$15,720 in FOI Estimates — CITY OF VICTORIA - for Records About Your Money and Your Water
$10,935 + $4,335 + $450 = $15,720.
Those are the original search-and-preparation estimates attached to three City of Victoria Freedom of Information requests about stormwater, sewer infrastructure, pollution, public spending and the health information behind swimming at Banfield Park.
Not a new engineering study. Not a new environmental investigation.
Access to existing records.
Among the records sought are publicly funded reports, consultant studies, appendices, monitoring results and the accounting behind municipal infrastructure work.
The $450 request concerns something any parent standing beside the Banfield dock can understand: who was consulted about the health risks, what advice was received, and what assessment supported opening or promoting the area for swimming?
The City estimated 11 hours searching and seven hours preparing those records. Its letter required a $225 deposit before processing could continue. The request covered consultations, reports, risk assessments and related correspondence—not simply one named report.
Before another child jumps into the water, shouldn’t that information be straightforward to find?
This started in the water, not in an FOI office
Veins of Life Watershed Society did not begin this investigation because we wanted to spend our days reading sewer documents.
We began because we noticed changes.
After years of cleanup and restoration work around Victoria Harbour, the Gorge Waterway and Portage Inlet, we started seeing warning signs again around 2007.
Water seemed to remain warmer for longer. Turbidity increased. A brown coating—what we describe as “mung”—appeared on eelgrass. Beds we had watched for years no longer looked or moved the way we remembered.
Healthy eelgrass dances like a lady.
It moves freely with the current. What we were seeing looked coated and burdened.
Those are our field observations, not a laboratory diagnosis. They do not establish what caused the changes. They explain why people who had worked in these waterways for years began asking for measurements, investigations and answers.
We emailed. We phoned. We wrote letters. We raised stormwater, contaminated sediment, source control and sewer connections.
The central question was simple: what was changing in the water, and what was being done about it?
After years of questions without answers that resolved those concerns, we started following the documentary record ourselves.
The website points to the report. Then the trail stops.
Victoria’s own website promises easy access to information. It directs people to the Document Library, financial records, Council agendas and other public repositories. Its Council webpage says the HTML agendas contain links to meeting reports. (City of Victoria)
That is where we looked.
By July 2026, our correspondence documented a review of approximately 172 Council and committee agenda and meeting results, alongside financial plans, bylaws, project pages and supporting references.
We found budgets. We found staff summaries. We found project descriptions and references to engineering work.
But finding a reference is not the same as finding the report.
A summary mentions a study. The study refers to an appendix. A financial plan names a master plan. A Council record identifies further work or a report-back.
Then the underlying document cannot be located through the links and searches available.
Our recorded searches pursued sanitary and stormwater master plans, condition assessments, source-control records, Rock Bay investigations and monitoring, and the financial records supporting utility expenditure. The evidence includes a preliminary report documenting what was found and what remained unlocated.
“Not located” does not mean destroyed. A promised report is not necessarily a completed report. Those distinctions matter.
But so does the obvious public question:
If a report was received by Council, supported an expenditure or was identified as a guiding document, where can the person who paid for it read it?
And where a report was never completed, why not say so?
Follow the money—and read the actual figures
Victoria says its Stormwater Utility fee reflects a property’s impact on the system, including runoff volume and water quality. Its stormwater webpage also identifies controlling contaminants at their source as important to protecting local watersheds and the marine environment. (City of Victoria)
Now look at the City’s 2026 capital budget.
It assigns $8.667 million to stormwater mains replacement and $2.745 million to brick-main rehabilitation.
Together: $11.412 million.
The separately identified Stormwater Quality allocation is $404,000. Its listed activities include investigations, laboratory testing, consulting and program information.
Across the $13.179 million stormwater capital budget, those two pipe-renewal categories account for approximately 86.6 per cent. The dedicated Stormwater Quality category accounts for approximately 3.1 per cent.
That is roughly $28 under those pipe-renewal headings for every $1 under the Stormwater Quality heading. These are capital-budget comparisons, not a calculation of all pollution-control spending across capital and operations.
The plan labels the pipe projects as stormwater infrastructure and separately budgets sanitary-sewer I&I work. The headings alone therefore do not establish that stormwater funds were improperly spent on sanitary sewers.
The underlying accounting is precisely what the FOI requests seek to establish.
Which projects repaired storm drains? Which also reduced rainwater entering sanitary sewers? Which removed a sewage connection from a storm drain? Which actually reduced contaminants reaching the shoreline?
Where a project served more than one purpose, which utility paid which share?
Our July 16 submission asked for a focused set of 2024 accounting records: ledger transactions, work orders, coding guides, transfers and the reconciliation supporting the published Stormwater Utility total. The City disputed whether that proposal narrowed the original request because VOLWS also sought to preserve the remaining portions.
For the person paying the bill, the issue is less complicated than that exchange sounds:
How much of your money maintained the drainage system, how much benefited the sanitary system, and how much stopped pollution before it reached the water?
A budget heading cannot answer all three.
The sewer numbers give that question substance
Inflow and infiltration—I&I—means rainwater and groundwater entering sanitary sewers through defects or improper connections. Reducing it can relieve sewer capacity and reduce overflow risks.
The CRD’s published figures for Victoria alone show a substantial change in its estimated I&I rate for a standardized five-year storm:
2010: 96,734 → 2012: 94,281 → 2014: 84,650 → 2016: 76,026 → 2019: 73,490 → 2021: 68,646 → 2022: 75,162 litres per hectare per day.
That metric fell approximately 29 per cent between 2010 and 2021, or 22 per cent between 2010 and 2022. It measures estimated storm-related I&I intensity—not cumulative litres redirected into the Gorge.
The “6 per cent” discussed earlier cannot settle this question without its calculation, time period and definition. Nor can these different percentages, by themselves, disprove it.
What the CRD figures establish is that Victoria’s sanitary-system response has changed materially.
What did those changes mean for the rest of the watershed?
Repairing a leaking sanitary pipe may leave groundwater in the ground. Disconnecting a roof drain or another direct rainwater connection creates a different question: where was that water routed afterward?
Into soil, storage or a rain garden? Into a municipal storm drain? Into which receiving water?
A reduction at the sanitary sewer is only one part of that accounting. The engineering record should explain the destination as well.
That is not an argument against repairing sewers. It is a reason to examine the results on both sides of the pipe.
Then look back at the dock
For someone swimming at Banfield, the accounting and engineering questions eventually become personal.
What information supported recreational use? Which professionals were consulted? Did their advice address stormwater, sewage discharges and contaminated sediments? What limitations or precautions did they identify?
Those were the subjects of VIC-2026-088, the request that produced the $450 estimate.
The estimate does not prove there was no assessment. An unproduced report does not establish that swimming is unsafe.
It means the requested supporting record was not in our hands.
A family should not have to guess what was assessed—or mistake the absence of an accessible report for an answer.
The fee dispute was not an all-or-nothing victory
The original requests were broad. They included records extending beyond final Council reports, and the City said searching and preparing them would require substantial resources. British Columbia’s information law permits certain processing fees and also provides for fee waivers, including for environmental and public-health matters. (Government of British Columbia)
That is the legal context. It does not erase the public-access problem.
On March 18, 2026, OIPC adjudicator Denise Eades issued Order F26-21, granting a 50 per cent fee waiver on the first request.
The order recognized the breadth of the request and declined to shift the entire processing cost to the City. But it also found that the City’s efforts:
“fell short of making every reasonable effort to assist”
The adjudicator identified VOLWS’s public purpose, its willingness to narrow the request and the absence of evidence that it had failed to cooperate. These findings concern the access and fee-waiver process—not a finding of financial misconduct.
Later reductions belong in the story. So do the original estimates.
$15,720 was the combined original search-and-preparation figure—not an amount VOLWS has paid.
“The average member of the public”
The evidence also contains this statement from City official Jas Paul’s affidavit:
“The average member of the public would not be able to understand this data.”
The affidavit said expertise was needed to interpret the technical information and pointed to publicly available CRD reporting. It was evidence in the fee-waiver dispute, not a ruling that technical data must be withheld.
But consider the person standing at the swimming dock.
They do not need to interpret every laboratory result themselves. They may ask a scientist, an engineer, a journalist or a community organization to help.
Understanding every column is not a prerequisite for asking to see the record.
Technical information can come with an explanation. The explanation need not replace the information.
Nearly 1,200 pages—and the questions remain
The completed record through September 18, 2026, contains 1,193 pages, preserved in six searchable evidence volumes.
It includes emails, letters, fee estimates, submissions, affidavits, decisions and supporting attachments. These are not 1,193 separate emails, nor 1,193 pages of withheld reports. They are the documentary record of the requests and proceedings.
The final pages document another procedural turn. On September 16, the OIPC directed the City to resubmit materials without mediation information. On September 18, the City instructed the parties to disregard its September 15 submission and said a replacement would follow.
All of this has required effort from municipal staff, legal services, the OIPC and VOLWS. We do not have a verified total of those hours or their cost.
We do have the record.
And yes, we are angry about the time and effort it has taken to pursue information about publicly funded work and public waterways.
Our position remains that final, releasable reports already referenced in public municipal records should be readily accessible without another costly search. Legitimately protected information can be identified and redacted. Reports that were never completed can be identified as such.
That leaves a straightforward question for the reader:
How much of this process would have been unnecessary if the final reports, appendices and supporting financial records had been easy to find?
Your bill. Your water. Your questions.
The next time you receive a Stormwater Utility bill, put it beside this story.
Then consider what you would need to judge the results.
The amount collected. The work completed. The projects charged to each utility. The pollution sources corrected. The monitoring showing what changed at the outfall and in the receiving water.
Those are the records that connect a payment to an outcome.
And the next time you stand beside the Gorge, consider the other half of the story: the water, the shoreline habitat, the eelgrass and the people using them.
Our observations explain why this investigation began. The published numbers explain why the questions deserve investigation. The missing details are why the reports matter.
The point is not to make readers take VOLWS’s word for everything.
It is to let you read the same record, test the explanations and ask your own questions.
What did your money pay for?
What changed in the water?
And where is the evidence connecting the two?
Numbered references
1. City of Victoria — original FOI fee letters.
VIC-2025-206, October 14, 2025: master pages 18–22. VIC-2025-227, November 12, 2025: 45–50. VIC-2026-088, July 20, 2026: 958–962. The November letter’s line items total $10,935; its printed total contains a one-dollar discrepancy, while its deposit calculation corresponds to $10,935. See evidence volumes 1 and 5.
2. City of Victoria — Freedom of Information.
The City’s commitments concerning access, public repositories and routinely available records.
3. City of Victoria — Council and Committee Meetings.
Instructions for accessing agendas, meeting reports and archived proceedings.
4. City of Victoria — 2026–2030 Financial Plan.
Page 67: capital-budget comparison. Pages 119–120: stormwater project descriptions. The percentages in this article are calculated from the published 2026 capital allocations.
5. CRD — 2021 Core Area Inflow and Infiltration Program Report and 2023 Program Report.
Victoria’s estimated five-year-storm I&I rates, respectively in Table 6.1 and Table 4.1. These are modeled storm-response rates, not annual diverted-water volumes.
6. OIPC — Order F26-21, March 18, 2026; 2026 BCIPC 25.
Reproduced in volume 2, master pages 343–373. See particularly paragraphs 124–137 for the scope, assistance findings and partial fee waiver.
7. Province of British Columbia — FIPPA section 75: Fees.
Authorized processing charges, exclusions and grounds for waiving fees.
VOLWS searchable evidence record
Storage links above enjoy. The six volumes preserve the completed 1,193-page master record through September 18, 2026.
8. Victoria FOI Evidence — Volume 1 of 6.
Master pages 1–172. Includes the original requests, initial fee letters and December 2025 affidavits. Jas Paul’s quoted evidence appears on master page 146. [Storage link to be added]
9. Victoria FOI Evidence — Volume 2 of 6.
Master pages 173–453. Includes further inquiry evidence, Order F26-21 and Stormwater Utility accounting correspondence. [Storage link to be added]
10. Victoria FOI Evidence — Volume 3 of 6.
Master pages 454–609. First portion of the preserved July–August correspondence concerning narrowing and publicly referenced records. [Storage link to be added]
11. Victoria FOI Evidence — Volume 4 of 6.
Master pages 610–785. Continuation of that preserved correspondence and its supporting material. [Storage link to be added]
12. Victoria FOI Evidence — Volume 5 of 6.
Master pages 785–1016. Includes the July accounting submission, preliminary public-record findings, Mayor and Council complaint, Banfield request and fee estimate, and subsequent inquiry correspondence. [Storage link to be added]
13. Victoria FOI Evidence — Volume 6 of 6.
Master pages 1017–1193. Includes the September filing and affidavit, OIPC direction, and September 18 instruction to disregard the earlier submission. [Storage link to be added]
Master page 785 intentionally appears in both volumes 4 and 5 to preserve a message crossing the volume boundary. The manifest and transmission index document the compilation.
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