Esquimalt Harbour, Juan de Fuca, the Gulf Islands and southern Vancouver Island. We document stormwater pollution, failing sewer infrastructure, contaminated sediments, endocrine disruptors, habitat loss and damage caused by abandoned boats and marine debris. Everything is connected: streets drain to outfalls, outfalls contaminate sediment, sediment affects forage fish and juvenile salmon, and Chinook feed Southern Resident orcas. Source control, intertidal habitat protection and enforcement remain central to our work. Our success belongs to volunteers, First Nations, tradespeople, businesses, scientists, young people and supporters who stood beside us. We continue because the Salish Sea cannot defend itself. People must do that.

Monday, July 27, 2026

Out of Sight, Into the Harbour: The Core Area’s Unfinished Stormwater Problem


Beneath the Surface

What the CRD’s 2024 Stormwater Report Reveals About Pollution Across Greater Victoria’s Core Area

An Independent Review of the 2024 Core Area Stormwater Quality Program Report



Executive Summary

The Capital Regional District’s 2024 Core Area Stormwater Quality Program Report provides substantial evidence that sewage contamination, metals, petroleum-related chemicals and other pollutants continue to enter local creeks, beaches, harbours and waterways through municipal stormwater systems.

The report covers approximately 550 stormwater discharges extending from the Colwood–Metchosin border to the Saanich–Central Saanich border. This includes Esquimalt Lagoon, Esquimalt Harbour, Victoria Harbour, Rock Bay, the Gorge Waterway, Portage Inlet, Oak Bay and portions of Saanich Inlet.[1]

The principal findings are serious:

  1. The CRD sampled 195 stormwater discharges for E. coli in 2024.

  2. Forty percent had at least one bacterial result greater than 400 colony-forming units per 100 millilitres.

  3. Twenty-eight discharges received a high public-health concern rating.

  4. Seventeen of those 28 discharges have remained high-rated for at least five years.

  5. The number of high-rated discharges increased from 25 in 2023 to 28 in 2024.

  6. Sixteen stormwater discharges remain on the CRD’s chemical Corrective Action List.

  7. Most of the remaining chemical-action locations have been concerns for more than ten years.

  8. Copper exceeded the applicable marine aquatic-life screening guideline in 81 percent of the 245 stormwater discharges included in the CRD’s multi-year aqueous dataset.

  9. Zinc exceeded the screening guideline in 47 percent of those discharges.

  10. Victoria Harbour contained the highest stormwater concentrations of metals and polycyclic aromatic hydrocarbons.

  11. Stormwater discharge SW0629 at Rock Bay had the highest concentrations of metals and PAHs in the regional dataset.

  12. CRD investigations found sewage, business waste, chlorinated water and other contamination entering stormwater systems in 2024.

The report demonstrates that this is not simply a historical pollution problem. New sources continue to be identified, old infrastructure continues to fail, cross-connections continue to carry sewage into storm drains and several longstanding chemical problems remain unresolved.

The CRD performs valuable monitoring and source-investigation work. However, the CRD does not own most municipal stormwater systems and generally cannot compel municipalities to complete repairs or source-control work within fixed time limits.

The result is a monitoring program that repeatedly identifies contamination but does not provide an enforceable regional mechanism to ensure that every identified source is eliminated.


1. Purpose of This Review

This report reorganizes and explains the findings contained in the CRD’s 2024 Core Area Stormwater Quality Program Report.

Its purpose is to identify:

  1. the extent of bacterial and chemical contamination reported in 2024;

  2. the municipalities and waterways most affected;

  3. the discharges requiring continued investigation or corrective action;

  4. what the CRD monitoring program does and does not establish;

  5. the division of responsibility between the CRD and municipalities; and

  6. the measures required to turn monitoring results into effective pollution prevention.

This is an independent review. Findings attributed to the CRD are drawn from its published report. Recommendations and interpretations identified as independent are those of the reviewer and should not be represented as CRD conclusions.


2. Scope of the CRD Program

The CRD Stormwater Quality Program works to identify and reduce contamination in stormwater, creeks and the marine environment through monitoring, assessment, education and cooperation with municipalities and First Nations.

The program evaluates approximately 550 stormwater discharges across the Core Area.

Its monitoring territory includes:

  1. Esquimalt Lagoon;

  2. Esquimalt Harbour;

  3. Victoria Harbour;

  4. Rock Bay;

  5. the Gorge Waterway;

  6. Portage Inlet;

  7. Oak Bay;

  8. the Saanich coastline;

  9. Langford’s coastline along Saanich Inlet; and

  10. numerous creeks and watercourses.

The CRD performs bacterial and chemical sampling, assigns concern ratings and conducts source investigations. It also monitors major watercourses and selected locations in the nearshore marine environment.

The municipal stormwater systems themselves are generally owned and operated by the individual municipalities. The CRD identifies problems and assists with investigations, while the municipalities remain responsible for repairs and remedial work where action is possible.[1]

That division of responsibility is central to understanding both the value and the limitations of the program.


3. How Public-Health Concerns Are Rated

The CRD uses Escherichia coli, commonly known as E. coli, as an indicator of fecal contamination and the possible presence of disease-causing organisms.

A public-health concern rating considers:

  1. the bacterial concentration;

  2. the volume of discharge;

  3. the location of the outfall; and

  4. the likelihood that people may contact the discharge.

This produces low, moderate or high concern ratings.

The CRD expressly states that it does not conduct an actual public-health risk assessment through this rating system. The ratings are intended to prioritize monitoring, investigation and remedial work.[1]

This distinction is important.

A low or moderate rating does not necessarily mean that the water is safe. A discharge with high bacterial concentrations may receive a lower rating where the flow is small or public contact is considered unlikely.

The system measures the priority assigned to the discharge. It does not provide a comprehensive assessment of every possible human-health exposure.


4. Bacterial Contamination Remains Widespread

In 2024, the CRD sampled 195 stormwater discharges twice—once in winter and once in summer—for E. coli.

Of those discharges:

  1. 123 received low concern ratings;

  2. 44 received moderate concern ratings; and

  3. 28 received high concern ratings.

Forty percent had at least one E. coli result greater than 400 colony-forming units per 100 millilitres.

The CRD describes this level as indicating sewage or animal waste with the potential to cause adverse effects for people participating in primary recreational activities such as swimming and diving.[1]

Although the long-term number of high-rated discharges has declined, the improvement has not been steady.

The total number of high-rated discharges was:

  • 43 in 2011;

  • 31 in 2016;

  • 27 in 2020;

  • 22 in 2022;

  • 25 in 2023; and

  • 28 in 2024.

The number therefore increased by three between 2023 and 2024.

The 2024 monitoring also identified five newly discovered sources of bacterial contamination.

Most concerning, 17 of the 28 high-rated discharges have remained high-rated for at least five years.

The CRD attributes the difficulty in resolving these problems to:

  1. ageing wastewater and stormwater infrastructure;

  2. privately owned lateral pipes;

  3. sewage-to-stormwater cross-connections;

  4. multiple contaminant sources within individual catchments;

  5. the cost and complexity of repairs; and

  6. new cross-connections created during construction or renovation.

The evidence demonstrates that bacterial contamination is not restricted to one municipality or one isolated drainage system.


5. Municipal Distribution of High Public-Health Outfalls

5.1 City of Victoria

Victoria had 16 high public-health concern discharges in 2024—the highest municipal total in the Core Area.

The high-rated Victoria discharges were:

  1. SW0209;

  2. SW0216;

  3. SW0222;

  4. SW0230;

  5. SW0603;

  6. SW0607;

  7. SW0610;

  8. SW0611;

  9. SW0613;

  10. SW0614;

  11. SW0619;

  12. SW0641;

  13. SW0645A;

  14. SW0650;

  15. SW0758A; and

  16. SW0777A.

These discharges affect locations including Victoria Harbour, Rock Bay, Ross Bay, Cecelia Creek, the Gorge Waterway, Banfield Park and West Bay.

Victoria’s large number of high-rated discharges reflects a combination of:

  1. old infrastructure;

  2. dense urban development;

  3. industrial and commercial land use;

  4. large drainage catchments;

  5. contaminated fill and historical land uses;

  6. cross-connections; and

  7. repeated spills or improper discharges.

5.2 Township of Esquimalt

Five Esquimalt discharges received high public-health concern ratings:

  1. SW0744B;

  2. SW0780;

  3. SW0805;

  4. SW0806; and

  5. SW0812.

Gorge Creek, associated with SW0744B, remains particularly concerning. Esquimalt repaired one identified source and replaced or relined sections of pipe, but the CRD reported that at least one other contamination source remained.

5.3 District of Oak Bay

Five Oak Bay discharges were high-rated:

  1. SW0245;

  2. SW0307;

  3. SW0318;

  4. SW0320; and

  5. SW0322.

These include discharges near Oak Bay Marina, Willows Beach and other highly used shoreline areas.

5.4 District of Saanich

Two Saanich discharges were high-rated:

  1. SW0503; and

  2. SW0671.

Saanich also shares responsibility with Victoria for portions of the Cecelia Creek watershed, where sewage and other contaminant sources were identified during the 2024 spill investigation.

5.5 Town of View Royal

No View Royal discharge received a high public-health concern rating in 2024.

However, this does not mean that View Royal’s stormwater system was free from environmental concern. SW0866 at Portage Park received the only high chemical environmental rating assigned during the year.


6. Chemical Contamination in Stormwater Sediment

The CRD assesses environmental concern by measuring metals and PAHs in sediment collected from stormwater infrastructure such as:

  1. manholes;

  2. ditches;

  3. streams; and

  4. storm drains.

Results are compared with sediment-quality guidelines intended to protect aquatic life.

In 2024, the CRD collected 21 stormwater sediment samples. These produced current environmental ratings for 15 discharges:

  1. six low ratings;

  2. eight moderate ratings; and

  3. one high rating.

The single high-rated location was SW0866, a stream in Portage Park, View Royal. Elevated zinc had been found intermittently over several years.

CRD and View Royal investigations had not identified the upstream source. View Royal continued cleaning upstream catch basins and manholes.[1]

The relatively small number of sediment samples must be kept in perspective. Twenty-one samples represent only a limited portion of approximately 550 discharges.

The finding that only one discharge received a new high rating in 2024 does not mean that only one chemical problem exists.

The CRD maintains a separate Corrective Action List for discharges where elevated contamination has been confirmed through repeated findings.


7. Sixteen Discharges Remain on the Chemical Corrective Action List

The CRD recommends corrective action when:

  1. a discharge remains high-rated for two consecutive years; and

  2. the contaminants of concern are confirmed through repeated sampling.

Sixteen discharges remained on the Corrective Action List following the 2024 assessment.

Esquimalt

  1. SW0742;

  2. SW0749; and

  3. SW0806.

Langford

  1. SW6006.

Oak Bay

  1. SW0306;

  2. SW0307; and

  3. SW0310.

Victoria

  1. SW0603;

  2. SW0614;

  3. SW0620;

  4. SW0627;

  5. SW0629;

  6. SW0633;

  7. SW0634; and

  8. SW0636.

Private Victoria discharge

  1. SW0649.

The number of listed discharges declined from 21 in 2020 to 16 in 2024.

That reduction is positive, but it must be balanced against another CRD finding: most of the remaining discharges have been concerns for more than ten years.

The longstanding problem locations are often associated with:

  1. large industrial or commercial catchments;

  2. historical contaminated fill;

  3. former industrial practices;

  4. spills;

  5. contaminated soil or groundwater;

  6. roadway runoff;

  7. accumulated sediment in the storm system; and

  8. intermittent discharges that are difficult to trace.

The Corrective Action List therefore identifies a persistent regional pollution problem rather than a collection of newly discovered or temporary incidents.


8. Three Discharges Were Removed from the Corrective Action List

The CRD removed SW0250, SW0505 and SW0737 from the Corrective Action List in 2024.

SW0250 — Oak Bay

Elevated PAHs had been measured since 1996.

Oak Bay previously removed oil-contaminated soil and a collapsed storm drain that may have contributed to the contamination. PAHs continued to appear intermittently in upstream sediment, but the CRD concluded that the remaining sediment was unlikely to be materially affecting the marine environment.

The discharge will continue to be monitored.

SW0505 — Saanich

Mercury and lead were detected in sediment in 2017.

Saanich cleaned the affected storm line and removed sediment. Recent water samples did not indicate mercury above background concentrations in upper Craigflower Creek.

Monitoring will continue.

SW0737 — Esquimalt

This discharge showed intermittent zinc and PAH contamination for more than a decade.

Following three years of lower results and catch-basin cleaning by Esquimalt, the discharge was downgraded to moderate concern. It will continue to be monitored.

Removal from the Corrective Action List therefore does not necessarily mean that no contamination remains. It means that the available evidence no longer met the CRD’s criteria for continued corrective-action status.


9. Metals Are Widespread in Stormwater

The CRD’s multi-year aqueous dataset included samples from 245 Core Area discharges.

The water results were compared with British Columbia aquatic-life water-quality guidelines. The CRD notes that these guidelines are intended for the receiving environment and were used as a screening tool for stormwater entering marine waters.

The results were substantial:

  1. copper exceeded the applicable guideline in 81 percent of discharges;

  2. zinc exceeded the applicable guideline in 47 percent;

  3. one or more PAHs were detected in 30 percent of discharges;

  4. 18 percent exceeded at least one PAH guideline; and

  5. Victoria Harbour contained the highest concentrations of metals and PAHs.

Copper and zinc are common urban-runoff contaminants.

Potential sources include:

  1. vehicle brake and tire wear;

  2. building materials;

  3. galvanized surfaces;

  4. industrial and commercial activities;

  5. contaminated soils;

  6. road sediment;

  7. spills;

  8. plumbing and infrastructure; and

  9. improper waste disposal.

Because the CRD comparison uses receiving-water guidelines as screening thresholds, an exceedance in the stormwater pipe does not by itself quantify the final concentration after discharge and mixing.

However, repeated and substantial exceedances identify contaminant sources that warrant investigation, control and receiving-environment monitoring.


10. Rock Bay Recorded the Highest Contaminant Concentrations

Stormwater discharge SW0629 at Rock Bay produced the highest concentrations of metals and PAHs in the CRD’s regional aqueous dataset.

Investigations found upstream copper concentrations more than 10,000 times the British Columbia marine aquatic-life guideline.

Aluminum, cadmium, chromium, iron, lead and zinc were reported at concentrations between 10 and 100 times their respective guidelines.

CRD and City of Victoria staff identified and stopped a business from dumping waste into the stormwater system.

Samples collected later in 2024 showed that aqueous metal concentrations had decreased.

This is an important source-control success. It demonstrates that targeted investigation can identify and stop a major contaminant discharge.

However, the CRD described the SW0629 investigation as both complete and ongoing because other sources may remain.

One stopped discharge does not establish that the entire Rock Bay drainage catchment has been corrected.

SW0629 also remains on the chemical Corrective Action List.


11. Eleven Source Investigations Were Conducted in 2024

The CRD conducted contaminant or spill investigations in the catchments of 11 stormwater discharges.

Six sewage or contaminant sources were found.

Two Victoria sources and two Saanich sources were reportedly identified and resolved during the year. Other repairs were underway.

Nine investigations remained ongoing because of:

  1. multiple contamination sources;

  2. inconsistent bacterial results;

  3. low or absent flows during sampling;

  4. large drainage catchments; or

  5. difficulty narrowing the source.

SW0216 — Ross Bay

A large source was found and repaired, but other sources remained.

SW0250 — McNeill Bay

The investigation continued because of multiple possible sources. Bacterial concentrations were low during the sampling event, and a PAH was detected at a low concentration.

SW0306 — Oak Bay Marina

The investigation was considered complete after contaminants associated with an upstream spill were no longer detected at the discharge.

SW0318 — Willows Beach

One source was narrowed down, but multiple sources remained.

SW0629 — Rock Bay

A significant business-waste source was removed and contaminant concentrations declined. Investigation of other sources continued.

SW0641 — Cecelia Creek

Several sources of sewage and other contaminants were found during the spill investigation. Other sources remained.

SW0650 — Gorge Waterway

The investigation remained inconclusive.

SW0744B — Gorge Creek

Esquimalt repaired one source and replaced or relined pipe sections. At least one other source remained.

SW0758A — Banfield Park

A possible sewage-to-stormwater cross-connection was identified. Investigation continued.

SW0777A — West Bay

Sources were narrowed down and Victoria completed some repairs. Bacterial concentrations declined, but the investigation remained open.

SW0812 — Sturdee Avenue

The investigation was considered complete after bacterial concentrations declined.

The results show that finding one source does not necessarily resolve an outfall. Large catchments frequently contain multiple sources.


12. Cecelia Creek Demonstrates the Weakness of a Reactive System

In July 2024, reports were received of a white substance in Cecelia Creek.

Victoria and Saanich staff inspected manholes and businesses. The City of Victoria distributed information to businesses in the area. The CRD assisted with coordination and sampled the creek and water near the Banfield Park dock.

The original source of the white substance was not determined. The visible incidents ended later in July.

The investigation nevertheless identified:

  1. at least two sewage sources;

  2. chlorinated water entering from a new splash pad;

  3. ageing infrastructure requiring repair; and

  4. other contaminant sources that remained unresolved.

Saanich suspended the splash pad and began examining dechlorination measures.

Work was also undertaken to reduce sewage inputs.

This investigation reveals an uncomfortable truth: the visible spill was not traced, but the search uncovered several other problems that were already present in the watershed.

Cecelia Creek should therefore not be understood as a single spill incident. It is a complex drainage system affected by sewage, urban runoff, ageing infrastructure and commercial or industrial land uses.


13. Major Watercourses Show Continuing Urban Impacts

The CRD monitored:

  1. Bee Creek;

  2. Bowker Creek;

  3. Cecelia Creek;

  4. Colquitz River;

  5. Colwood Creek;

  6. Craigflower Creek;

  7. Douglas Creek;

  8. Hospital Creek;

  9. Noble Creek;

  10. Selleck Creek;

  11. Tod Creek;

  12. Goldstream River; and

  13. Mill Stream.

The CRD identified the principal water-quality concerns as:

  1. bacteria;

  2. phosphorus;

  3. turbidity;

  4. metals;

  5. low dissolved oxygen; and

  6. elevated summer temperature.

The Vancouver Island stream objective for phosphorus was exceeded in every CRD creek monitored.

Bowker Creek

Bowker Creek continued to show the clearest evidence of serious urban impacts.

The CRD reported:

  1. sewage contamination;

  2. elevated copper;

  3. elevated phosphorus;

  4. elevated turbidity;

  5. low dissolved oxygen at several stations;

  6. elevated E. coli;

  7. elevated iron near the headwaters; and

  8. PAHs at Browning Park.

The benthic invertebrate community at the creek mouth was rated in fair condition.

No sensitive mayfly, stonefly or caddisfly groups were found. The sample was dominated by pollution-tolerant organisms, and the biological index indicated substantial organic pollution.

This provides biological evidence that contamination is affecting the creek ecosystem, not merely producing laboratory exceedances.

Bee and Selleck Creeks

Bee and Selleck creeks were comparatively healthier.

Bee Creek nevertheless showed elevated turbidity, suspended solids and indications of low-to-moderate organic or nutrient pollution.

Selleck Creek had relatively few guideline exceedances in 2024, although the CRD noted that sampling did not occur during heavy rainfall—the conditions under which elevated iron and zinc had been measured previously.

This illustrates another monitoring limitation: the timing of sampling can materially influence what contamination is detected.


14. What the CRD Report Establishes

The CRD’s findings support the following conclusions.

14.1 Sewage continues to enter stormwater infrastructure

High E. coli concentrations, identified cross-connections and direct source investigations confirm continuing sewage contamination.

14.2 Chemical contamination is widespread

Copper, zinc and PAHs occur across a substantial portion of the monitored stormwater system.

14.3 Victoria Harbour is the principal chemical hotspot

The highest metal and PAH concentrations were reported from Victoria Harbour, particularly Rock Bay.

14.4 Several problems are chronic

Seventeen high public-health discharges have remained high-rated for five years or more, while most chemical corrective-action discharges have been concerns for more than a decade.

14.5 New contamination continues to appear

Five newly discovered bacterial sources were identified in 2024.

14.6 Municipal infrastructure is a significant factor

Ageing pipes, damaged infrastructure, private laterals and cross-connections are repeatedly identified as causes or contributing factors.

14.7 Source investigation can work

The Rock Bay business discharge demonstrates that persistent investigation can locate and stop major pollution sources.

14.8 Monitoring alone does not ensure correction

A number of discharges remain under investigation year after year despite repeated evidence of contamination.


15. What the CRD Report Does Not Establish

The report contains important evidence, but it should not be treated as a complete assessment of stormwater risk.

It does not establish:

  1. that every one of the approximately 550 discharges was sampled in 2024;

  2. that two annual bacterial samples capture all wet-weather or intermittent pollution;

  3. that a low-rated discharge is free from sewage or pathogens;

  4. that the public-health ratings constitute actual health-risk assessments;

  5. that fecal testing establishes chemical safety;

  6. that stormwater sediment results determine contaminant concentrations in nearby marine sediment;

  7. the total contaminant load discharged by each outfall;

  8. where contaminants settle after entering the receiving environment;

  9. whether contaminants are accumulating in shellfish, fish or other organisms;

  10. the cumulative effect of several outfalls entering the same bay or waterway;

  11. whether all identified sources have been repaired;

  12. whether repairs have permanently prevented recurrence;

  13. the complete condition of contaminated intertidal sediments;

  14. the effect of sediment disturbance on human or ecological exposure; or

  15. the full risk posed by contaminants not included in the routine analytical program.

The CRD report is therefore best understood as a screening, prioritization and source-investigation report—not a complete assessment of human-health, ecological or harbour-sediment risk.


16. Independent Assessment of the Program

The CRD provides a valuable regional service. Without its work, many sewage cross-connections, spills and chemical contamination sources would likely remain unidentified.

The program’s principal strengths are:

  1. consistent regional monitoring;

  2. established outfall identification numbers;

  3. long-term trend information;

  4. cooperation with municipal staff;

  5. bacterial source tracing;

  6. chemical screening;

  7. watercourse monitoring;

  8. biological assessment; and

  9. public reporting.

Its principal weakness is structural.

The CRD identifies contamination and recommends action, but municipalities own most of the infrastructure and determine how and when repairs are undertaken.

The report repeatedly uses language such as:

  • municipalities may consider mitigative action;

  • municipalities are responsible for remedial measures where possible;

  • recommendations are provided to local governments; and

  • action is taken according to municipal priorities.

This leaves no single authority clearly responsible for ensuring that every serious problem is corrected within a defined period.

A regional pollution problem is being managed through separate municipal systems, separate budgets and separate priorities.

The water does not respect those boundaries.


17. Recommended Actions

The following are independent recommendations arising from the CRD’s findings.

17.1 Require written corrective-action plans

Every high public-health discharge and every chemical corrective-action discharge should have a public plan identifying:

  1. the responsible municipality or property owner;

  2. the contaminant or sewage problem;

  3. the investigation completed;

  4. the work still required;

  5. the responsible department;

  6. the target completion date;

  7. the estimated cost;

  8. the confirmation-sampling requirements; and

  9. the consequences of failing to complete the work.

17.2 Establish enforceable deadlines

A discharge should not remain high-rated for five, ten or more years without an escalation process.

Escalation should include:

  1. formal notice to the municipality;

  2. mandatory reporting to council;

  3. referral to provincial or federal regulators where warranted;

  4. public disclosure of missed deadlines; and

  5. enforcement where prohibited discharges continue.

17.3 Increase wet-weather monitoring

Twice-yearly bacterial sampling cannot reliably characterize intermittent sewage discharges, spills or first-flush contamination.

Priority discharges should be sampled:

  1. during heavy rainfall;

  2. during the first flush of major storms;

  3. during dry weather;

  4. during suspected spill events; and

  5. following repairs.

17.4 Measure contaminant loads

Concentrations should be combined with flow measurements to calculate the mass of contaminants entering receiving waters.

A large-volume discharge with a moderate concentration may contribute more pollution than a small discharge with a high concentration.

17.5 Connect outfalls to receiving-environment monitoring

High-priority outfalls should be linked to:

  1. near-outfall water sampling;

  2. intertidal sediment sampling;

  3. subtidal sediment sampling;

  4. sediment deposition monitoring;

  5. benthic-community assessment;

  6. toxicity testing; and

  7. tissue monitoring where appropriate.

17.6 Expand the contaminant list

Routine monitoring should be expanded where risks justify it to include:

  1. PCBs;

  2. dioxins and furans;

  3. PFAS;

  4. tire-wear chemicals, including 6PPD-quinone;

  5. pesticides;

  6. pharmaceuticals;

  7. endocrine-active compounds;

  8. microplastics;

  9. organotins; and

  10. petroleum hydrocarbons.

17.7 Assess recreational areas for more than bacteria

Locations used for swimming, paddling and shoreline play should be evaluated for both microbiological and chemical hazards.

This is particularly important where people contact mud, sediment or shallow intertidal water.

17.8 Publish a regional enforcement and repair ledger

The public should be able to see:

  1. when each problem was first identified;

  2. what contaminants were found;

  3. who is responsible;

  4. what repairs were completed;

  5. what sources remain;

  6. whether the outfall improved; and

  7. whether the file is genuinely closed.

17.9 Establish a regional stormwater utility or authority

The Core Area requires a body with sufficient authority, staff and funding to:

  1. set common standards;

  2. require municipal compliance;

  3. coordinate capital improvements;

  4. enforce prohibited-discharge rules;

  5. manage cross-boundary watersheds;

  6. conduct regional receiving-environment monitoring; and

  7. ensure that identified sources are corrected.


18. Conclusion

The CRD’s 2024 report is not a clean bill of health for the Core Area.

It documents:

  1. 28 high public-health concern discharges;

  2. 17 discharges remaining high-rated for at least five years;

  3. 16 chemical corrective-action discharges;

  4. widespread copper and zinc exceedances;

  5. the highest contaminant concentrations in Victoria Harbour;

  6. sewage entering stormwater systems;

  7. unresolved cross-connections;

  8. industrial and commercial waste entering municipal drains;

  9. chemical contamination persisting for more than a decade; and

  10. urban creeks showing biological evidence of pollution.

The CRD has shown that the contamination exists.

The next question is no longer whether more monitoring is needed before anyone acts. Monitoring and action must occur together.

Every investigation should lead to a responsible party, a corrective measure, a completion date and confirmation that the pollution has stopped.

Otherwise, the region will continue producing annual reports that carefully count the same contaminated outfalls while sewage, metals and toxic sediment continue travelling from our streets and pipes into the Gorge, Portage Inlet, Esquimalt Harbour, Victoria Harbour and the Salish Sea.

Those contaminants do not disappear at the end of the pipe.

They enter sediment, benthic organisms and the marine food web—affecting the forage fish needed by Chinook salmon and, ultimately, the Southern Resident killer whales that depend upon them.

References

[1] Capital Regional District. Core Area Stormwater Quality Program: 2024 Report. Reported results include work completed during 2024 and selected early-2025 information.


Draft Comparative Review of Core Area Stormwater, Harbour Sediment and Receiving-Environment Monitoring

Victoria, Esquimalt, Saanich, View Royal and Oak Bay

Working Draft for Review

1. Purpose

This review compares the available stormwater, sediment, water-quality and environmental-risk information for the Core Area municipalities of:

  1. City of Victoria;

  2. Township of Esquimalt;

  3. District of Saanich;

  4. Town of View Royal; and

  5. District of Oak Bay.

The review examines work completed by the Capital Regional District, Transport Canada, Public Services and Procurement Canada, municipal governments, Department of National Defence, BC Hydro and environmental consultants working on individual contaminated-site and infrastructure projects.

The purpose is to determine:

  1. what each agency monitors;

  2. where the different datasets agree;

  3. where monitoring responsibilities overlap;

  4. where important contaminants or pathways are being missed;

  5. whether continuing stormwater inputs are recontaminating harbour sediments; and

  6. what a complete Core Area monitoring and source-control program should include.

The central finding is that the existing studies describe different parts of the same contamination pathway, but no agency is presently responsible for assembling the complete picture:

pollution source → municipal storm sewer → outfall → receiving water → sediment deposition → benthic organisms and forage fish → Chinook salmon → Southern Resident killer whales.


2. Main Findings

2.1 The agencies broadly agree on the principal contamination problem

The available reports consistently identify municipal stormwater as an important continuing source of:

  1. copper;

  2. zinc;

  3. lead;

  4. mercury;

  5. cadmium;

  6. chromium;

  7. polycyclic aromatic hydrocarbons;

  8. polychlorinated biphenyls;

  9. dioxins and furans;

  10. suspended solids;

  11. petroleum-related contaminants; and

  12. sewage contamination caused by cross-connections, leaking pipes and illicit discharges.

Transport Canada concluded that some Victoria Harbour stormwater discharges contained concentrations of lead, PCBs, PAHs and dioxins/furans that were two to three orders of magnitude higher than other tested outfalls. Lead, PAHs and PCBs were reported at concentrations four to 100 times applicable British Columbia water-quality guidelines. Transport Canada further concluded that a relatively small number of outfalls accounted for most of the estimated stormwater contaminant load entering Victoria Harbour.[1]

The CRD’s annual monitoring reaches a similar conclusion using a narrower contaminant list. Its reports repeatedly identify elevated metals, PAHs and fecal contamination at many of the same Victoria Harbour outfalls.[2]

The difference is not that one agency finds contamination and another does not. The difference is mainly what they test, where they test and how they describe the risk.


2.2 The strongest cross-agency agreement occurs at Victoria’s Upper Harbour and Rock Bay outfalls

Transport Canada identified outfalls 0629, 0634 and 0636 as its first-priority outfalls for monitoring, source tracing and source control.

Outfall 0629

Transport Canada reported:

  1. high concentrations of metals;

  2. PAHs;

  3. PCBs;

  4. dioxins and furans;

  5. high suspended-solids loading;

  6. localized PCB contamination in adjacent sediment; and

  7. effects in clam tissues collected near the outfall.

CRD monitoring separately found some of the highest aqueous metal concentrations in the regional stormwater dataset at this outfall.

Recent CRD findings reported extraordinarily high upstream copper, together with elevated aluminum, cadmium, chromium, iron, lead, zinc and PAHs. CRD and the City of Victoria identified at least one business discharging waste into the storm system, although the available findings indicate that further sources may remain.[1][2]

Outfall 0634

Transport Canada reported that this outfall had:

  1. the highest PCB and lead concentrations among the outfalls it tested;

  2. some of the highest PAH and dioxin/furan concentrations;

  3. localized sediment contamination;

  4. evidence of sediment recontamination by PCBs and metals; and

  5. elevated contaminant concentrations in clam tissues near the discharge.

CRD has also repeatedly identified elevated metals in this drainage, including cadmium, chromium, copper, iron, lead and zinc.[1][2]

Outfall 0636

Transport Canada ranked this as the third-highest priority outfall. It reported elevated PCBs, dioxins/furans and lead in stormwater and increasing PCB and heavy-metal concentrations in nearby sediments.

CRD has independently reported zinc and other metals in storm-sewer sediment and elevated cadmium, chromium, copper, iron, lead and zinc in water samples.[1][2]

Conclusion for the three first-priority outfalls

These three outfalls are not merely historical industrial-contamination locations. The combined evidence indicates that municipal stormwater continues to transport contaminants capable of:

  1. degrading marine water;

  2. depositing contaminated solids;

  3. delaying natural sediment recovery;

  4. recontaminating previously managed areas; and

  5. entering marine organisms.


2.3 Rock Bay remains a source-control and recontamination problem

Rock Bay underwent one of the most extensive contaminated-site remediation programs in Victoria Harbour. However, the federal remediation did not eliminate contaminant sources entering through municipal storm sewers.

Outfalls 0626 and 0627 were specifically identified as possible causes of recontamination following the Rock Bay cleanup. A 2014 licence agreement required the City of Victoria to:

  1. monitor stormwater and sediment;

  2. conduct source tracing;

  3. implement source controls;

  4. assess or remediate sediment affected by the discharges;

  5. report findings to Transport Canada; and

  6. provide information that could be shared with the Songhees Nation, Esquimalt Nation, Veins of Life Watershed Society and other interested parties.

Transport Canada stated in its 2021 report that the agreement had only been partially implemented. It also reported that the City constructed the new Store Street outfall, identified as 0626A, without prior Transport Canada review and approval.[1]

This is particularly important because remediation cannot be considered durable where the stormwater system continues to carry contaminants into the remediated area.

Rock Bay demonstrates the fundamental problem with the present approach:

government may spend very large sums removing contaminated sediment while failing to control the municipal sources capable of contaminating it again.


3. What Each Agency Covers

3.1 Capital Regional District

The CRD operates the broadest regional stormwater-monitoring program. It evaluates hundreds of stormwater discharges from Colwood and Metchosin through Victoria, Esquimalt, Oak Bay and Saanich.

Its principal activities include:

  1. bacterial sampling using E. coli as an indicator;

  2. public-health concern ratings;

  3. storm-sewer sediment sampling;

  4. testing for metals and PAHs;

  5. environmental concern ratings;

  6. source tracing;

  7. selected aqueous contaminant sampling;

  8. creek and watercourse monitoring; and

  9. recommendations to municipalities for corrective action.

Strengths

The CRD program provides:

  1. consistent regional outfall numbering;

  2. repeated long-term monitoring;

  3. broad geographic coverage;

  4. identification of sewage cross-connections;

  5. a historical record of repeated problem outfalls;

  6. municipal source-investigation support; and

  7. a regional basis for comparing jurisdictions.

Limitations

The CRD program generally does not provide a complete assessment of:

  1. contaminant mass loading;

  2. the movement of contaminants beyond the outfall;

  3. deposition in intertidal and subtidal sediments;

  4. contamination of shellfish, fish or other organisms;

  5. food-web transfer;

  6. human-health risk from chemical exposure;

  7. cumulative effects from multiple outfalls;

  8. PCBs at all priority outfalls;

  9. dioxins and furans;

  10. PFAS;

  11. organotins;

  12. pharmaceuticals;

  13. pesticides;

  14. tire-wear chemicals;

  15. endocrine-active compounds; or

  16. chronic and sublethal biological toxicity.

The CRD expressly states that it assigns public-health concern ratings but does not conduct a complete public-health risk assessment. Its bacterial rating system therefore should not be interpreted as establishing that a beach, shoreline or sediment area is chemically safe.[2]


3.2 Municipal governments

The municipalities own and operate most storm drains and have the practical ability to:

  1. inspect pipes;

  2. enter manholes;

  3. trace upstream branches;

  4. smoke-test and dye-test systems;

  5. inspect private laterals;

  6. repair cross-connections;

  7. clean catch basins;

  8. remove contaminated storm-sewer sediment;

  9. enforce sewer-use bylaws;

  10. regulate businesses;

  11. maintain municipal infrastructure; and

  12. control development and land use within drainage catchments.

The municipalities therefore control the infrastructure where most source identification and source elimination must occur.

The principal weakness is that CRD findings are generally provided to municipalities as recommendations. The available reports do not establish a consistent regional requirement for:

  1. mandatory corrective-action plans;

  2. fixed completion dates;

  3. public reporting of source-control progress;

  4. confirmation that repairs eliminated the discharge;

  5. sediment follow-up after source removal; or

  6. escalation where a municipality does not act.

A recurring pattern appears in the reports:

  1. CRD identifies contamination;

  2. a municipality cleans a manhole, repairs one pipe or investigates one branch;

  3. contaminant levels temporarily decline;

  4. other sources remain;

  5. the outfall remains high-rated for years; and

  6. the matter continues into another annual report.


3.3 Transport Canada and Public Services and Procurement Canada

Transport Canada’s Victoria Harbour Floor work is substantially more detailed than CRD monitoring in the receiving environment.

The federal program has included:

  1. stormwater sampling;

  2. intertidal sediment sampling;

  3. subtidal sediment sampling;

  4. surface-water sampling;

  5. sediment-transport modelling;

  6. natural-recovery monitoring;

  7. clam and other shellfish tissue;

  8. fish and crab tissue;

  9. human-health risk assessment;

  10. ecological risk assessment;

  11. contaminant-load modelling;

  12. identification of sediment-recontamination areas;

  13. remediation of contaminated sediment; and

  14. source-control recommendations.

Transport Canada’s work connects stormwater contaminants to:

  1. harbour water quality;

  2. sediment deposition;

  3. marine-organism tissue;

  4. seafood-consumption exposure; and

  5. human and ecological risk.

Transport Canada found that stormwater was responsible for at least half of the PCB loading to the Victoria Harbour water column. Its modelling indicated that controlling discharges from the highest-PCB outfalls could reduce stormwater-related PCB loading by approximately 80 to 90 percent.[1]

Transport Canada also found lead concentrations in clam tissue near first-priority outfalls to be:

  1. more than twice those at other Victoria Harbour beach areas; and

  2. more than 20 times concentrations in clams from reference beaches outside the harbour.[1]

Limitation of the federal program

Transport Canada’s most detailed work is concentrated within the federally administered Victoria Harbour floor and does not provide equivalent coverage throughout:

  1. Oak Bay;

  2. Portage Inlet;

  3. the upper Gorge Waterway;

  4. Saanich shoreline areas outside the federal harbour floor;

  5. View Royal; or

  6. all of Esquimalt Harbour.

Transport Canada has also stated that it does not control municipal pipes and cannot complete upstream source tracing without municipal cooperation and enforcement.[1]


3.4 Department of National Defence and Esquimalt Harbour

Esquimalt Harbour has been studied separately because of naval, shipyard and historical industrial contamination.

Department of National Defence programs generally focus on:

  1. federal property;

  2. naval facilities;

  3. contaminated harbour sediment;

  4. remediation areas;

  5. sediment monitoring;

  6. ecological risk; and

  7. federal operational sources.

The CRD, meanwhile, monitors municipal and other stormwater discharges entering Esquimalt Harbour.

The principal problem is that the two systems are not consistently presented through a common station and outfall framework. A sediment station may show contamination without being clearly linked in public reports to:

  1. a CRD outfall number;

  2. a municipal drainage catchment;

  3. a federal facility;

  4. an historical industrial parcel; or

  5. another contaminant source.

This makes it difficult to determine whether contaminated sediment reflects:

  1. historical contamination;

  2. current municipal stormwater;

  3. federal property runoff;

  4. marine industrial activity;

  5. vessel activity; or

  6. a combination of sources.


3.5 BC Hydro and project-specific studies

BC Hydro’s Selkirk Waterway cable investigation provides useful sediment information but was designed mainly to support construction planning and sediment disposal.

The study examined sediments along the proposed cable crossing between Banfield Park and Viaduct Park. The report identified exceedances for:

  1. lead;

  2. mercury;

  3. zinc;

  4. several PAHs; and

  5. PCBs.

The highest number of exceedances occurred on the northern side of the waterway near historical industrial operations. The report also expressly identified industrial discharge from Cecelia Creek as an ongoing potential influence on project-area sediment.[3]

The study’s strength is that it used deeper sediment cores, allowing the vertical extent of contamination to be examined.

Its limitation is that it was not designed to provide a complete ecological or public-health assessment. The 2025 investigation analyzed only selected intervals from a limited number of the collected cores. Its primary purpose was sediment handling and disposal, not determining cumulative exposure or the present rate of contaminant deposition.


4. Current Harbour-Floor Monitoring Findings

Transport Canada’s more recent harbour-floor monitoring substantially expands the evidence available for comparison.

The current program extends generally from Ogden Point and Macauley Point north to the Selkirk Trestle. It includes:

  1. intertidal and subtidal sediment;

  2. flatfish, reef fish and shrimp tissue;

  3. caged bivalves;

  4. surface water;

  5. bathymetry;

  6. sediment deposition and scour;

  7. lead;

  8. carcinogenic PAHs;

  9. PCBs;

  10. dioxins and furans;

  11. pentachlorophenol; and

  12. PFAS screening.[4]

The 2024 federal monitoring dataset incorporated:

  1. 48 harbour-floor sediment samples;

  2. 22 Selkirk early-action investigation samples;

  3. 42 shoreline and bank data-gap samples; and

  4. associated tissue and surface-water monitoring.

A total of 108 surface-sediment samples were evaluated.

Reported findings included:

  1. approximately 29 percent exceeding the probable effects level for lead;

  2. approximately 70 percent exceeding the fish-based probable effects level for dioxin/furan toxic equivalency;

  3. PCB probable-effects-level exceedances concentrated in targeted intertidal locations;

  4. particularly high dioxin/furan results along the eastern Selkirk shoreline; and

  5. the highest PCB exceedance at the Centennial Park shoreline.[4]

These findings are important because the CRD’s normal annual stormwater program does not routinely test for dioxins/furans or PCBs at all regional outfalls.

The federal results therefore demonstrate that a stormwater program limited mainly to metals and PAHs can fail to characterize some of the contaminants driving sediment, seafood-consumption and ecological risk.


5. Selkirk Waterway, Cecelia Creek and the Gorge

5.1 Cecelia Creek, SW0641

CRD identifies Cecelia Creek as a high public-health concern discharge.

Recent investigations identified:

  1. sewage contamination;

  2. at least two sewage sources;

  3. chlorinated splash-pad water;

  4. chromium;

  5. zinc;

  6. PAHs;

  7. industrial or commercial contamination; and

  8. additional unidentified sources.

Some cross-connections were reportedly repaired, but the available reports do not establish that all contamination sources were eliminated.[2]

Transport Canada’s harbour-floor work identifies the eastern Selkirk shoreline as one of the principal remaining sediment-risk areas. The federal monitoring found particularly elevated dioxin/furan toxic equivalency there.[4]

BC Hydro separately identified:

  1. lead;

  2. mercury;

  3. zinc;

  4. PAHs; and

  5. PCBs

in Selkirk Waterway sediment near the proposed cable alignment. Its report identified Cecelia Creek industrial discharge as a continuing potential influence.[3]

Combined interpretation

The three datasets are mutually reinforcing:

  1. CRD identifies active contaminant transport through the creek and storm system.

  2. BC Hydro identifies contaminated sediment in the receiving area.

  3. Transport Canada identifies broader intertidal and subtidal sediment risk along the Selkirk shoreline.

This is one of the strongest examples of a complete, although fragmented, source-to-sediment contamination pathway.


5.2 Banfield Park and SW0758A

CRD rates SW0758A near Banfield Park as a high public-health concern and has identified a possible sewage-to-stormwater cross-connection.

The adjacent sediment area is also affected by:

  1. historical industrial activity;

  2. Cecelia Creek inputs;

  3. older contaminated deposits;

  4. municipal stormwater;

  5. shoreline development;

  6. vessel activity; and

  7. planned disturbance from infrastructure projects.

This makes Banfield Park unsuitable for evaluation through fecal bacteria alone.

Before encouraging swimming, shoreline play, saltmarsh construction or sediment disturbance, the responsible agencies should examine:

  1. fecal contamination;

  2. chemical contamination;

  3. intertidal sediment exposure;

  4. resuspension during construction;

  5. contaminated-material migration;

  6. contact by children and frequent shoreline users; and

  7. cumulative exposure from multiple nearby outfalls.


5.3 Gorge and Portage Inlet

The Gorge and Portage Inlet are not adequately covered by Transport Canada’s harbour-floor program.

CRD provides:

  1. bacteria monitoring;

  2. selected sediment chemistry;

  3. creek monitoring; and

  4. limited source investigations.

However, there is no equivalent system-wide program for:

  1. depositional sediment;

  2. shellfish and fish tissue;

  3. contaminant loading;

  4. sediment resuspension;

  5. contaminated intertidal areas;

  6. chemical exposure at swimming locations;

  7. endocrine-active contaminants;

  8. cumulative outfall effects; or

  9. food-web transfer.

This is a major gap because the Gorge is:

  1. narrow;

  2. tidally restricted;

  3. heavily urbanized;

  4. historically industrial;

  5. surrounded by municipal outfalls;

  6. used for swimming and recreation; and

  7. important habitat for juvenile fish and benthic organisms.


6. Oak Bay

CRD identifies several Oak Bay outfalls as high public-health concerns, including SW0245, SW0307, SW0318, SW0320 and SW0322.

Chemical concerns include:

  1. PAHs;

  2. mercury;

  3. lead;

  4. zinc;

  5. copper; and

  6. possible soap or detergent discharges.

At SW0307 near Oak Bay Marina, contaminant sources have been narrowed toward the Newport Avenue and Currie Road area. Cleaning and investigation have occurred, but the reports do not establish complete elimination of the sources.[2]

The key Oak Bay gap is receiving-environment monitoring.

Unlike Victoria Harbour, Oak Bay does not appear to have a comparable publicly integrated program examining:

  1. sediment around high-priority outfalls;

  2. shellfish or fish tissue;

  3. contaminant deposition;

  4. food-web transfer;

  5. chemical exposure at beaches; or

  6. cumulative effects from marina, road, residential and commercial runoff.

The CRD can identify that contamination is leaving the pipe. It generally does not determine where the contaminants settle or what organisms are exposed.


7. Saanich

CRD identifies high public-health concern outfalls in Saanich, including SW0503 and SW0671.

Saanich also contains major drainage systems and watercourses flowing toward:

  1. the Gorge;

  2. Portage Inlet;

  3. Cadboro Bay;

  4. Cordova Bay;

  5. the outer coastline; and

  6. sensitive nearshore habitat.

CRD watercourse monitoring provides useful watershed information, but the marine connection is incomplete.

A complete Saanich program should connect:

  1. upstream creek chemistry;

  2. municipal drainage branches;

  3. stormwater outfalls;

  4. nearshore sediment;

  5. beach and intertidal exposure;

  6. eelgrass and forage-fish habitat;

  7. benthic organisms; and

  8. long-term contaminant loading.

At present, these elements are usually examined separately, if they are examined at all.


8. View Royal

CRD identified SW0866 at Portage Park as a high environmental concern because of elevated zinc in stream sediment.

The source has not been fully identified. View Royal has undertaken catch-basin and manhole cleaning, but the available findings do not establish whether:

  1. zinc loading has stopped;

  2. contaminated sediment remains upstream;

  3. the contamination reaches Portage Inlet;

  4. depositional sediment is being affected; or

  5. aquatic organisms are exposed.

View Royal illustrates a recurring limitation in the CRD process: a contaminant may be identified in storm-system sediment, but there is no automatic follow-through into the receiving environment.


9. Esquimalt

CRD identifies high public-health concern discharges including:

  1. SW0744B;

  2. SW0780;

  3. SW0805;

  4. SW0806; and

  5. SW0812.

SW0744B, associated with Gorge Creek, remains particularly concerning. Esquimalt repaired one source and completed pipe repairs or relining, but CRD reported that another contamination source remained.[2]

SW0806 has both public-health and chemical concerns, including elevated copper, zinc and PAHs. CRD narrowed the source area but had not established complete correction.

Other Esquimalt chemical-action locations include:

  1. SW0742, with mercury;

  2. SW0749, with zinc, mercury and possible oil or food-waste influences; and

  3. SW0806, with metals and PAHs.

Esquimalt Harbour is additionally influenced by naval, shipyard, marina and historical industrial sources.

The problem is not a lack of information. The problem is the absence of one integrated map and reporting system connecting:

  1. CRD outfalls;

  2. municipal drainage catchments;

  3. DND monitoring stations;

  4. federal contaminated sites;

  5. shipyard areas;

  6. receiving sediment;

  7. remediation locations; and

  8. present contaminant sources.


10. Where the Datasets Match

The datasets consistently support the following conclusions.

10.1 Stormwater is transporting contaminants to marine waters

This is confirmed through:

  1. CRD outfall-water sampling;

  2. CRD storm-sewer sediment sampling;

  3. Transport Canada stormwater sampling;

  4. federal surface-water sampling;

  5. BC Hydro sediment investigations; and

  6. sediment contamination concentrated near specific discharge areas.

10.2 Stormwater solids are contaminating or recontaminating sediment

Transport Canada documented recontamination or increasing contaminant concentrations near priority outfalls.

Hydrodynamic and sediment-transport modelling showed that solids from selected outfalls could account for continuing contamination in the Upper Harbour and Selkirk Waterway.[1]

10.3 A small number of outfalls account for a disproportionate share of contamination

Transport Canada concluded that certain high-priority outfalls contributed most of the estimated stormwater pollutant loading.

This supports prioritizing high-loading outfalls, but it does not justify ignoring smaller outfalls that discharge into sensitive or poorly flushed intertidal habitat.

10.4 Sewage and chemical contamination frequently occur in the same drainage systems

Transport Canada reported bacteria indicative of sanitary waste at its three first-priority outfalls.

CRD has similarly identified high bacterial ratings at numerous chemically contaminated outfalls.

Cross-connections and illicit discharges may therefore transport both:

  1. fecal contamination; and

  2. toxic or bioaccumulative chemicals.

10.5 Historical contamination and ongoing contamination coexist

Some sediment contamination originates from historical industries, landfills, creosote, shipyards, sawmills and former waste practices.

However, the reports also identify present-day contaminant movement through operating municipal stormwater systems.

Historical contamination cannot be used to dismiss evidence of continuing sources.


11. Principal Monitoring Gaps

11.1 No unified Core Area contaminant database

The agencies use different:

  1. station names;

  2. outfall numbers;

  3. sample depths;

  4. coordinate systems;

  5. laboratory methods;

  6. reporting limits;

  7. guidelines;

  8. time periods; and

  9. risk-rating systems.

A common GIS-based database should connect every sample to:

  1. the outfall;

  2. drainage catchment;

  3. upstream branches;

  4. municipality;

  5. land use;

  6. nearby contaminated sites;

  7. sediment station;

  8. tissue station;

  9. habitat type; and

  10. corrective action.


11.2 Concentrations are reported more often than contaminant loads

A small outfall with a high concentration and a large outfall with a moderate concentration cannot be properly compared without discharge flow and contaminant mass.

Monitoring should calculate:

concentration × discharge volume = contaminant load.

Load estimates should include uncertainty and should be calculated for individual storm events and annual discharge.


11.3 Insufficient wet-weather and first-flush sampling

Many urban contaminants are mobilized during the first portion of a rain event.

Sampling only once or twice annually may miss:

  1. first-flush metals;

  2. road-deposited sediment;

  3. tire-wear particles;

  4. petroleum residues;

  5. contaminated catch-basin solids;

  6. sewer overflows; and

  7. intermittent illegal discharges.

Priority outfalls should be monitored using automated samplers triggered by rainfall and flow.


11.4 Endocrine disruptors are largely absent

Existing programs do not adequately examine endocrine-active substances such as:

  1. natural and synthetic hormones;

  2. alkylphenols;

  3. bisphenols;

  4. phthalates;

  5. pharmaceuticals;

  6. personal-care products;

  7. pesticides; and

  8. other compounds capable of affecting reproduction, development and behaviour.

These substances may cause effects at concentrations below those normally associated with acute toxicity.

Monitoring should include both chemical analysis and biological-effect testing.


11.5 Emerging contaminants are inconsistently addressed

Transport Canada has begun PFAS screening in harbour sediment, water and tissues.[4]

This approach should be expanded regionally to include:

  1. PFAS;

  2. 6PPD-quinone and related tire chemicals;

  3. microplastics;

  4. organophosphate flame retardants;

  5. contemporary pesticides;

  6. pharmaceuticals; and

  7. antifouling compounds.


11.6 Limited biological monitoring outside Victoria Harbour

Transport Canada has examined contaminants in:

  1. clams;

  2. caged bivalves;

  3. flatfish;

  4. reef fish;

  5. shrimp;

  6. crab; and

  7. other marine organisms.

Comparable monitoring is not routinely conducted across Oak Bay, Portage Inlet, the upper Gorge, View Royal or most Saanich receiving waters.

A Core Area program should use common sentinel species to determine whether contamination is entering the food web.


11.7 Recreational-water assessments remain too narrowly focused

Beach and swimming decisions are often based primarily on fecal bacteria.

This does not address:

  1. contaminated mud;

  2. PAHs;

  3. metals;

  4. PCBs;

  5. dioxins and furans;

  6. chemical exposure following sediment disturbance;

  7. chronic exposure;

  8. children playing in intertidal areas; or

  9. combined chemical and microbiological risk.

The appearance of clean water does not establish that the water or sediment is safe.


12. Recommended Core Area Program

12.1 Establish one regional stormwater and receiving-environment authority

The Core Area requires a coordinated authority or enforceable regional framework capable of managing the complete watershed-to-harbour system.

The framework should include:

  1. Victoria;

  2. Esquimalt;

  3. Saanich;

  4. View Royal;

  5. Oak Bay;

  6. CRD;

  7. Transport Canada;

  8. DND;

  9. provincial agencies;

  10. Island Health;

  11. Songhees Nation;

  12. Esquimalt Nation; and

  13. relevant harbour and infrastructure authorities.


12.2 Create a single source-to-receptor monitoring network

Every priority drainage should include:

  1. upstream storm-sewer sampling;

  2. outfall-water sampling;

  3. flow monitoring;

  4. suspended-solids sampling;

  5. sediment traps;

  6. near-outfall intertidal sediment;

  7. subtidal depositional sediment;

  8. benthic toxicity;

  9. shellfish or caged-bivalve tissue;

  10. forage-fish habitat assessment; and

  11. corrective-action verification.


12.3 Expand the contaminant suite

The standard suite should include:

  1. metals;

  2. PAHs;

  3. PCBs;

  4. dioxins and furans;

  5. petroleum hydrocarbons;

  6. organotins;

  7. chlorinated phenols;

  8. PFAS;

  9. pesticides;

  10. pharmaceuticals;

  11. endocrine-active compounds;

  12. tire-wear chemicals;

  13. microplastics;

  14. nutrients;

  15. fecal indicators; and

  16. total suspended solids.


12.4 Require enforceable corrective-action plans

Every confirmed high-priority outfall should have:

  1. a named responsible municipality or owner;

  2. a defined contaminant problem;

  3. a mapped investigation area;

  4. an investigation deadline;

  5. a source-control deadline;

  6. confirmation sampling;

  7. receiving-sediment follow-up;

  8. public progress reporting; and

  9. escalation where the responsible party fails to act.

A problem outfall should not remain on a corrective-action list indefinitely without a documented enforcement response.


12.5 Protect intertidal habitat before new disturbance or construction

No project should disturb, cap, restore, dredge or build habitat over potentially contaminated shoreline without:

  1. a complete sediment characterization;

  2. analysis of current stormwater sources;

  3. hydrodynamic and sediment-transport assessment;

  4. human-health review;

  5. ecological-risk review;

  6. construction monitoring;

  7. post-construction monitoring; and

  8. demonstrated source control.

Habitat restoration placed over continuing contaminant inputs risks creating an attractive ecological trap rather than durable habitat.


13. Priority Areas for Immediate Integrated Investigation

The following areas should receive the first coordinated source-to-receptor investigations:

  1. SW0629 — extreme metals, PAHs, PCBs and dioxins/furans;

  2. SW0634 — highest federal PCB and lead results;

  3. SW0636 — increasing sediment PCBs and metals;

  4. SW0626, SW0626A and SW0627 — Rock Bay recontamination;

  5. SW0641 and Cecelia Creek — sewage, metals, PAHs and Selkirk shoreline contamination;

  6. SW0614 — metals and contaminated Johnson Street Bridge-area sediment;

  7. SW0620 and SW0633 — Upper Harbour contaminant loading;

  8. SW0758A and Banfield Park — sewage cross-connection and contaminated receiving sediment;

  9. SW0744B and Gorge Creek — continuing sewage source near public recreation;

  10. SW0806 — bacteria, copper, zinc and PAHs;

  11. SW0649 — sewage, copper, mercury and zinc near Gorge Road Hospital;

  12. SW0307 — Oak Bay Marina metals and PAHs;

  13. SW0866 — unexplained zinc entering the View Royal and Portage Inlet system; and

  14. priority DND and municipal drainage areas entering Esquimalt Harbour.


14. Conclusion

The available evidence does not describe isolated or occasional stormwater problems.

It describes a regional system in which:

  1. municipal storm sewers carry sewage and toxic contaminants;

  2. contaminants enter marine and intertidal waters;

  3. contaminated solids settle near outfalls;

  4. some sediments are being recontaminated after expensive remediation;

  5. contaminants accumulate in marine organisms;

  6. chemical risks are not captured by fecal-bacteria testing;

  7. monitoring is divided among agencies;

  8. responsibility is repeatedly passed between jurisdictions; and

  9. source-control measures remain incomplete.

The CRD program provides the best regional framework for identifying problem outfalls. Transport Canada provides the strongest evidence connecting stormwater to sediment, marine organisms and human-health risk. Municipalities control the pipes and the upstream sources. DND and individual infrastructure projects hold additional sediment and source information.

The data should no longer be treated as separate agency studies.

Together, they establish the need for an enforceable Core Area source-control and receiving-environment program that protects the intertidal zone and interrupts the contamination pathway from urban runoff to marine sediment and the food web:

stormwater → sediment and benthic life → sand lance and other forage fish → Chinook salmon → Southern Resident killer whales.

References

  1. Anchor QEA. Stormwater Recommendations Report for Transport Canada-Administered Portions of Victoria Harbour, Victoria Harbour Sediment Management Program. Prepared for Transport Canada and Public Services and Procurement Canada, March 2021.

  2. Capital Regional District. 2024 Core Area Stormwater Quality Program Report. Published 2025, including selected early-2025 information.

  3. Tetra Tech Canada Inc. Sediment Characterization — Cable 2L143 Replacement Project, Victoria, BC. Prepared for BC Hydro, July 8, 2025.

  4. Anchor QEA. Harbour Floor Monitoring Year 1 Data Trends Memorandum. Prepared for Transport Canada and Public Services and Procurement Canada, January 30, 2026.

  5. Transport Canada. Victoria and Esquimalt Harbours Environmental Baseline Study Series, various volumes and addenda covering harbour parcels including Fisherman’s Wharf, Johnson Street Bridge, Point Ellice, Selkirk Trestle, West Bay, McLoughlin Point and Point Hope, principally 1998–2006.

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