28 March 2022
To:
Taumata Arowai
Level 2/10
Brandon Street
Wel ington Central
Wel ington
Subject:
Taumata Arowai Consultation
Submission from:
Ruapehu District Council
Private Bag 1001
TAUMARUNUI 3964
Point of Contact:
Warren Furner (Executive Manager Infrastructure, Executive Leadership
Team)
Email:
[email address]
Phone:
07 895 8188 ext 251
Sarah Matthews (Executive Manager and Strategy)
Email:
[email address]
Phone:
07 895 8188 ext 235
The Ruapehu District Council (RDC) thanks Taumata Arowai for the opportunity to submit
on this very important matter.
Council does not wish to speak in support of its submission.
Page 2
1.
ABOUT US
The Ruapehu District is a land-locked area covering 6,733km², with a usual resident
population of 12,309 (Statistics NZ, Census 2018). The population is projected to increase to
13,328 in the coming years. Ruapehu is one of New Zealand’s largest districts by land area,
however, has a relatively smal and dispersed population base with one of the lowest
population densities in the country (0.02 persons per hectare). The Ruapehu District is also
a growing tourist destination and enjoys a significant and steadily increasing number of
visitors each year.
Communities within the Ruapehu district rely on critical infrastructure and lifeline utilities such
as water, wastewater, telecommunication, gas, electricity, road, rail and solid waste
management. As the region continues to grow, the physical nature of many of the waterways,
structures and flood protection works has altered. This has led to a decline in the state of
physical health of the waterways in the region which also provide water for potable supply
(Horizons Regional Council, 2019). Ruapehu relies largely on surface water sources for
drinking water supply, stock watering, and irrigation.
2.
PROPOSED CHANGES – CONSULTATION
Ruapehu District Council (RDC) applauds Taumata Arowai for initiating the necessary work
to uplift the standard of water quality and management in New Zealand. We recognised that
these changes need to be made to protect the livelihoods of our community and environment,
however we have reservations about the financial cost these proposed changes wil have on
our district. As a smal rural district council with a low rating base, we have limited capacity
to comply with these new water standards.
Any imposed costs proposed by Taumata Arowai wil push us over our debt affordability limit.
At the time of writing this submission, the details of the Three Waters reform are stil largely
unknown and therefore, it is unclear whether the new Three Waters entity wil take on Council
water debts. RDC wishes to make it clear to Taumata Arowai that our ability to comply with
these new water standards is restricted by our finances and in-house capacity and we urge
Taumata Arowai to consider providing water service providers with viable options to assist
water service providers in meeting these standards.
Council asks that Taumata Arowai consider the Covid-19 effects on supply chain delays and
work force availability along with the continued legislation and standards in its compliance
assessments. It’s acknowledged that indications have been made by Taumata Arowai, these
are not legislation requirements with set standards providing certainty that the financial
commitment are against the best decision options.
TECHNICAL FEEDBACK
2.1
DRINK WATER STANDARDS
RDC recommends Taumata Arowai to provide water service providers around the country
with a ‘Best Practice Guide’ on the Laboratory Standard method for testing each new
Minimum/Maximum Al owable Value (MAV). This would provide us with clear outcomes to
target.
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Indicator parameters within the pesticide list for MAV are often used to assess it further
detailed sampling is required in other consents. Use of indicator parameters could free up
laboratory resources.
The MAV and raw water sampling appear as the main focus to assess source water quality
as appropriate for Drinking Water Supply. Eg Boron values can be high around Mt Ruapehu.
The source water is only Barrier 1, and the raw water source informs the treatment train
required to deliver potable drinking water. The MAV assessment after treatment is more
important to ensure that water delivered in the reticulation system is within health guidelines
to protect Human health when consumed.
Monitoring the treated water process is more important than continual y monitoring raw water
which varies with river flow, rainfal and catchment activities. Table 14 is dedicated to weekly
monitoring raw water but is not reflective of the water being consumed.
Raw water monitoring across al parameters and flows is an environmental function and
should be undertaken by Regional Council. It is a Regional Council function to inform on the
natural environmental health of the river and if it’s safe to swim or drink in a raw form. This
provides the raw water catchment characteristics which is published into LAWA National
Environmental Standards – Drinking Water. There appears to be a blurring of the Councils
functions when there is such intense raw water monitoring being required at Barrier 1.
Treatment operators should use this data and additional data relevant to the intake point to
help determine the treatment train requirements from the environment. That is where they
have control over the water quality characteristics being produced.
In attempting to align Nation Environmental Standards for Drinking Water there is the
potential that Regional Council may use MAV values as a test to grant abstraction consents.
This is not the intent of MAV values, which are indicators of the risk and treatment required.
Currently there is a high risk that surface waters will be seen as inappropriate water sources,
without considering that water from bores are tapping into “underground rivers”. Mountain
Ruapehu influences both surface and subsurface waters regardless of depth.
2.2
DRAFT DRINKING WATER QUALITY ASSURANCE RULES
Please note the bul et point numbers below references the bul et point numbers in the ‘DRAFT
Drinking Water Quality Assurance Rules’ document. The comments below speaks directly to each
point as seen in the original document.
4.4
‘Varying Population Size Drinking Water Supplies’
“Varying population” does not have a method to assess if the population has changed
greater than the base population for a period of more than one day. Monitoring a
population movement on a daily or weekly basis is not practical. A better trigger method
is required eg “where the average treated water volume of population consumption has
increased above a X % for a period greater than XX % excluding industrial and rural
water from the previous quarter, then the population wil move into the next category eg
> 500 people
Monitoring
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Ongoing weekly inspections between “October and May”, of an area around a surface water
take for the presence of benthic cyanobacterial mats and or planktonic cyanobacteria growth,
has no trigger value or methodology. During summer there wil always be some present as
they are part of the natural ecosystem. Tthe question is what risk does this pose to the health
of the people? There could be a simple visual table with photos and a matrix to provide an
assessment method. Cyanobacteria is natural y found in surface water bodies. It is the
volume that should trigger further investigation.
When the visual assessment triggers sampling by chemical analysis to assess the potential
risk. As set out in S1.4. Alternatively, the water take is not inspected weekly or within that
week, due to a variety of reasons including health and safety risks, then the raw water is
sampled at the plant and sent for chemical analysis during this week/period. Again, it is
important to achieve the outcome that the treatment process has removed the contaminate
to appropriate health guidelines.
E.coli and total coliforms in the water standards have not changed to al ow the flexibility
of adding presence absence testing as an option after treatment. Presence absence
testing is instant and can be used to provide some assurance for the human errors that
result in data loss e.g. courier failure, laboratory sample loss, etc. Presence/absence
testing where the supply is smal and resources are constrained could be used to
escalate resources for monitoring where risk is evident.
Total coliforms do not have any associated limits. Does Taumata Arowai see the
need to continue wil this testing in the legislation?.
9.
Community Drinking Water Stations/Water Carrier Supplies
The data storage of a minute of data and the use of excel spreadsheet limitation also
needs to be explored. SCADA storage and retrieval over time has some technical issues
as the data volume increases. What software is required to store this information is this
to be uniform across platforms? Note the biggest issue with data retrieval in time-based
systems is the loss of sequencing. SCADA systems are very flexible and general y built
and implemented to the level of management appropriate for the treatment system. A
known set standardised system to transition to over time is important if standardized
reporting is a goal across New Zealand, eg Daylight Saving Time or New Zealand
Standard time.
Continuous monitoring of parameters is one of the best methods of assessing if the plant
process is performing within parameters. Minute data col ection lossess due to
technology failure should be considered against other parameter measurements being
made at the time and the volume of water being effected to build the risk profile. For
example chlorination being achieved at the plant is designed to kil bacteria both within
the reservoir and the distribution network. So the loss of 1 minute data point on turbidity
is not resulting in a compromised treatment system.
Table 5 (T3) - the UV disinfection rules combined with the colour test are very restrictive
and non-compliances occur but the actual outcome is achieved. e.g., UVT
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transmittance/intensity method is a theoretical number which is not always met. The
colour is not visible to the human eye so it’s not for visual aesthetics. No E.coli has been
found in the National Park Water Supply which has colour exceedance so the test is not
indicative of the risk, that UV treatment is not being achieved, and E.coli is entering the
distribution line. RDC would like to see the test method changed to reflect the outcome
of No E.coli but al ow for natural occurring colour within the water column.
10.
Compliance Rule Modules
10.3
Treatment rules
The T1 rules relies on gravity flow ability into a tank – this wil not be possible in al
circumstances.
10.4
Distribution System Rules
With regards to the ‘A backflow prevention device where there is a high or moderate risk
of backflow’, the building code and the previous drinking water classification were not
aligned. This inconsistency in classification needs to be resolved to provide clarity to
Drinking Water Supply Planning.
10.10
D3.6-Backflow Protection Rules
‘Access to water network, where it is reasonable necessary to access the network
for the operation of the drinking water supply’. This statement excludes the
reticulation drinking water being used for other purposes other than fireflow or
other emergency via a standpipe. Eg washing of footpaths, hanging baskets etc.
are not permitted. Council infrastructure maintenance has been set around the
availability of reticulation water for other purposes such as hygiene of the streets
and wel being through beautification. Long-term goals may be to use alternative
options, but this wil take years. Planning for greenspace development does
provide for some of these opportunities moving forward.
10.10.2
Facilities Operation, Maintenance and Disinfection Rules
These regulations wil impose future costs on the management of our water
systems. Operational costs significantly affect community health and
wel being as affordability is one of the greatest struggles of smal
populations with high devevation indexes. There is stil no certaintain that
the debit wil be moved to a separate entity.
2.3
KEY CRITERIA FOR THE USE OF THE DRINKING WATER ACCEPTABLE SOLUTIONS
FOR ROOF WATER SUPPLIES
Council have had some difficulties with private supplies not wishing to join available networks
which provided a higher standard of treatment but not “perceived wholesome values”. Is
there guidance on how this compliance is resolved?
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The aesthetic values appear to be set below the treatment standards. This is particularly
prevalent for chlorine and wil drive unnecessary angst within the community. While the rules
state that this should not over-ride drinking water health its simpley an agument that Councils
do not need to debate if values are set in line with treatment values.
The definition of source water as rainwater appears inconsistent with NES-DW which
appears to exclude rainwater.
Clarification of the drinking water use criteria: “…share the same roof water source” could be
interpreted to mean a single roof. But the actual source is rainwater which may be captured
off multiple roofs into storage tanks before treatment. Increasing roof area capture wil be
important during dry climatic conditions. More clarity as to how to interprenate this rule may
be useful.
2.4
DISCUSSION DOCUMENT- DRINKING WATER NETWORK ENVIRONMENTAL
PERFORMANCE
How is the performance management of drinking water coverage quantified? (page 12)
Water New Zealand’s National Performance Review measures do not total y align with the
DIA KPI measures. Please note, DIA measures are also legislatively imposed on Councils.
Wil DIA measures be repealed when Taumata Arowai measurements commence or wil
Water Supplies be again moving down the tranch of reporting to different Government
Masters.
Fault attendance and resolution-Wil the criteria for fault attendance be changed or
maintained against the current criteria administered by DIA. Wil Taumata Arowai take over
the auditing of this criterial?
Drinking water treatment byproduct- currently we discharge backflow into a backflow pond
onsite. The sludge is pumped into the wastewater treatment system and the surface water
can be decanted to the receiving environment under resource consent. We would like to
know, is this stil an acceptable solution?
The concept that safe drinking water is available to al is contradictory when networks
operated by universities, hospitals and other large institutions are excluded on the basis that
they are not operated by a government department. These institutions have the same risk
of exposing a significant population. Water borne outbreaks have largely been linked to
private and educational institutions. Given Hospitals are first responders to any health
emergency it would be assumed that they would have the highest response requirements.
As education institutions feed the mind and body they should also be meeting drinking water
standards.
Asset Conditions-What criteria wil be used to assess asset conditions? If metadata is to
be made universal a significant lead in time wil be required.
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Water Pressure- At the present time, there is no requirement to provide a standard water
pressure to customers, if Taumata Arowai was to introduce a standard, RDC wil struggle
with meeting those standards because our water systems are gravity fed. What’s the new
criteria for water pressure, and what is it based on?
Efficient consumer use of water- This is difficult to quantify because we do not have a
metered network and we also provide farms with portable water for such activity as milking
sheds and stock drinking. Rural Water Supply tanks are fil ed overnight in our trickle feed
supplies and using night monitoring assessments to measure water loss do not provide
sensible data.
Alternate water use- Water is supplied to commercial, industrial and rural users, there are
no restrictions on how they use water or what the water should be used for. This is a change
that wil need to be managed and consideration needs to be given to the implementation of
the change against the economic climate.
Energy efficiency- what is Taumata Arowai basing this on, in terms of what they mean by
‘energy efficiency’, is there a standard in place or wil there be a standard in place
3.
CONCLUSION
To conclude, Council shares Taumata Arowai’s commitment to ensure al communities have access
to safe drinking water. However, our ability to meet these new water regulations is restricted by our
capacity and financial resources. We recommend that Taumata Arowai provide options that can
assist us in meeting these new water standards.
Council would also like to put forward the idea for Taumata Arowai to work alongside the Ministry of
Environment with regards to protecting drinking water sources to avoid confusion. Also to look at
the Key Performance Indicators set by DIA and the need for these measures.
