# Written Submission to Council re: Proposed Bylaw No. 1746 (Crematoria) - November 28, 2017

Meeting: Regular Council — December 4, 2017

Canonical HTML: [Open Langford](<https://openlangford.ca/meetings/2017-12-04-regular-council/documents/4824>)

Meeting record updated: 2026-10-19T03:59:02.831579+00:00

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Source: [20171204-Agenda-Package](<https://langford.ca/wp-content/uploads/2021/05/20171204-Agenda-Package.pdf>)

Source pages: 23–24

## AI-processed summary

Public correspondence submitted to Council expressing concerns about allowing crematoria in BP2A, BP4, BP8 and M2 zones, citing health and environmental risks and calling for local emissions/monitoring standards.

## Extracted text

### Written Submission to Council re: Proposed Bylaw No. 1746 (Crematoria) - November 28, 2017

Source pages: 23–24

## Written Submission to Council re: Proposed Bylaw No. 1746 (Crematoria) - November 28, 2017

### To
City of Langford Council

### RE
Public Hearing - Application to Amend Zoning Bylaw No. 300 by Means of Proposed Bylaw No. 1746

Thank you for the opportunity to present a written submission to the City of Langford Council, on December 4, 2017, regarding matters contained in the above noted proposed bylaw amendment allowing crematoria in the BP2A, BP4, BP8, and M2 Zones.

From review of Zoning Bylaw No. 300, Crematorium (crematoria used interchangeably in this letter) are currently permitted in BP8 – Centre Mountain Zone. It is my understanding that the proposed amendment will allow the addition of the wording “crematoria” to increase clarity of its already permitted general industrial use in zones BP2A, BP4, BP8, and M2. With this wording proposed to be included in the bylaw, it brings to light that crematoria are already permitted in populated areas, including the more densely occupied M2 zones in the core of the City.

From information available from basic internet research, crematoriums in British Columbia are not subject to environmental regulations. 1

We live in one of the least regulated provinces in Canada for the crematorium industry. While technical standards may be monitored by the Business Practices and Consumer Protection Authority of British Columbia, they apparently do not monitor emissions. What this can lead to is a self-regulating industry, with an interest in its financial bottom line and not necessarily the health of the community that it chooses to do business within. As our population ages there is a direct correlation with the increased need for this type of business. To the best of my knowledge, we do not currently have crematoria in Langford. But, since our bylaws already permit crematoria in our city, it follows that this growing industry will likely ask to do business in Langford soon. The addition of crematoria into Langford could create pressure on public and environmental health, especially in densely populated and developed areas.

Crematoriums create emissions that affect health and environment. This is not exclusively a NIMBY (not in my back yard) issue: it also impacts our neighbouring Vancouver Island communities and our global community. We have a responsibility and a duty to make a healthy choice and get ahead of the issue instead of chasing it. We have an opportunity to learn from our neighbours, including from the District of Saanich with its crematorium problems.

Air scrubbers are not necessarily a viable solution. Scrubbers may or may not effectively filter the mercury, dioxins, and other particulate matter and pollutants from incomplete combustion emissions. They are an expensive addition to a crematorium, ranging from approximately $250,000 to $500,000, and are cost-prohibitive to a business.2 Because the industry is not regulated for emissions, this added expense likely means a scrubber would not be utilized, as it is not required. If the City does not have an effective bylaw to control these types of emissions, then our community has little recourse to make a business comply with what its citizens want for its public health and environmental protection.

### Health and Environmental Concerns

Seen in closer proximity to a crematorium, ash is a concern from the burned particulates that can be inhaled deep into lung tissue, which are potentially harmful.3 Because of this, crematoriums should not be located close to residential areas, including schools, daycares, and work places. On a larger scale, when the emissions are permitted into our air, nature’s atmospheric cycle moves the pollution through the water cycle of evaporation and condensation and into our food-chain. Our water bodies, including Sooke Reservoir, and fish and other species are impacted with this natural cycle. Mercury emissions from amalgam tooth fillings contribute to our atmospheric mercury emissions and since crematoriums are apparently exempt from mercury emission standards, they contribute to mercury deposits and bio-accumulations in our food chain and in our water systems.4

### Suggested City Actions

The City can choose to be proactive, such as with its recent burning bylaw changes, and get ahead of the issue and protect its residents and people who choose to work and do business in Langford. National standards may not be good enough for our community, as we have experienced in our communal past with the turmoil of communication tower installations. The time, money, and cost of human health are incalculable when it comes to fighting to do the right thing by the citizens of Langford against growing industries. Recent news on fish farming waste water emissions and derelict boats in marine waters are clear symptoms of the gaps that exist among our local, provincial, and federal regulating bodies.

With our global warming crisis in mind, I ask the City to consider what this bylaw amendment, with its permitted use wording of “crematoria,” has brought to public light. If the City chooses to allow crematoria to operate in these zones, then I suggest that it should prudently and swiftly, (before crematoria incinerators are installed and can no longer be regulated by the City), create and/or amend air pollution bylaws that:

- require continuous monitoring of mercury, dioxins, and all particulate emissions;
- require real-time reporting of emissions data on a public website;
- establish strict emissions limits;
- create strict set-back requirements for residential and other sensitive properties (such as schools, water bodies, and recreational areas) where populations are dense and ecosystems are sensitive5;
- and do whatever else it believes protects our community in perpetuity.

The City could look at not permitting crematoria as an addition to an existing funeral home business, as we have these businesses already operating in the City.

Langford is known for its leadership and trail blazing to create a community that we are proud to live and work within. Most of us are not scientists and I do not have the industry, scientific, and environmental expertise to be an expert. But, we don’t need experts to tell us that putting particulates into the air is bad and that no amount of air pollution is safe. Until national and provincial health and pollution standards catch-up with the crematoria industry, it is prudent for the City to uphold its commitment to its citizens’ health and our global community by implementing our own local emissions and monitoring standards BEFORE these business operators apply for a business license in our amazing City. We have an opportunity to be a leader in the CRD on this issue and be proactive now to protect our communal health and environment well beyond our individual futures.

Thank you for your consideration,

### References / Footnotes
1. www.bclaws.ca  
   www.2.gov.bc.ca

2. www.ejnet.org/crematoria

3. www.ejnet.org/crematoria

4. www.ejnet.org/crematoria

5. www.ejnet.org/crematoria
