My response to the SCS review

In September 2019, the Government of Alberta established a Supervised Consumption Sites Review Committee. The government gave the committee a mandate to study the socio-economic impact of supervised consumption sites in the communities where they were located. The government specifically prevented them from simultaneously reviewing the health care impacts of the sites.

At the beginning of March, the committee released the results of their review in a document called “Impact: A socio-economic review of supervised consumption sites in Alberta”.

Because it’s nearly 200 pages long, I won’t be responding to the entire document. I’ll focus specifically on the Lethbridge section, found on pages 24 through 26.

This review is extremely biased and flawed, which will be apparent to the reader as they go through my response. My response below will address the review one paragraph at a time.

Here we go.

Lethbridge has one fixed SCS site, which has been in operation since February 28, 2018 and is run by a not-for-profit organization called ARCHES, originally established in 1986 to curb the transmission of HIV and Hepatitis C. The site provides 24-hour services throughout the week. The SCS site is in close proximity to the Lethbridge Soup Kitchen, a temporary shelter and resource centre, and to the Lethbridge Food Bank. Overall, the immediate area is best described as being light commercial with small retail establishments predominating. A large residential area is situated about three blocks to the south and east of the SCS location.

This opening paragraph is mostly fine; although there’s no residential area east of the SCS. Other than a single, small apartment building on the corner of 13 Street and 2 Avenue South, there are no residences east of the SCS until after Mayor Magrath Drive South. Residences north of the SCS are closer than the residences to the east.

Anecdotal evidence suggests that the Lethbridge SCS site may be one of the most used, not only in Canada, but worldwide. Whether or not this is the case, it is evident that Lethbridge has a significant opioid use problem. In 2018, the number of deaths, mostly due to fentanyl poisoning (overdose), was 25 for a rate of about 25.1 per 100,000 population for the year. In the first six months of 2019, the municipality experienced 11 deaths. This is higher than the provincial average of 17.1 per 100,000 population for the same period. For Alberta, the death rate due to opioids other than fentanyl in 2018 was 9.4 per 100,000 (seven deaths) while in the first half of 2019, it was about one per 100,000 (one death).

This is true, and this fact should not be ignored when considering such things as prevalence of social disorder. That being said, there are a few things to keep in mind. First, although Lethbridge’s death rate is higher than what the report labels as the provincial average, it’s not the highest. Grande Prairie, at 51%, is more than twice as high as Lethbridge’s 22.5% for the first half of 2019. In 2018, it was lower than both Grande Prairie and Red Deer, which had 32.4% and 42.8%, respectively. Lethbridge’s death rate increased between 2016 and 2017 and between 2017 and 2018, so clearly it was a growing issue prior to the SCS opening.

On the point of the provincial average, the 17.1 cited in the review is not actually an average. It is the number of deaths per 100,000 for the combined population of the 6 cities. The average of the 6 cities studied in the cited report is actually 23.7%. So, in actuality, Lethbridge’s death rate for the first half of 2019 was actually lower than the average of the 6 rates.

The Lethbridge SCS reported that from its opening in February 2018 until July 31, 2019, there had been 268,283 visits. In its report to Lethbridge City Council in August 2019, ARCHES noted that, “Since opening the facility, there has been a high uptake of service with approximately 1,376 community members having accessed the SCS and an average of 663 visits to SCS a day.” In their latest report to Alberta Health for the six-month period from April 1, 2019 until Sept 30, 2019, they reported a total of 910 unique users, with an average of about 136 unique users per day.

I have nothing to comment on here, as they, in turn, provided no commentary or analysis in this paragraph.

Based on multiple comments from stakeholders, it was the Committee’s impression that the Lethbridge SCS site may be facing the most problems in the province, since the expressed concerns were disproportionately higher than expressed at other sites. Most of the concerns the Review Committee heard were directed at the operations of the site itself — how it is being run, the behaviour of its employees, an apparent lack of accountability, alleged occurrences of flagrant and open criminal activity around the site, its isolation from the greater community and several questions about the integrity of how data are submitted. The Review Committee also heard from some medical professionals that they would not work in this place as it is “unethical.”

Another explanation for the disproportionally higher number of expressed concerns is greater prejudice among people in Lethbridge.

Even so, just because the committee received a large number of complaints doesn’t mean that this indicates a large number of individual events. The complaints could be describing the same events. For example—hypothetically speaking—if over the last year, there was only one person who consumed drugs in the alley behind SCS, but 30 people submitted complaints to the review committee about that person, it wouldn’t be fair to interpret that as 30 people consuming drugs in the alley.

Regarding medical professionals, did you hear from medical professionals who would be willing to work in the supervised consumption site? After all, medical professionals are already working there. They don’t seem to find that it violates their ethics.

Recently, there has been open conflict between the site and some residents and local business owners. In July 2018, there were protests both for and against the site. Much of this conflict is playing out through social media channels. One nearby business owner has (and continues to) broadcast pictures and live video from cameras placed around his building to illustrate the disorder at the SCS site and at his place of business because of the SCS site. This has resulted in equally hostile and aggressive responses including purported death threats by the site’s supporters. As indicated in the previous section of this report, police calls for service around the site have increased dramatically since it opened.

To be clear, this disorder is caused by the drug crisis, not the SCS. This disorder still existed in 2017, and even before that. It’s just that Doug Hamilton didn’t care then because it was happening in someone else’s alley and behind someone else’s building. It’s true that there are more instances of disorder in that vicinity than before the SCS opened, but that’s because some of the instances that occurred prior to 2018 simply shifted to this location instead of the downtown alleys, nearby parks, and school grounds where they had been previously.

Funny how there’s no mention about the countless death threats made to staff and clients of the SCS.

Of course police calls for service have increased around the site. People in the area hate that it’s there and will use whatever opportunity they can to shut it down, including phoning the police for benign activity. While calls of services could correlate with crime—theoretically—they don’t correlate one-for-one: one call for service doesn’t mean one crime. Calls for service are when people phone the police to report something they think needs responding to. And while certainly, this could include reporting crime, it also includes people phoning in someone sleeping in their entrance or a group of people just standing around outside their business. Calls for service is a poor indicator of crime or even general risk to the public.

It is also believed by many members of the community that ARCHES staff actively contribute to the problem of drug use. Several community groups that met with the Review Committee indicated that they felt intimidated by ARCHES and were afraid to speak out in public out of a fear of retribution by ARCHES.

Of course there are people in the community who think ARCHES staff contribute to drug use. Heck, there are people who think the SCS in general enables drug use. It’s one of the most frequent myths perpetuated by opponents of the site. But what does many members of the community mean? How many is many? Is it 5? 50? 500? Why not quantify it? Also, you used many 76 times in your document, in case you were wondering.

Also, in what ways do these members of the community think staff contribute to drug use? Why just leave the claim sitting out there like that?

Also, referring to drug use as a problem seems subjective. How is drug use problematic? Because of crime? Wouldn’t crime be the actual problem? Or perhaps elements of social disorder, such as loitering, sleeping in businesses, or public defecating? But, again, wouldn’t those specific actions be what’s problematic, and not the drug usage itself? If society was able to eliminate crime while still allowing drug usage, if it could address social disorder while allowing drug usage, would we still see drug usage as problematic? After all, social disorder and crime are connected with alcohol usage, but we don’t find alcohol usage problematic.

Finally, I can’t really speak to the intimidation by ARCHES staff, as I wasn’t there to witness the summarized claims apparently found in the submissions. That being said, I find it interesting that the report references intimidation done by ARCHES staff—real or not—but failed to reference intimidation done to ARCHES staff. They don’t label Doug Hamilton’s live streaming of surveillance video of the facility as intimidation. They don’t mention staff and clients being shot by paintballs as intimidation. They don’t label people organizing protests on SCS property as intimidation. They don’t label the racism, sexism, and death threats sent by email to staff or posted in social media comments as intimidation.

And by leaving out these acts or refusing to label them as intimidation, the report writers are trying to frame SCS staff as the antagonists and the concerned citizens as the protagonists.

The statistics generated by the site appear to be out of line with those in the rest of the province, as do some aspects of the costs. Except for the smaller sites (RAH in Edmonton, and the mobile site in Grande Prairie), the Lethbridge SCS is estimated to be one of the costliest on a per-capita (client) basis. While most of the other sites have a cost under $600 per unique client, the cost in Lethbridge is over five times that, at $3,270 per unique client. The Committee could not find any plausible explanation for this, and there was no mention of it by the Alberta Health management contact person who would have overseen this in the past.

Really? You couldn’t find any plausible explanation for it? Are you costing just supervised consumption site services operated by ARCHES, or are you looking at their total operating cost, which covers 17 health services, including supervised consumption? Do the other supervised consumption sites in the province provide such comprehensive services? Do the other sites provide as many consumption services as Lethbridge does, including injection and inhalation facilities?

Even so, let’s talk about that calculation. On page 24, you indicated that the average cost per visit is $25, and when you multiply this by the 119,355 total visits between 1 April and 30 September 2019, you report a total of $2,982,756. You then divide this by 910 unique clients to get an average cost per unique client of $3,278.

Well, first of all $25 times 119,355 is actually $2,983,875, not $2,982,756. But your false calculation aside, I don’t think measuring cost effectiveness based on unique clients is a fair assessment, particularly at a facility that offers 17 health services.

If a client comes in at 2:00 in the morning to use the injection facilities, then at 11:00 to use sexual health services, then at 15:30 for the Hip Hop For Healing programme, you’re calculating their cost as if they made one visit, despite having accessed multiple services, all of which are delivered by separate staff members.

I think a fairer metric for determining cost of delivery is cost per visit per day, particularly if you’re using total funding and total visitors to calculate the delivery cost, considering that you’re not delineating the different types of unique users.

And if we use cost per visit per day, Lethbridge’s is—according to Table 13—$25.18, which is not only below the provincial average of $101.93, but it is the lowest cost per visit per day of any of the supervised consumption sites in Alberta.

ARCHES operates the most cost-efficient facility in Alberta, and it’s unfair to misrepresent it as the most expensive.

An increase in crime rates was one of the key concerns raised by many who attended the town hall meetings in Lethbridge. Police calls for service suggest that the city has experienced one of the highest levels of crime increases at a site location relative to the rest of the city. Despite the increase in police activity, many residents believe that there is a “safe zone” for open drug use, trafficking, prostitution and related criminal activity around the Lethbridge SCS site. The Committee was reminded by many stakeholders of the seriousness of crime in the area. During the limited time the Review Committee spent visiting the area around the site, members directly observed several instances of open drug use, with individuals injecting drugs on the sidewalks close to the SCS site. Committee members also observed what appeared to be drug trafficking as well as prostitution.

As I mentioned above, calls for service is a poor indicator of crime, since it includes more than just criminal activity.

In a news article from September, Acting Police Chief Scott Woods denied the myth that there is a “safe zone” around the SCS, stating:

“That’s not true. The police . . . us, will arrest people for criminal activity around there, including drug possession and trafficking. The only exemption that the Federal Government has given is within that site specifically. So, criminal activity around that site is not something we’re turning a blind eye on.”

It’s irresponsible of the review’s writers to perpetuate this commonly held myth and omit official statements from the Lethbridge Police Service that debunk this myth.

Regarding the actual crime observed by committee members, I’m not sure what the point of this is. As I already pointed out, crime existed in Lethbridge prior to the SCS opening. In fact, crime has increased every year since 2014. If crime increases in the city overall, then it makes sense that crime will also exist, let alone increase, in the area around the SCS. But, again, the SCS doesn’t cause the crime. If you label public drug usage as a crime, as the quote above does, then the SCS actually reduces crime, since people consuming drugs in the SCS aren’t consuming publicly. Now, people might be committing the acts listed in the quote around the SCS because the SCS is there, but if the SCS didn’t exist, those acts would still occur; they’d just be in other locations in the city, maybe even still relatively close by, such as downtown parks or alleyways.

This view is echoed by members of Lethbridge Police Services in the First Responders’ Survey. As one police officer wrote: “The SCS is a lawless wasteland. Drugs can be readily purchased right in the parking lot. I have watched videos where SCS security staff are watching while drugs are being bought and sold and say nothing. They say they are reluctant to call police because it is frowned upon by SCS management and they don’t want to lose their jobs. SCS management make it very clear police are not welcome there and regularly complain if police try to do enforcement in the area.”

Another law enforcement officer stated that, “There has been attempts by the SCS staff to destroy video evidence. They had a pregnant lady have [a] miscarriage immediately after using their facility. They became offended when I asked what their procedures were for pregnant women and filed a formal complaint.”

In a news article from March 2020, Scott Woods said regarding the claim that police are unwelcome at the SCS, “We have a fairly positive relationship with (ARCHES). I meet with them monthly, and I discuss any issues we may have.” The article later summarized Woods, claiming that he said any issues LPS has with the SCS is with any crime in the immediate area, and not with the staff in the SCS.

Everything else in those quotes is heresay, so there’s not much I can respond to, as I wasn’t present during any of those apparent events.

Lethbridge Police services reported that in the period of March 1, 2018. and February 28, 2019, there were 424 calls for service in the area immediately surrounding the site. During the same period the year prior, there were only seven calls for service. Across the city, there was only a 0.15 per cent increase in total calls for service across the two periods. This is consistent with a dramatic and disproportionate increase in call rates to police after the SCS site opened.

Again, this makes sense, as mentioned above. Plus, the building sat vacant from August 2017 until they started construction. And even before August, the nightclub that was there was open only twice a week, so it’s not surprising that they had lower calls for service. I’m curious, however, what the number of calls for service were several years ago when The Roadhouse was at that location. For example, what was the number of calls for service in the area in 2009, when 5 people were stabbed at that location?

That being said, let’s look at calls for service city wide: 27,638 in 2014, 28,519 in 2015, 26,119 in 2016, 34,327 in 2017, and 34,379 in 2018. There are a couple of things to note here.

First, calls for service were up significantly in 2017—the year before the SCS opened—over 2016. Obviously, that wasn’t the fault of the SCS. Even in the first year of operation for the SCS, calls for service were up by only 52 for the entire city. If calls for service for the area increased 600% in the immediate area of the SCS, it wasn’t because calls for services increased substantially, but they shifted locations.

Second, calls for service for the entire city increased by 3% between 2014 and 2015, dropped by 8% between 2015 and 2016, increased by 24% between 2016 and 2017, and increased by only 0.2% between 2017 and 2018. The largest increase to calls for service citywide was the year before the SCS opened, and it increased by three times as much as the second largest increase. The year the SCS opened, calls for service for the entire city increased by less than 1%.

For reference, the population of Lethbridge grew by 1.6% between 2017 and 2018. That means that calls for service for the entire city increased at a lower rate than the population did in the same period. If you account for population growth, that means calls for service per capita actually dropped for the entire city the year the SCS opened.

Again, if calls for service for the city overall did not increase significantly, then all a 600% increase in the SCS vicinity means is that the calls for service shifted from elsewhere in the city.

Another major complaint concerning the Lethbridge SCS site relates to the volume of needle debris surrounding the site. As noted elsewhere in this report, needle debris is a significant issue in all areas where supervised consumption sites or needle distribution and exchange services are located. The situation in Lethbridge, however, is reportedly exacerbated by the particular policy of needle distribution that allows drug users to obtain excessively high quantities of needles — that is, packages of 200 to 500 needles at a time — simply upon request. ARCHES reports that it distributes somewhere between 13,000 to 15,000 needles per month. Presenting before the Review Committee, one representative reported a number that is approximately two to three times higher, indicating that 37,000 syringes are distributed per month from ARCHES. This is beyond those needles that are issued and used inside the actual SCS. ARCHES maintains that all but about 400 needles per month are accounted for. Given the directly observed residual level of needle debris around the site, however, this assertion does not appear plausible and appears to defy credulity. Several stakeholders raised doubts about whether ARCHES is forthcoming and candid in their self-reporting. The review committee was not able to corroborate the veracity of ARCHES’s statements.

While 13,000–15,000 needles per month seems like a lot, it’s important to keep this in context. In the “A Community Based Report on Alberta’s Supervised Consumption Service Effectiveness” published last summer by the Alberta Community Council on HIV, we find the following table:

In it, we see that during the first year the SCS was open, ARCHES was actually distributing 11% fewer needles than the year before it opened. Not only that, but the return rate went from only 32% the year before it opened to more than tripling to 103% for the first year the SCS was open. So, 2018 saw fewer needles going out and more needles coming back than in 2017. And while the 2019 number are incomplete, the return rate is higher than 2018, despite being on track for distributing more needles.

Given that ever since it opened, the SCS has been retrieving more needles than it has been distributing, the number distributed doesn’t seem to be significant. Even if we assume that the claim in the above quote of 37,000 syringes per month is correct (not the 9,269 listed in the ACCHIV report), at a 113% return rate, that would mean that ARCHES collected over 500,000 needles in 2019. It’s odd that the panel’s review left out the figure of half a million needles being collected by ARCHES last year.

What basis did the stakeholders have for raising doubts regarding ARCHES reporting practices? Did they provide justification? Was it just a hunch? Why is this information not present in the review?

The fact that the panel was unable “to corroborate the veracity of ARCHES’s statements” means they were equally unable to prove them false. Saying that you can’t prove something is true doesn’t automatically mean it’s false. That’s fallacious.

In a 2019 report to Lethbridge City Council, ARCHES also noted that, “From 2017 to 2019, needle distribution has decreased approximately 70 per cent.” This 2019 report does not provide the number of needles distributed in either 2017 or 2019. Nor is there any explanation as to why distributing 70 per cent fewer needles is acceptable now but was not in 2017. It remains unclear how ARCHES determined its policies on needle distribution.

Distributing 70% fewer needles is acceptable now because we have a supervised consumption site now. If people are consuming drugs at the site instead of in public, then there’s less need to distribute needles. It’s simple logic.

Lethbridge residents also report finding large numbers of unused needles in public areas. This is in addition to the volume of used needles that are discarded in public. Numerous stakeholders reported that needle debris causes significant concern among parents with children. During summer 2019, the local press reported the case of a six-year-old who was apparently injured by a discarded used needle. The child was given a series of blood tests and was started on a treatment for a possible Hepatitis C infection. To alleviate anxiety, some medical professionals cited evidence that the likelihood of contracting an infection from a used needle is small. Most parents found little solace in this, and it was evident that some stakeholders were offended by this apparent insensitivity to the consequences of a needlestick injury in a child, especially given that the supposed purpose of distributing needles is to prevent the spread of blood-borne infections, such as HIV and hepatitis, among drug users.

This is what I don’t understand. The panel goes out of their way to criticize the fact that they couldn’t verify the truth of ARCHES’ claims, but they say nothing about verifying the claims of submitted reports from the public.

How many needles did the public find? Are some user-submitted reports discussing the same needles? Were they needles that ARCHES picked up but that the public saw prior to pickup?

ARCHES has been distributing clean needles for decades. Literally, decades. Long before the SCS opened. If there was an increase in discarded needles in public, it’s because drug usage in public has increased because of the drug crisis over the last 5 years, not because the SCS opened. Even so, given that tens of thousands of instances of drug consumption have occurred at the SCS over the last two years, that’s tens of thousands of instances of drug usage that did not occur in public. As already established above and in your own report, there are literally fewer needles in public, so it’s confusing how people can be reporting large numbers of needles in public places.

Yes, the purpose of distributing clean needles (the actual purpose, not the supposed purpose, as you call it) is to prevent the spread of blood-born infections. By distributing clean needles, it reduces needle sharing, which would be a significant cause of contracting infections. And the fewer infections we prevent from spreading, the lower the risk of contracting infections from a discarded needle. That risk is further minimized by a year-over-year increasing rate of needle return.

Numerous complaints were received by the Review Committee about how the Lethbridge site is operated.

But what does this mean? What were the complaints? What was the proof of these complaints? Did you “corroborate the veracity of these statements”?

The Review Committee was also informed by ARCHES that it currently employs 174 persons working at the site. Putting this into context, at the time the Review Committee visited Lethbridge the site was seeing approximately 130-135 unique users per day. At the same time, police in Lethbridge had 161 constables on staff.

So what? Alberta Health Services employs over 3,300 people in Lethbridge. The University of Lethbridge employs nearly 2,300 people. I’m not sure I understand what the point is here.

An ARCHES worker told the Committee that approximately 40 per cent of workers at the SCS are “addicts in recovery” themselves. There was no apparent concern about the associated occupational risk or relapse risk to those workers in recovery.

Why do you think this is an issue? Was there evidence of occupational risk or relapse among staff over the last two years?

Finally, the review panel included a single quote from someone who is in detox:

“When I was in the Fort McLeod detox last year, I had made the first step in getting sober and trying to maintain a healthy lifestyle. There were mandatory groups we had to attend which also included ladies from ARCHES coming in and telling us about their programs and what is included. Letting us know where the SCS was located and that they were on ways to test drugs so us addicts know exactly what we were getting. Also, that they will help drive us to and from appointments, as well as give us clean material to use with. I felt extremely hopeless. Was there even a reason for me to get clean? I ended up calling my mom crying, how desperately I wanted to get out of detox. I was feeling extremely triggered. I felt resentful towards Foothills detox for letting these ladies in. I thought they were supposed to help me, not give up on me.”

In contrast, here are some testimonials from people who use the SCS:

ARCHES is a type of family where you are accepted despite the drug life. Smiling faces of support and encouragement greet you at the door, making the trip to get here worthwhile every time.

The supervised consumption site are my heroes. Thanks for saving my life.

The supervised consumption site is the best life saving project. Keep up the good work.

They help me feel better about myself and feel safe.

Without the site, I probably wouldn’t be here.

The most important thing to me is the staff being there for me lately in my most toughest time.

The supervised consumption site means feeling safe with the services here. Having health services and counsellors close by to help is important. Feeling comfortable with the workers!

ARCHES has been the best thing for me because I don’t have much people before them. I got everything I need and want: a family who cares.

As seen above, this review published by the panel is biased, lacks academic rigour, and fails to present the supervised consumption site in an objective, balanced, factual way. It focuses on anecdotes and misrepresenting what little data it does share.

It’s unfortunate that this review will be used to create policy regarding supervised consumption sites in Alberta.