No apologies have been received
at this time.
2
Confirmation Of Order Of Business
3
Interests
Members are reminded of their obligation to declare any conflicts of interest they might have in respect to
the items on this agenda.
No requests
for public forum have been received.
5
Confirmation Of Minutes
5.1
12 February 2025 - Minutes
That the Nelson Regional
Sewerage Business Unit
1. Confirms
the minutes of the meeting of the Nelson Regional Sewerage Business
Unit, held on 12 February
2025, as a true and correct record.
Minutes of
a meeting of the Nelson Regional Sewerage Business Unit held in the Boardroom,
Best Island on 12 February 2025, commencing at 10:00 AM.
Present: Tasman
District Councillor K Maling (Chairperson), Tasman District Councillor
B Dowler, Nelson City Councillor T Skinner (Deputy Chairperson), Nelson City
Councillor K Paki Paki and Independent Member T Mehmood
In Attendance: Deputy
Chief Executive/Group Manager Infrastructure (A Louverdis), General
Manager Regional Services
(N Clarke) and Governance Adviser (A Bryce)
Apologies: Industry Representative (non-voting) P Wilson
1 Apologies
Resolved RSBU/2025/1
That the Nelson Regional Sewerage Business Unit
1. Receives
and accepts the apology from Philip Wilson.
TDC Cr Dowler/Cr Skinner Carried
2 Confirmation Of Order Of Business
There were no changes
to the order of business.
3 Interests
There were no updates to the Interests Register, no interests with items on the agenda were
declared.
4 Public Forum
There was no public forum.
5 Confirmation Of Minutes
5.1
15 November 2024 - Minutes Resolved RSBU/2025/2
That the Nelson Regional Sewerage Business Unit
1. Confirms
the minutes of the meeting of the Nelson Regional Sewerage Business
Unit, held on 15 November
2024, as a true and correct record.
Cr Paki Paki/TDC Cr Dowler Carried
5.2 15 November 2024 – Minutes
Confidential
Section 7(2)(b)(ii) To
protect information where
the making available of the information would be likely unreasonably to prejudice
the commercial position of the person who supplied or who is the subject
of the information
Nelson Regional
Sewerage Business Unit - 12 February 2025 2 of 3
6 Reports For Decision
6.1
Nelson Regional Sewerage Business Unit General
Manager Update Report February 2025
General Manager Regional Services, Nathan Clarke and Operations
Manager Regional Services, Brad Nixon, took the report
as read and answered questions on maintenance expenses budget and expectations, health and
safety incident reporting and implementing improvement for contractor reporting
management and fire risk monitoring.
Resolved RSBU/2025/3
That the Nelson Regional Sewerage Business Unit
1. Approves the commencement of the consent
application for discharge
of wastewater to land on Best Island and Bell Island
in the current financial year (a year earlier than expected), at an estimated
cost of $300,000 with this to be offset against the proposed carry forward for the High Flow Pumpstation
budget that will not be completed this financial year.
Cr Skinner/Aneika Young Carried
7
Exclusion
Of The Public Resolved RSBU/2025/4 Recommendation
That the Nelson Regional Sewerage Business Unit
1.
Excludes the public from the following parts of the proceedings of this meeting.
2.
The general subject
of each matter
to be considered while the public
is excluded, the reason for passing this resolution in relation to each
matter and the specific grounds under section 48(1) of the Local Government
Official Information and Meetings Act 1987 for the passing of this resolution
are as follows:
Cr Paki Paki/TDC
Cr Dowler Carried
Section 7(2)(i)
To enable the local authority to carry on, without prejudice or disadvantage, negotiations
(including commercial and industrial negotiations)
The meeting went into confidential session at 10.45a.m. and resumed in the public session
at 10.50a.m.
8 Minutes Confirmed In Confidential
The only
business transacted in confidential session was to confirm the minutes of 15
November 2024. In accordance with the Local Government Official Information and
Meetings Act, no reason for withholding this information from the public exists, therefore
this business has been recorded
in the open minutes.
Resolved RSBU/2025/5
That the Nelson Regional Sewerage Business Unit
1. Confirms
the minutes of part of the meeting of the Nelson Regional Sewerage Business
Unit, held with the public excluded on 15 November 2024, as a true and correct
record.
Cr Skinner/TDC Cr Dowler Carried
There
being no further
business the meeting
ended at 10.50a.m.
Confirmed as a correct
record of proceedings by resolution on (confirmation date). Insert Resolution here (remove
bold please)
Business Unit 14 May 2025
Report Title: R25-212 NRSBU General Manager
Update Report
May 2025
Report Author:
Business Unit 14 May 2025
Report Title: R25-212 NRSBU General Manager
Update Report
May 2025
Report Author: Nathan Clarke
(General Manager Regional
Services)
Report Authoriser: Alec Louverdis (Deputy Chief Executive
/ Group
Manager Infrastructure)
1
Purpose of Report
1.1
This report is an update by the General Manager
(GM) on activities undertaken to 31 March 2025 by the Nelson Regional
Sewerage Business Unit
(NRSBU).
2
Recommendation
That the Nelson
Regional Sewerage Business
Unit
1.
Receives the NRSBU General Manager Update
Report May 2025; and
2.
Approves retrospectively the submission
made to Taumata Arowai on behalf of NRSBU regarding consultation on proposed
wastewater environmental performance standards.
3
Health and safety
3.1
H&S for the operations contract is being
managed well, and no significant safety issues are currently outstanding, the H&S Dashboard
is now up and running and a
copy of this is shown below in section 3.2.
3.2
No significant incidents
occurred during the
period.
Nathan Clarke
(General Manager Regional
Services)
Report Authoriser: Alec Louverdis (Deputy Chief Executive
/ Group
Manager Infrastructure)
4
Purpose of Report
4.1
This report is an update by the General Manager
(GM) on activities undertaken to 31 March 2025 by the Nelson Regional
Sewerage Business Unit
(NRSBU).
5
Recommendation
That the Nelson
Regional Sewerage Business
Unit
3.
Receives the NRSBU General Manager Update
Report May 2025; and
4.
Approves retrospectively the submission
made to Taumata Arowai on behalf of NRSBU regarding consultation on proposed
wastewater environmental performance standards.
6
Health and safety
6.1
H&S for the operations contract is being
managed well, and no significant safety issues are currently outstanding, the H&S Dashboard
is now up and running and a
copy of this is shown below in section 3.2.
6.2
No significant incidents
occurred during the
period.
Nelson Regional Sewerage
|
Event Type
|
Date
|
Event Details
|
Summary
Findings
|
|
Close Call (Near
|
20/02/2025
|
While
jetting
|
The hose
was
|
|
Miss)
|
|
biosolids line with
|
monitored by the
|
|
|
|
Nicholsons to
|
jetting
operator as
|
|
|
|
release
stuck pig,
|
it was going into the
|
|
|
|
their
pressure line
|
pipe and
no issues
|
|
|
|
snapped
at the
|
were found,
this
|
|
|
|
|
|
|
|
|
|
|
|
|
|
coupling and flew out of the hole
missing me but covering me in water both biosolids and water.
|
was the second or third time this
section of hose had entered the pipe.
This was an unforeseeable event as the
hose and feral's were in good condition.
|
|
|
|
|
A hose doctor attended site to repair
the hose, he checked the other feral connections at this time and had no
concerns with the fittings.
|
|
Injury/Illness
|
04/03/2025
|
Bitten by a spider
|
Bite site was
|
|
(Accident)
|
|
on my neck when I
|
swollen, but healed
|
|
|
|
was cleaning the
|
up without
|
|
|
|
containers out
|
complications
|
|
Close Call (Near Miss)
|
05/03/2025
|
When I was crossing the causeway at
6.45am yesterday I came across a lady
walking a dog. It was quite foggy and I didn't see her until I was right on
her. I think it shocked her and me. She had her
dog under control
|
Good driving practice avoided an
incident, the pedestrian should not have been in the area but we are aware
they are often walking through there
|
|
Property Damage (Incident)
|
18/03/2025
|
Opening the drivers door of ute when a
strong gust of wind pushed the door it broke a central hinge and this dent in
the door and the body.
|
Employee was reminded of the Bell Island
induction section on reverse parking in carparks, and the caveat to park into
/ facing the direction of wind as a priority when onsite.
|
|
Property Damage
Incident
|
31/03/2025
|
Installing
mobile diesel pump for seeding from facultative pond 2 to facultative pond 1, a hose has been broken by high pressure because all
ponds pipeline were closed by main butterfly valves.
|
Hose rated
much higher than pressure generated
by pump, so shouldn’t have failed.
Review condition of hoses onsite.
Review SOP
for pumping. Instigate 6 monthly
inspections of all
pumping
hoses.
|
4 Operations
and maintenance
4.1 Operational performance of the Nelson
Regional Sewerage Scheme (NRSS) continues at a high level.
4.1 The dashboard
of compliance data is shown below, with no non- compliance issues occurring during
the year to date.
4.2 The operating & maintenance costs against the Target Outturn
Cost (TOC) for the 2024/2025 year are slightly
above the NRSBU
2024/2025 Business Plan
forecast budget. The increased costs were related to a higher maintenance
programme at the start of the fiscal year, along with abnormal pond conditions
over summer and unexpected maintenance requirements to the primary clarifier.
Costs over the final quarter are expected to be lower than the budget and bring
expenditure closer to budget.
4.3
Graph of progress
against Target Outturn Cost (TOC)
Figure 1: O&M Contract Expenditure vs TOC
4.4
Odour
4.4.1
There were no odour notifications over January to March
4.5
Wastewater overflows:
4.5.1
There was one wastewater overflow
during the period.
4.5.2 The discharge occurred
during a trial
run of bypass pumping by a
contractor at the Beach Rd pumpstation to allow the connection works of the duplicate
rising main to proceed.
4.5.3 A hose used in the bypass pumping failed, resulting in an estimated discharge of 35m3 to the area around the pumpstation,
which reached Saltwater Creek and the Waimea Estuary.
4.5.4 The hose failed
at roughly 25% of its pressure rating,
and whilst an exact cause of
the hose failure has not been confirmed the damage indicated deterioration of
the internal lining of the hose was the primary factor contributing to failure.
4.6
Beneficial reuse of resources:
4.6.1 NRSBU has applied
46,300m3 of treated
effluent to land so far this
irrigation season.
4.6.2 18,969m3 of treated
effluent has been processed through
the
ultra-filtration (UF) plant for re-use onsite
during the report
period.
4.6.3 8,288m3 of UF treated water
was exported to Green Acres Golf
Course for use for irrigation during the report period.
4.6.4 NRSBU applied 6,598m3
of Biosolids between
September and December 2024.
This equates to 14.4 tonnes of Nitrogen for fertiliser to the Motoroa/Rabbit
Island pine forests.
5
Compliance with Trade Waste
Agreements
5.1 NRSBU provides
services to its customers under Trade Waste Agreements
(TWAs).
5.2 The TWAs confirm the flows and loads NRSBU
is contracted to convey and treat for each customer.
5.3 As
part of the new network reporting requirements implemented by Taumata Arowai,
NRSBU is required
to report annually
on compliance with TWAs along with actions taken in
response to breaches.
The table below outlines
the contracted flow and load breaches for the
2024/25 financial year to date:
|
Contracted Parameter Number of breaches
|
|
Average daily volume
|
0
|
|
Peak ½ hour
flow
|
3
|
|
BOD (Biochemical
Oxygen Demand)
|
0
|
|
COD (Chemical Oxygen Demand)
|
0
|
|
SS (Suspended
Solids)
|
4
|
|
TN (Total
Nitrogen)
|
0
|
|
TP (Total Phosphorus)
|
0
|
5.4 Officers will shortly be writing to contributors highlighting the breaches. The
breaches have not had material impact on the performance of the scheme, and
therefore penalties under the TWA are not intended to be applied. One
contributor may be required to increase their contracted suspended solids
limit.
6 Projects
6.1 General projects
underway at present
include:
6.1.1
Update of the Business Continuity Plan.
6.1.2
Regional wastewater philosophy development.
6.1.3 Moturoa/Rabbit Island biosolids discharge consent finalisation (awaiting TDC action of minor
amendments).
6.1.4 Condition assessment of the concrete
rising main between
Monaco and Bell Island.
6.1.5 Pump replacement at Beach Rd and Wakatu
pump stations.
6.1.6
Pump and non-return valve replacement at Airport pump station.
6.1.7
Emission management plan
development.
6.1.8 Biosolids application facility
tank odour extraction & treatment, flow
actuation.
6.1.9 Update Moturoa/Rabbit Island biosolids application consent to better
manage stormwater discharge from the facility.
6.2 Bell Island
projects currently underway
include:
6.2.1 Installation of isolation
valves to rising mains at the treatment plant inlet structure.
6.2.2 Fencing improvement to Bell Island to improve
safety around the ponds.
6.2.3 Bell Island access
road resealing.
6.2.4
Biosolids tank renewal.
6.2.5
Old sludge storage
tank removal.
Figure 2: Old sludge storage tank with top strake
removed
6.2.6 Secondary treatment system upgrade concept
design works –
this is substantially completed, with refinement of the concept to
ensure ease of any future expansions. Progression to detailed design will be
delayed slightly to consider the outcomes from the upcoming Taumata Arowai
wastewater standards.
6.2.7 Bell Island High Flow pumpstation design – work has commenced on this design, however the
scope of this work has broadened slightly to consider integration of the
project with the renewals required on the Bell Island gravity pipelines, to
check if cost savings are possible.
6.2.8
NRSS Rising Main Duplication:
6.2.9 The duplicate rising main from Beach Rd to Martins
Point was brought online
during the report period, following connection works at the Beach Rd
pumpstation.
6.2.10 The final component
of works, connection to Saxtons pumpstation, is now underway. This is
expected to be bought into service in early May.
6.2.11 Bell Island site designation:
6.2.12 Officers are working
with TDC to finalise conditions for the designation.
6.2.13 The designation conditions, and required delegations to accept the conditions, will be brought to a
future meeting.
7
Risks
7.1 NTRLBU has an ongoing process
on managing risks and criticality at different levels within the Business Unit process,
7.2 Asset management system
7.2.1 NRSBU has been looking to upgrade the asset management system being
used to allow the required
level of functionality.
7.2.2 Currently the Infor Asset management system does not have the
functionality to accommodate the Best Practice “Three Waters” Asset
management schema which NRSBU has adopted, and the current Infor system does
not have a field module for inputting data. These, along with other deficiencies, mean the current
Infor system is considered by officers as not fit for purpose.
7.2.3 The new system proposed is Asset Work Manager, which NCCs transport team has been using for a long time and which the NCC
parks team is currently implementing. The system is currently going through a
business case process for adoption by NCC utilities. NRSBU will move to this
new system as soon as it has access to it.
7.3 Rising main
capacity:
7.3.1 The NRSBU provides
services for its customers based on requested flows and loads.
7.3.2 The customers are asked to confirm future demand annually, so that NRSBU can understand future capacity requirements and can plan and
implement upgrades in a timely fashion.
7.3.3 In response to the request
at the end of the 2023/24 financial
year NCC and TDC have either confirmed sizable increases in future
flows, or subsequently advised recent
updates to the Future
Development Strategy (FDS) will result in increases
to flows currently requested.
7.3.4 NCC and TDC have advised that they are currently updating catchment models
to better refine
flow predictions, however
if the future projected flows
are correct/confirmed then there will be insufficient capacity within the
network to accommodate the projected flows. NRSBU will need to seek funding in
the next NRSBU Activity Management Plan for a new rising main from Richmond to
Bell Island following a clockwise route, this has an estimated cost of around
$60 Million.
7.4 Bell Island
discharge capacity:
7.4.1 The Bell Island discharge
consent allows for the treatment
plant to discharge for 3
hours after high tide, at an average daily limit of 20,000m3, or to a maximum
daily limit of 25,000m3.
7.4.2 Since the current consent was issued the Bell Island treatment plant has had to exceed the discharge limits
on three occasions to mitigate or avoid uncontrolled overflows from the ponds.
These events have occurred as the result of significant wet weather inflow to
the plant.
7.4.3 Officers are working to vary the consent conditions to allow
increased discharge limits
in response to conditions outside
of NRSBUs control (eg extreme or extended rainfall etc).
7.4.4
Dependent on the results of NCC and TDCs future
flow modelling works NRSBU
may be required to seek an additional consent variation to increase the average
daily limit for discharge
8
Proposed wastewater environmental performance standards
8.1 Taumata Arowai has published information on proposed wastewater
environmental performance standards that have been out for consultation.
8.2 In consultation with the NRSBU Chair, NRSBU submitted technical
responses on the consultation across many of the areas covered - including discharge
to water, discharge
to land, overflow
and bypass, and biosolids land application.
8.3 The submission to Taumata Arowai
is appended for reference.
8.4 Of particular note the feedback provided on the proposed discharge
to water standards outlined
that the changes
may have significant financial consequences to the NRSBU if the standards do not
allow a method for consent application based on adverse effects
8.5 If the outcome
of the standards does not allow NRSBU to have a discharge standard different to the
proposed performance standard for discharge to estuaries (i.e. less stringent)
then NRSBU will need to either change its discharge point or will need to
significantly upgrade the Bell Island wastewater treatment plant. Both these
options will have significant upgrade costs.
8.6 NRSBU will consider whether it would be appropriate to liaise with
both NCC and TDC to consider the effects of the proposed standards on each, and
to consider whether there are options available that would be more effective and cost efficient, should the proposed
wastewater environmental
performance standards be implemented without changes.
9.4 The net income
for the six months ending
31st March 2025 is $1,095,537 behind budget.
9.2 Income:
9.2.1
Fixed recoveries year to date under budget by $867,688.
9.2.2
The variable income
year to date is under
budget by $414,928.
9.2.3
Other recoveries
year to date income is under budget
by $71,542.
9.3
Expenditure:
9.3.1 Total Operating and Maintenance expenses
are over budget
by 0.5% ($24,111).
9.3.2 Maintenance costs are slightly above budget due to a range of
activities including heavy maintenance activities and purchase of pond emergency response chemicals
during the first quarter.
9.3.3 The trend for the contract maintenance and the reactive and
proactive maintenance worsened
slightly during the third quarter and is now tracking slightly over
budget.
9.3.4 Financial and depreciation expenses are below
budget by $258,435 due to lower than budgeted
interest rates.
9.4.1 The financial
trend year to date is for income
to be low. Flows and loadings increased during the second
quarter to closer to normal levels, which has improved variable
income, with the year-to-date
variable income deficit reducing from $450,000 to $414,000.
9.4.2 The
ongoing trend for the finances is for a lower than budgeted revenue, particularly the fixed revenue.
This will lead to a reduced
surplus at year end for the owners.
9.4.3 The fixed
revenue trend is not able to be changed by NRSBU
management, and it is expected that the financial trend will continue for the
rest of the financial year.
9.4.4 As
discussed in each quarterly report, the under-recovery on fixed revenue results
from changes to interest rates used in the charging
model versus the budget and the timing of setting these interest rates. The
budget process used means there is a considerable time difference during
which changes to interest rates can occur.
10 Conclusion
10.2 The NRSBU is operating well, with Operations and Health and Safety being managed to an appropriate level.
10.3 Business Unit operation is satisfactory except that the income is
lower than budgeted. This is leading to a shortfall in revenue. The variable
income improved during
the third quarter,
but the year-to-date revenue
remains lower than the budget due to low loadings received during the first
quarter.
10.4 It is likely based on the current trends that the NRSBU customers
should expect the end of year variable charge
reconciliation to include
a payment to make up for the
shortfall in variable revenue.
10.5 The result of the fixed
revenue shortfall is a lower-than-expected surplus. This trend was identified in the first quarter,
continued in subsequent quarters and will continue for the remainder of the
financial year.
10.6 NRSBU operational costs
are within 0.5% of the budget and therefore it is
clear that cost controls are working effectively.
10.7 Currently limited operational budget reductions are available to mitigate
the lower revenue.
10.8 For the scheme owners the lower variable revenue means that they as
customers have been making savings,
and this will partly compensate for the lower annual surplus projected.
Attachments
1. TA Wastewater Standards - Feedback - NRSBU
24 April
2025
Civic House, 110 Trafalgar Street PO Box 645, Nelson
7040, New Zealand
P (03) 546 0200
E nrsbu@ncc.govt.nz
NRSBU.govt.nz
Feedback to Taumata
Arowai on proposed
wastewater standards Introduction
Nelson Regional
Sewerage Business Unit (NRSBU) is a joint committee of the Nelson
City and Tasman District
Councils that has been set up to manage the Nelson Regional Sewerage System
(NRSS) infrastructure on behalf of the owners Nelson City and Tasman District
Councils. The ownership of the NRSBU is shared 50% by both NCC and TDC
The NRSBU has been delegated
responsibility for decision
making on behalf
of the owners of the facility
(NCC and TDC) and acts in a semi-independent manner to provide regional
wastewater services.
The NRSBU treats wastewater from a population of around 50,000 people, while the treatment facility has a population
equivalent of around 130,000.
The NRSBU supplies
services to its users under
trade waste agreements, and these users include the Nelson City and Tasman
District Councils.
The NRSBU receives wastewater from three domestic catchments,
through 24 km of rising mains including five major pumpstations, and one septage
reception facility, and treats this wastewater through the Bell Island
WWTP. Biosolids from the WWTP are disposed of beneficially to Moturoa/Rabbit
Island as fertiliser for the pine plantations there.
NRSBU
is in general support of the intended outcomes of the proposed Wastewater
Performance Standards and agree it is an important opportunity to support the development of nationally consistent baseline standards
and design solutions
for Wastewater Treatment
Plants, however as currently written the standards will result in a
minor decrease in consenting costs for NRSBU but will also result in
significant (tens of millions of
dollars) increase in costs to upgrade the well performing Bell Island WWTP to
comply with standards. These significant costs would all be borne by rate
payers and local businesses.
This
feedback is specifically provided by the NRSBU on the effects of the proposed
standards on its operations (i.e. the Nelson Regional Sewerage Scheme only),
not any of the networks operated by Nelson
City Council or Tasman District
Council. The feedback provided here should be read
in conjunction with the feedback separately provided by Nelson City Council and
Tasman District Council.
In no circumstances should this feedback be considered a response by either Council in their capacity as a
Regulatory Authority.
NRSBUs
Goals and Aspirations
NRSBU acts to provide
a service for its community
with the following mission statement:
Resilient, reliable, and effective infrastructure that supports and protects our community and environment.
|
Area
|
Goal
|
|
Our approach
|
Implement and
operate infrastructure considering the needs of our
community. Our priorities for this are protection of public health, the
environment, and cultural values.
|
|
Our
Vision/Ambition/Aspiration
|
We will
work towards the beneficial reuse
of resources.
|
|
Our conduct
|
We will
undertake our activities transparently, fairly, respectfully, in a timely manner and we will provide regional
infrastructure leadership.
|
As part of this Mission NRSBU
has actively promoted
the development of the draft Regional
Wastewater Philosophy project
which helped build
understanding of a Te ao Māori perspective and articulated shared
objectives and outcomes for the management of wastewater with Tasman District
Council and the Eight Te Tauihu Iwi. NRSBU invited
other stakeholders to join
in this process.
In addition to the Regional
Wastewater Philosophy, NRSBU has also developed
a Draft 50 Year Master Plan
specifically for its services using an adaptive pathway process.
As part of the above processes
NRSBU has actively worked to adopt additional discharge to land,
and wastewater reuse options, with a goal of reducing
wastewater discharge to water.
NRSBU is concerned the direction of the wastewater performance standards will undermine the significant shared progress made
between Te Tauihu iwi, and NRSBU.
Feedback
NRSBU provide
the following feedback
on the proposed wastewater standards:
·
Responses to selected
consultation questions posed
in the Discussion Document
·
Other comments.
GENERAL
Do you agree with the areas the first
set of standards are proposed
to cover?
Our understanding is that the proposed national
standards are intended
to reduce the costs associated with Resource Consents for wastewater treatment plants.
While NRSBU
believes that this would be a good outcome, our opinion based on a review of the
consultation documentation and technical reports is that this will not be
achieved with the proposed standards and would need the national
standards to encompass all consents required for a facility.
The consequence of the national
standards as they are proposed
is not expected to reduce
consenting costs significantly, but will result in significantly larger costs
for upgrading facilities and will result in significant additional costs for
operating and maintaining these more complex facilities.
Our initial
assessment when considered against the future of our Bell Island wastewater treatment plant are:
• That the proposed systems
and national standard will not mitigate many of the issues associated with wastewater treatment consenting process (cultural
concerns associated with
discharge to water, and land use, sea level rise and odour, and therefore will
not significantly reduce the cost of consenting the wastewater facility.
• That the proposed systems and national
standard will require significant (tens of millions) of dollars of upgrading
costs to meet the required standard associated with estuarine discharge. This seems counterproductive when scientific evidence
shows that the current
outgoing tidal discharge method has resulted in no significant adverse
environmental effects
over the 40 years the Bell Island wastewater treatment plant has been operating.
• That the current national
standards proposed will encourage Territorial Authorities to prioritise the development of High Dilution
Ocean discharges as these
will likely have low
ongoing operational costs.
•
That the proposed systems
and national standard
will significantly increase
the cost
associated with the operation of a much more technically complex wastewater treatment
plant required to meet the estuarine discharge standard.
Significant gaps exist between
the discharge consent
covered by the national standards and the range of additional
consents needed for operation of wastewater infrastructure, which could result
in TAs imposing reduced consent terms for infrastructure outside of the
proposed national standards. This could in some circumstances result in ‘stranded
assets’ –
e.g. a WW treatment plant that has no consents
for the outfall or incoming
pipework located in marine areas.
What areas should
we prioritise to introduce wastewater standards in future?
•
Wastewater standards around use of recycled water (e.g. highly
treated wastewater)
would provide
pathways for re-use opportunities such as use on sports fields, within new or existing subdivisions etc. Clarifying requirements to enable wider
re-use opportunities should
also be considered (e.g. on-site reuse at WWTPs, dust-suppression, re-use by a
third party)
•
Some method
for regulating what is an acceptable peaking
factor on wastewater
networks, and a
method for ensuring that TAs are improving their performance against this. This may be intended
to be captured within proposed
Wastewater Risk Management Plans, however, at present
this is unclear.
•
NRSBU
provides services for the community, our discharge is covered by
Consents, however the networks
we receive wastewater from are not governed by NRSBU and NRSBU has to respond to excessive
peaking factors associated with Inflow and
Infiltration. At present
there appears to be no mechanism in the national
standards that requires TAs to achieve a particular
standard with the Network (e.g. a peaking factor
of six time ADWF)
•
Managing this issue
would substantively change the number and size of network overflows to the environment, reduce the adverse
effects from WWTP discharges
including the number and size of bypasses, and would significantly reduce the cost for physical infrastructure development.
• Occupation of coastal marine areas (e.g. pipes, discharge
diffusers etc) – this is outside of current standards so
theoretically could have a resource consent issued with a term that does not
match the discharge to water consent.
What topics should we cover in the guidance material
to support implementation of the standards?
Clarity of the procedure associated with consent for an existing
WWTP (e.g. once a party obtains a new consent
under the standards, does that party have a certain timeframe to carry out any required upgrades to be able
to meet the standards)?
Currently the
normal RC practice is to allow for a period of time for upgrades etc to be implemented following the issue of the consent.
This allows infrastructure owners to design and implement treatment upgrades to
meet the consent standards once these are known. Whilst the consent standards
would be set for some performance parameters there is currently no indication
if these must be complied with from the start of any new consents, or if a
transition period would be provided for to allow any upgrades or changes to be completed.
Further to the
above there are a number of parameters which sit outside of the proposed standards – NRSBU understands consent limits for these would
be set as part of the RC process as is currently completed. If compliance with
the new WW standards is required from day one, then there is a risk for
infrastructure owners and operators that significant expenditure may be incurred
to comply with the new WW standards through upgrades, only to have RC conditions for
non-standard parameters imposed through the RMA process that would require
changes to recently upgraded processes to ensure compliance – resulting
in significant additional expenditure. Consideration of these types of
scenarios, and guidance around how Consenting Authorities and infrastructure
owners can work through this interface is critical.
Page 3 of 10
How should factors
such as climate change, population growth, or consumer complaints be addressed when
considering a 35-year consent term?
As the WW
standards are set then compliance is required regardless of the impact of climate change or population growth.
In effect the asset
owners would have to either a)
incorporate the reasonably foreseeable increases in flow & load (through
climate change and/or
population growth) in their infrastructure design prior to implementation of
the resource consent, or b) develop
an adaptive management style plan to allow for process
upgrades and capacity increases throughout the life of the asset as demand
increases.
Either way the
provision of a 35 year term provides certainty for the asset owners to develop appropriate investment
plans to deliver on the requirements
of the standards, as well as certainty to allow reasonable asset life assumptions when considering the financial implications of depreciation
to ratepayers.
The exception to
this would be how the consent terms and standards manage changes within the definitions of plant size – e.g. if during
the term of a consent
a ‘small’ treatment plant was no longer considered
as such. Clear requirements need to be considered.
As asset owners need to consider
the location of assets in relation to climate change
(e.g. sea level rise, flood hazards, etc),
it would seem unlikely that inappropriate site selection would be a factor that
the standards would need to consider.
Due to the 35
year proposed length of consent, it is highly likely that the interface point between wastewater infrastructure and neighbours will continue to change as communities
grow and urban areas continue to expand. Standard conditions for other
discharges associated with wastewater treatment plants, (e.g. discharges to
air) would clearly set expectations for asset owners, as well as the
territorial authorities as urban expansion progresses.
DISCHARGE TO WATER
How should we consider
checks and balances
to protect against
situations where the degree of microbial contamination may
change throughout the duration of a consent.
All discharges
should have a mechanism included that require determination of whether harm is occurring or is likely
to occur to the environment and should also have a risk based assessment on the risk from the discharge to human
health. This could include monitoring for signs of adverse effect or risks and
could also involve Quantitative Microbial Risk Assessments being undertaken.
While QMRA is relatively expensive, if it is set up at the start of a consent
period, then it should be relatively cost effective to review the QMRA every
say 5 or 7 years to confirm if the QMRA is still valid or if it needs to be
updated (e.g. to reflect change in network, plant operation or receiving
environment) to confirm if the human health risk has not significantly changed.
It is important to focus on the fact that the
core function of wastewater treatment facilities is to treat wastewater to avoid public
health issues, and to avoid adverse effects on the environment. Having
sufficient data and a way of checking
these risks systematically with appropriate frequency ensure that the facility
achieves this function.
Are the areas for exceptions appropriate to manage the impacts of discharges and do you anticipate implementation
challenges?
• NRSBU currently interprets
that the treated wastewater discharge from the Bell Island facility would fall
in the ‘estuaries with dilution ratio >50’ receiving environment
category under the standard. However, NRSBU does not consider that the current
definition for the estuaries category considers
the specific situation undertaken at the Bell Island Wastewater
treatment facility. The Bell Island facility only discharges for a short
duration on the outgoing tide so
that the wastewater is flushed out
into Tasman Bay and does not
circulate inside the Waimea Estuary.
• NRSBU currently interprets the national standards proposed for discharges into estuaries to mean that the Bell
Island Wastewater treatment plant would need to have significant upgrades (tens
of millions of dollars in cost) to meet the estuarine discharge standard
despite NRSBU investigating the effects
and having scientific evidence that after 40
years of discharge that no
significant adverse effects have occurred.
•
On this basis it is highly
recommended that if a treated
wastewater discharge does not meet the relevant discharge standard (for
water or land), the asset owner apply for a resource
consent via the ‘conventional’ consenting pathway and that consent may be
granted (i.e. as proposed for exceptions). This
would allow for site specific treated wastewater discharge quality sufficient to ensure no more than minor adverse
effects occur to the environment, and that the risk to
human health is protected to an appropriate degree. i.e. (QMRA).
How should the exceptions be further defined
to ensure there are no unintended
consequences?
Scientific evidence
should be required
to demonstrate any ‘exceptions’ do not result
in more than minor effect. This is particularly relevant to existing
facilities that have been operating
effectively for many years.
Are the treatment limits, and monitoring and reporting requirements proportionate to the potential impacts of the different
discharge scenarios?
NRSBU considers
that the discharge scenarios are too generic. For example, the Bell Island WWTP (operated by NRSBU) has been discharging to the Waimea Estuary
since the 1980s. All monitoring has determined that the treatment plant
discharge does not have a detrimental effect on the environmental health of the
Estuary. The current discharge scenarios do not consider the different types of
estuaries, nor the discharge mechanism or timing of the WWTP discharge to the estuary.
In the case of Bell Island, the Waimea Estuary is extremely tidal, and almost
completely empties with every tidal cycle. The Bell Island WWTP discharges to
one of the main tidal channels of the Estuary for the first 3 hours of each
outgoing tide only. This results in the WWTP discharge being carried directly
out to Tasman Bay (where monitoring has also demonstrated no detrimental
environmental effects). The proposed discharge scenarios will require a
significant alteration to the WW treatment processes employed at the Bell
Island WWTP, at significant cost to local rate payers, with likely no
measurable benefit to the receiving environment – in fact the current
proposed standards would allow the WWTP to discharge continually, resulting in
effluent (even if significantly better treated) being carried back into the
wider Estuary on incoming tides, which NRSBU considers an inferior outcome for
the community and the environment.
What benefits and challenges do you anticipate in implementing the
proposed approach? Are there
particular matters that could be addressed through
guidance material?
See response to previous
question.
DISCHARGE TO LAND
Are the proposed parameters appropriate to manage
the impact of wastewater
discharges to land?
The parameters fail to recognise the use of deficit irrigation. The Bell Island
WWTP has been applying treated
wastewater seasonally to low lying land adjacent
to the plant for almost
20 years. The receiving environment is
well monitored, and no significant adverse effects have been found.
The NRSBU
recognises the importance of protecting the fresh and marine water bodies of the region and supports the stance of many parts of the community,
especially mana whenua, of preference of land disposal rather than disposal to
water. The land discharge parameters seem at present to exclude large areas of land that can (and do) safely
support land disposal when managed properly.
Given the limitations already
faced when determining suitable land for wastewater disposal, the
proposed factors considered in the site-specific assessment for potential
discharges to land – in particular depth to groundwater – will
result in significant additional treatment requirements plus development and
operational cost. The factors as they stand will discourage network
owners and operators from considering land discharge as an alternative or supplementary disposal
method to discharge to water.
Overall, NRSBU
supports in principle a risk-based approach to discharging treated wastewater to land, which considers varying ability of different
receiving environments to assimilate treated wastewater sustainably and effects
of discharges on underlying groundwater and connected
surface water. For ‘mix-and-match’ situations, it also supports assessments being carried out
for the period when discharge to land (and water) is
occurring. However,
it seeks that as part of developing the site-specific assessment
framework
(including the site capability categorization) for the adopted standard, the definitions for each factor and category are refined, with consideration given to a wider
range of site conditions (e.g. shallower groundwater depths and setbacks) and the standard recognizes the use of deficit irrigation.
NRBSU does not
support setting a blanket maximum hydraulic loading rate for treated wastewater discharge to land, rather
seeks that the maximum rate is set on a case-by-case
basis. See previous comment under Discharge to Water about using a
‘conventional’
consenting pathway
if the discharge to land standard cannot
be meet.
What benefits and challenges do you anticipate in implementing the proposed
approach? Are there other particular matters that could be addressed through guidance material?
See response
to previous question.
Are the monitoring and reporting requirements proportionate to the potential
impacts of the different discharge scenarios?
The requirement
to engage third party auditing of compliance will add additional costs. In the case of the Bell Island WWTP the disposal
to land activity has been undertaken for many
years, with compliance reported and monitored as per existing consents without
requirement for auditing.
NRSBU also seeks that monitoring and reporting requirements under the discharge to land standard reflect the scale of the wastewater scheme and consider
‘mix-and-match’ situations, where treated wastewater is discharged
to land sometimes otherwise is discharged to water.
BENEFICIAL REUSE OF BIOSOLIDS
What should
the permitted activity
standards include?
NRSBU does not
support the unrestricted discharge of A1 biosolids to land, specifically where such discharges would enable contaminants to enter surface
or groundwater directly or
where discharge would occur to areas of high ecological and biodiversity
values. The impact to areas of heritage, archaeological or Māori cultural
value should also be considered.
How should contaminants of emerging concern
in biosolids be addressed in the
short-term?
• NRBSU supports the standard
referring to international evidence for land contamination from parameters of emerging concern
(e.g. PFAS). This includes
looking at work in
USA to understand any adverse
effects and ensure it doesn’t happen in NZ.
•
Disposal/reuse needs
to avoid the ability of it leaching
to groundwater or getting into the
food chain.
•
Understanding what, if any, effective treatment options there are for contaminants of emerging concern such as PFAS is a current research area.
OVERFLOWS AND BYPASSES
Is the current definition of overflow fit-for-purpose, and if not, what changes
do you suggest?
The definition
of overflow fails to provide a required performance standard required to be achieved (or a system designed
to achieve) prior to overflow.
Under the current
definition a network
owner/operator could design their WW system to only convey flows seen through
an annual return rainfall event, with everything else overflowing. This seems to fail to meet
the intent of wastewater systems
in safely conveying, treating, and discharging wastewater in a manner that reduces risk
to public health.
As the definition stands
it does not encourage network
operators to target
and reduce inflow &
infiltration, simply to engineer overflow points.
It also removes
the ability for the community served by the wastewater systems to determine the level of service
they are willing
to pay for – i.e. what is important
to them.
Addition of either a maximum peaking
factor for networks, or minimum ARI, would provide a
required level of service.
Does the proposed
definition of bypasses
adequately cover these situations, and if
not, what changes do you suggest?
In line with feedback
provided for the ‘overflow’ definition the definition proposed
for bypass fails to incorporate a minimum required standard. In effect it
allows network owners/operators to undersize the WW treatment plant, by
designing plants to manage much smaller flows than may be received, either as
part of normal diurnal flows, or in response to increase flows due to rainfall.
Addition of a required
minimum WWTP design
treatment flow percentile would define a level of
service for network owners/operators to achieve, however this should take into
consideration of maximum network flows, as detailed in the response to
overflows.
What should be covered in guidance to support developing wastewater risk
management plans?
•
The Risk Management Plans
should not only deal with mitigating the risks associated with overflows, but also seek to reduce the likelihood of the
overflows occurring in the first
place. At present the proposal reads more along
the lines of an ‘ambulance at the bottom of the
cliff.’
Do you support
setting all wastewater network overflows as controlled activity?
• Yes, this is supported but
only if the conditions include the responsibility to quantify the number and scale of the overflows. The conditions should
also include the responsibility to mitigate harm from the overflow and
should have a responsibility to upgrade the network to either increase capacity
or reduce the inflow and infiltration if the network does not meet certain
performance requirements.
• Any controlled activity
should only be available for networks that are demonstrated to have appropriate
inflow and infiltration levels. For example, if a network has a peaking factor of six then the network
would be considered to have a reasonable peaking factor, and any overflows would
be related to unusual or emergency issue. Whereas if the network has a peaking
factor of more than six then the network is not a good network, and the network
owner should be obligated to have a plan to reduce the peaking factor back to
six.
•
Consideration should be given to charging
a fee for overflows, which are ringfenced within budgets for use in investigating
and resolving Inflow and Infiltration issues.
OTHER COMMENTS
·
As
noted earlier, NRSBU is concerned the direction of the wastewater performance
standards will undermine the significant shared progress made between Te Tauihu iwi and NRSBU. There are potential adverse
implications for existing relationships and potential conflict with Te Ao
Māori perspectives.
·
NRSBU
supports a compulsory 35-year term for all consents issued under the standards, including discharge permits for discharging treated
wastewater to land or
water, where those discharges comply with the wastewater performance standards.
This provides greater certain on investment.
·
NRBSU
seek clarity on activity status for discharges complying with the standards.
NRSBU support activities that comply with the standards having controlled
activity status. However, if controlled activity status is removed from new
resource management legislation as proposed by the Expert Advisory Group on
Resource Management Reform, would discharges complying
with the national
standards become restricted
discretionary instead?
·
NRSBU
seek clarity on activity status for discharges where the standards are not
applied (i.e. alternative consenting pathway;
still aligned with standards just do not use
the numeric limits)
·
NRSBU request
further clarity on aspects that regulators will have control
over (i.e. what they could
introduce alongside standards, e.g. volume controls)
·
NRSBU request
more detail on how any future changes
to standards would be fed in to discharge consents, and the process
for revising/reviewing the standards
at a national scale.
·
NRSBU seek clarity on proposed end-of-pipe wastewater monitoring. Continuous on-line monitoring is not available for all proposed parameters,
is not accredited, can be challenging to calibrate, and maintain to provide reliable
results, particularly for WWTPs
with a significant industrial load component. The alternative of fortnightly
24-hour composites referred to in the supporting technical information that
informed the discussion document is also not appropriate for all parameters.
NRSBU currently is required to conduct fortnightly compliance monitoring, with
analysis carried out using an accredited laboratory under the current consent
for Bell Island WWTP.
Please feel free to contact
us should you wish to discuss any of the feedback provided
here. Yours sincerely
Nathan
Clarke
General Manager
– Regional Services, on behalf of the Nelson
Regional Sewerage Business Unit
