PNCC Submission – Taumata Arowai Rules – 2022-03-28
Palmerston North City Council submission on Taumata
Arowai Rules
28 March 2022
1
Introduction
Thank you for the opportunity to submit on the proposed rules for Taumata Arowai under the
fol owing areas:
1. Drinking Water Standards
2. Drinking Water Quality Assurance Rules
3. Drinking Water Aesthetic Values
4. Drinking Water Acceptable Solution for Roof Water Supplies
5. Drinking Water Acceptable Solution for Spring and Bore Drinking Water Supplies
6. Drinking Water Acceptable Solution for Rural Agricultural Water Supplies
7. Drinking Water Network Environmental Performance
Palmerston North City Council (PNCC) owns and operates urban water supplies for Palmerston
North, Ashhurst, Bunnythorpe and Longburn, providing water 24 hours a day, 7 days a week to
some 80,000 people. Water underpins everything we do, from the health of our communities to the
economic development of our city. The availability of safe, secure water supplies is critical to our
success and growth.
We’re committed to meeting the requirements for ful compliance against current and future
regulations. We have a strong track record with respect to compliance, having achieved ful
compliance with the Drinking Water Standards for the last two reporting years covered by
MidCentral District Health Board. We have a funded programme of works to deliver on future
improvements as part of our Long Term Plan, and our vision for the sustainable growth of our city.
Palmerston North water in particular has consistently performed wel , with high resident
satisfaction rates and an award for the best-tasting water in New Zealand in 2016. Our Turitea
Water Treatment Plant is accredited under ISO9001; an achievement in line with our vision of
“Smal City Benefits, Big City Ambition”.
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
We have a strong partnership with Rangitāne o Manawatū and are working towards embedding the
principles of Te Mana o te Wai into management of our water resources.
We are supportive of the work that Taumata Arowai is doing to raise the bar in drinking water
regulation across New Zealand. In recent years there have been several high profile incidents that
have reminded everyone how important it is that consumers can rely on their water being safe to
drink.
Detailed feedback on the most significant changes proposed is given in the fol owing pages.
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
2
Drinking Water Standards
2.1
Maximum Acceptable Values (MAVs)
Aluminium
Parameter
Current MAV
Proposed MAV
Aluminium
None
1 mg/L
PNCC doses aluminium (in the form of Poly Aluminium Chloride) at the Turitea Water Treatment
Plant for the Palmerston North water supply and actively monitors concentrations in the
distribution system.
We support the introduction of a MAV for aluminium.
We support that this MAV be set at the proposed level of 1.0 mg/L. Concentrations reported on the
Palmerston North network are wel below the MAV. We believe it is set at an appropriate level to
al ow potential impacts on public health to be addressed.
We request that the Drinking Water Standards specify the test to be used to determine compliance,
for example whether this measurement is dissolved aluminium or total. Leaving this key piece of
information out of the standards would lead to a lack of clarity.
We note the existing GV1 for aluminium is 0.1 mg/L for aesthetic reasons and that this is proposed
to be retained.
Nitrite, Long-Term
Parameter
Current MAV
Proposed MAV
Nitrite, long-term
0.2 mg/L
None
Nitrite, short-term
3.0 mg/L
3.0 mg/L
We support the temporary removal of a long-term MAV for nitrite given the uncertainty of
information and the advice from the WHO2.
We request that Taumata Arowai give urgency to reviewing short-term and long-term limits for
nitrites and nitrates.
1 Guideline Value
2 World Health Organisation
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
Perchlorate
Parameter
Current MAV
Proposed MAV
Perchlorate
None
0.08 mg/L
We oppose the introduction of a MAV for perchlorate on the basis of advice we’ve received from
our laboratory services contractor that there are no available laboratories currently testing for
perchlorate in water (only in dairy products). Further, the advice we received is that because these
are unstable compounds, laboratories may be disinclined or unable to achieve accreditation to test
for them. We see no benefit in having tests completed that are not accredited.
We are conscious of the need to test for disinfection byproducts, and are general y supportive of
moves by Taumata Arowai to increase surveil ance in this area. However, we do not feel that it is
practical to introduce a requirement that we cannot meet through lack of ability to assess
compliance.
Further to the above, we are informed that testing for chlorate in water is available at Eurofins or
WaterCare. Our current laboratory services contractor is CEL (Central Environmental Laboratories),
based in Palmerston North. They won this contract in a competitive process which included a local
supplier premium. As wel as the economic benefit of having these services available local y, there is
a practical benefit as wel . Reduced travel time for samples between col ection and analysis reduces
the chance of false readings or samples arriving out of specification and unable to be tested.
PFHxS + PFOS, PFOA
Parameter
Current MAV
Proposed MAV
PFHxS + PFOS
None
0.00007 mg/L
PFOA
None
0.00056 mg/L
We request more information on the proposed MAVs for these compounds:
We note that there is no WHO GV to support either of the proposed MAVs, and that they have been
adopted from the Australian Drinking Water Guidelines. We request more information on their
applicability in the New Zealand context.
We would like to know what, if any, treatment options there may be if these compounds were to be
found in any of our water supply bores.
We would like clarification on the implications of non-compliance with the proposed MAVs.
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
1080
Parameter
Current MAV
Proposed MAV
1080 (long-term)
0.0035 mg/L
0.0035 mg/L
1080 (short-term)
None
0.0035 mg/L
We support the introduction of a short-term MAV for 1080 to strengthen provisions for protecting
water supply catchments.
We control pests and predators in our Turitea Reserve water supply catchment using a pest control
contractor, Daniel Ritchie Contracting. We do not use, and have never used, 1080 for this. The
topography of and access to our catchment is such that bait stations can be placed manual y.
Brodifacoum is the poison used. Tararua Forest Park is located to the south of the Turitea Reserve,
but is distant from the water supply catchment. Although the Department of Conservation carry out
drops of 1080 further south in the park, this is far enough away from our environs that there is no
risk of contamination.
Most of the Turitea water supply catchment is indigenous forest in Council ownership. There is no
known use of 1080 on land within or adjacent to the catchment. Horizons Regional Council carries
out pest control activities on land outside our catchment, but Brodifacoum and cyanide are the only
poisons used, and as the land is outside the water supply catchment there is no risk of
contamination.
We are aware that Health Protection Officers have responsibility for approving the use of verotoxins
such as 1080, control ing and monitoring their use closely.
We believe that the best way to ensure there continues to be no risk of 1080 contamination in our
catchment is to actively prevent its use. We accept, however, that testing to confirm its absence
could be considered good practice, and would provide further reassurance to consumers.
Radiological Determinands
Parameter
Current MAV
Proposed MAV
Total alpha activity
0.1 Bq/L (excluding radon)
0.5 Bq/L (excluding radon)
Total beta activity
0.5 Bq/L (excluding 40K)
1.0 Bq/L (excluding 40K)
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
We support the raising of these MAVs to bring them in line with the revised WHO3 GVs. We
currently test for alpha and beta activity, as required under the Drinking Water Standards, and al
recent results have been below the detection limit. We do not believe there is a risk of radioactive
compounds in our water supplies, or that raising this MAV would negatively impact public health.
3 World Health Organisation
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
3
Drinking Water Quality Assurance Rules
Water Supply Categories
We support the revised distinction between supply sizes as per the fol owing table. We understand
the approach that Taumata Arowai has taken in reducing the upper bounds for a large supply.
Public health is of prime importance, and it shouldn’t matter whether the population served is
80,000 or 1 mil ion.
Water Supply Size
Population Connected
Large
> 500
Small
50 – 500
Very Smal
< 50
Varying Population
Base and Peak e.g. summer homes
The current official populations of PNCC supplies are as fol ows:
Water Supply Size
Water Supply
Official Population Connected
(as proposed above)
Palmerston North
72,284
Large
Ashhurst
2,800
Large
Bunnythorpe
493
Smal 4
Longburn
350
Smal 5
Structure of the Rules
We support the rules being structured as modules for:
Source Water
S
4 Quite possible this has increased, or wil increase, above the threshold of 500 to become a Large supply.
5 May have increased above the threshold of 500 to become a Large supply. Likely to reach this in future.
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Treatment Systems
T
Distribution Systems
D
General
G
Water Carriers
WC
Planned Temporary Event
PTE
We support the rules being divided into separate modules according to complexity:
Simple
1
Moderate
2
Complex
3
We note that smal supplies must demonstrate compliance against Moderate rules, and large
supplies must demonstrate compliance against Complex rules.
We support suppliers being able to opt for a higher complexity of rules to demonstrate compliance
at a more detailed level. We have two supplies that would be categorised as Smal with their
current official populations but may find it clearer and easier to demonstrate compliance against
Complex rules for al four of our supplies, particularly in the case of network operations.
Compliance and Reporting
We support the introduction of Assurance Rules that require water supplies to demonstrate
compliance annual y, for example by providing a distribution zone sampling plan (which is produced
annual y by our laboratory services contractor and checked internal y before implementation).
Source Water – Sanitary Bore Heads
Item
Current
Proposed
Prevention of surface water Secure Bore Status as a
Class 1-4 and sanitary bore head
intrusion into bore
mechanism to demonstrate
requirements
headworks
protection from protozoa
We support the ability to demonstrate that a bore head is sanitary and can be considered Class 1
under S3 (Complex Source) rules in order to remove the need for protozoa treatment. Our bores
have secure bore status under the current rules. We have a programme of work underway to
ensure that this is maintained.
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
Source Water - Monitoring
Item
Proposed
Bromide
Monthly sampling
TOC6
Monthly sampling
Conductivity
Continuous sampling
pH
Continuous sampling
Turbidity
Continuous sampling
We support in principle the requirement for monthly sampling of bromide and Total Organic
Carbon in source waters to better understand the risks, at least for the first year to gather
information before reducing sampling requirements where appropriate dependent on risk. We
calculate that the additional cost for this would be:
200 hours of staff time/year
$6,500 of analysis costs/year
We support the requirement for continuous sampling of conductivity, pH and turbidity in source
waters. The fol owing table shows which we already measure using online instrumentation at 1-
minute intervals, with data saved in our telemetry database:
Source
Turbidity
pH
Conductivity
Turitea Dam
Yes
Yes
No
Ashhurst Bore
Yes7
Yes8
No
Bunnythorpe Bore
Yes
Yes
No
Keith St Bore 1
No
No
No
6 Total Organic Carbon
7 After reservoir at filter station.
8 Recorded on Depolox at site; not currently trended on SCADA but can be added.
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Source
Turbidity
pH
Conductivity
Keith St Bore 2
No
No
No
Longburn Bore
Yes
Yes
No
Papa-i-oea Park Bore 1
No
No
Papa-i-oea Park Bore 2
Yes9
No
No
Papa-i-oea Park Bore 3
No
No
Roberts Line Bore 1
No
No
No
Roberts Line Bore 2
No
No
No
Takaro Bore
No
No
No
It could cost up to $20,000 to instal continuous monitoring at sources where this is currently not a
requirement. The total capital investment for this additional monitoring could be $200,000. To ful y
scope and cost improvements would take time and cost in itself. Added to this is the financial and
delivery risk associated with procuring equipment and resources in the current environment.
COVID-19, growth and investment in our sector, and high demands on a smal number of suppliers
is causing large, unpredictable cost fluctuations.
Source Water - Classification
Item
Current
Proposed
Source waters for Level 3
Risk assessed and treatment
Source waters categorised into
(complex) supplies
requirements determined
four categories to determine
through Catchment Risk
level of protozoa treatment
Assessments (CRAs)
required
We support the categorisation of source waters into four categories to determine protozoa
treatment requirements. This is similar to the current practice of assessing catchments with the
Catchment Risk Assessment process, under which they were assigned requirements for log credits
(normal y 3 or 4 depending on the catchment).
9 Combined for al bores (prior to UV)
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Treatment – Monitoring
Item
Proposed
FACE
Continuous monitoring
T10 contact time
Continuous monitoring
C.t value
Continuous monitoring
We support the requirement for continuous monitoring of FACE (where there is not an exemption
to use monochloramine as disinfectant residual). This is already in place at the Turitea Water
Treatment Plant on our Palmerston North supply.
We support the requirements to monitor contact time and C.t value continuously but would like
clarification on whether this applies to treatment plants discharging directly into the reticulation
without storage (as is the case for our Palmerston North bores).
Treatment – Protozoal Compliance
We support the ability to achieve 4 log credits under Coagulation, Flocculation, Sedimentation and
Filtration Rules. The Turitea Water Treatment Plant on our Palmerston North water supply currently
achieves 4 log credits, with 0.5 log credits coming from enhanced filtration. Restructuring the rules
to make them simpler makes sense in this context, and this simplification won’t require any changes
to what we are currently doing.
Treatment – Chemical Compliance
Item
Current
Proposed
Additional monitoring
Priority classes assigned e.g. P2 Typical Value method
We support the use of the Typical Value method to assess whether additional chemical
determinands must be monitored regularly.
Treatment – Disinfection By-products
Item
Proposed
Chlorate, Perchlorate
Weekly if sodium hypochlorite used
monitoring
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
We support the requirement to monitor chlorate weekly if sodium hypochlorite is used.
We oppose the introduction of a MAV for perchlorate on the basis of advice we’ve received from
our laboratory services contractor that there are no available laboratories currently testing for
perchlorate in water (only in dairy products). Further, the advice we received is that because these
are unstable compounds, laboratories may be disinclined or unable to achieve accreditation to test
for them. We see no benefit in having tests completed that are not accredited.
We are conscious of the need to test for disinfection byproducts, and are general y supportive of
moves by Taumata Arowai to increase surveil ance in this area. However, we do not feel that it is
practical to introduce a requirement that we cannot meet through lack of ability to assess
compliance.
Further to the above, we are informed that testing for chlorate in water is available at Eurofins or
WaterCare. Our current laboratory services contractor is CEL (Central Environmental Laboratories),
based in Palmerston North. They won this contract in a competitive process which included a local
supplier premium. As wel as the economic benefit of having these services available local y, there is
a practical benefit as wel . Reduced travel time for samples between col ection and analysis reduces
the chance of false readings or samples arriving out of specification and unable to be tested.
Distribution – Residual Disinfection
We support residual disinfection becoming mandatory for al supplies, to ensure that water remains
safe for consumers even after it has been through the distribution system, and to provide a barrier
against contamination in the network. We currently have residual disinfection on al our supplies,
for these reasons.
We propose that the use of monochloramines as residual disinfectant be included in the Drinking
Water Quality Assurance Rules. Currently, monochloramines are used as residual disinfectant at our
Palmerston North bore stations with permission granted previously by the Drinking Water Assessor.
This practice has been adopted because our current water supply bores discharge directly into the
network, without contact time available to achieve breakpoint chlorination and use Free Available
Chlorine (FAC). PNCC is working towards achieving break-point chlorination in al zones. This would
require sufficient contact time to be available at each bore, with the provision of large aboveground
contact tanks or reservoirs. Given the urban nature of the environment around our Palmerston
North bores, it could take some five years to scope solutions, negotiate with landowners if
necessary, work through a legal process and complete construction. At some locations this may
prove practical y impossible. The ability to use monochloramines ensures we remain compliant. We
understand that there are other locations around the country in a similar position, with sources
discharging directly into the network. See Section 2.1.3 for further feedback.
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Distribution - Backflow Protection
Item
Proposed
Backflow prevention
Prepare and provide annual y
programme
Backflow survey
Assess premises at least 5-yearly; report annual y
Testing of backflow
Annual y
prevention devices
Register of testable
Keep and provide annual y
backflow prevention
devices
Access to network
Restrict access of the network via standpipe to FENZ, other
emergency services, the water supplier or authorised contractors
We support the above requirements for demonstrating management of the risk of backflow on
distribution systems. We have an active backflow protection programme that already addresses
most of the above concerns and are in the process of making further improvements.
We support there being a national y consistent rule to protect water supplies against the risk of
contamination through unsafe practices accessing hydrants or other parts of the network. Access to
our networks is now strictly control ed. Contractors are rarely given access, and in such cases must
use standpipes with testable backflow prevention. We control this through our Water Supply Bylaw
and communicate with existing or new contractors wishing to access our networks. Enquiries
normal y come to the Service Manager – Water, our Development team or our Network Operations
team.
Facilities Operation, Maintenance and Disinfection (Storage Reservoirs)
Item
Proposed
Water Storage
Water suppliers with storage facilities within distribution system
Management Plan
must prepare a Water Storage Management Plan
Reservoir inspections
Requirement to inspect annual y
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
Item
Proposed
Disinfection procedures
Water Suppliers must prepare and use written disinfection
procedures for storage facilities consistent with best practice
Disinfection
New storage facilities and existing ones drained for maintenance
must be cleaned and disinfected prior to use
Foreign materials
Materials used during inspection, maintenance or other activities
(including divers’ suits, ROVs10) must be made from materials
acceptable for contact with potable water and suitable for
disinfection
Testing
After ful or partial draining of storage facilities, they must be
refil ed with potable water and tested for E. coli, total coliforms
and residual disinfectant
We support the above measures becoming compliance requirements. This represents good
practice, and almost al measures are already being fol owed.
Distribution - Water Main Hygiene Procedures
We support the proposed requirements for hygiene on new and repaired water mains. We strive to
fol ow best practice to protect our networks. We have existing flushing and disinfection procedures
that cover our network in general, as wel as specific plans that are in existence or created at the
time for major operations. These are normal y communicated to external parties through our
Development team, our Network Operations team, or our Project Management Office. Only internal
staff or Approved Contractors are permitted to work on our water supply networks. On 10 January
2022 our new Infrastructure Unit structure took effect. One of the prime reasons for this
restructure was to move al 3 Waters staff into a standalone group, refining team structures and
clarifying reporting lines. Positions have been created in our Network Operations team for a Quality
Manager (already appointed) and a Compliance Testing Officer. This wil strengthen our ability to
properly document our processes, make improvements where necessary and clearly communicate
our requirements to external contractors.
10 Remotely Operated Vehicles
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Distribution – Residual Disinfection, DBPs and Plumbosolvency
We support the proposed Assurance Rules for disinfection by-products (DBPs). We believe that
increased surveil ance of disinfection by-products wil help to ensure there are no deleterious
effects on health. We calculate that the additional cost for this would be:
200 hours of staff time/year
$38,000 of analysis costs/year
We support the proposed Assurance Rules for plumbosolvent metals (such as lead). The events in
Otago raised the levels of concern in the industry and community about lead in particular; increased
surveil ance in the network wil help al eviate this. We calculate that the additional cost for this
would be:
40 hours of staff time/year
$2,000 of analysis costs/year
Distribution – Sampling Frequency for FAC, pH, DBPs and Plumbosolvent Metals
We support the increased monitoring frequencies proposed for FAC and pH on distribution systems,
and where necessary wil instal additional continuous monitoring on our networks. Currently,
continuous monitoring is only carried out on water leaving treatment plants. Residual disinfectant
and pH are sampled on distribution systems when bacteriological samples are taken, rather than on
a continuous.
We support the increased monitoring frequencies proposed for Disinfection By-Products (DBPs) and
plumbosolvent metals over an initial 12-month period to assess the extent of any issues. We
propose that fol owing this, requirements should be reviewed and where appropriate amended
based on the level of risk. Currently, there is no requirement to monitor either of these groups of
compounds on distribution systems. We regularly sample our sources for plumbosolvent metals. In
the past we have sample for disinfection byproducts at some locations, but this was discontinued
fol owing confirmation that there was no issue.
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4
Drinking Water Aesthetic Values
Chlorine
Parameter
Current GV
Proposed Aesthetic Value
Chlorine
0.6 to 1.0 mg/L
0.3 to 0.6 mg/L (as Cl2)
We support the lowering of the low end of the acceptable range for FAC (Free Available Chlorine)
for aesthetic reasons from 0.6 to 0.3 mg/L.
We oppose the lowering of the high end of the acceptable range for FAC from 1.0 mg/L to 0.6 mg/L.
Precise control of FAC at al points in the network is difficult to achieve in practice. We believe it is
more important to ensure that the FAC is above the minimum of 0.2 mg/L at al times to protect
public health. If the maximum aesthetic value is lowered to 0.6 mg/L, water leaving the treatment
plant would need to have a lower chlorine concentration, giving less assurance of maintaining
residual disinfection for al consumers at al times.
We support the requirement for disinfectant residual to be Free Available Chlorine (FAC), given that
we can apply for an exemption to use monochloramines as disinfectant residual for our Palmerston
North water supply bores at least as an interim measure.
Iron
Parameter
Current GV
Proposed Aesthetic Value
Iron
0.2 mg/L
≤ 0.3 mg/L
We support the raising of this value from 0.2 to 0.3 mg/L.
We support the use of “≤” (here and elsewhere) to make it clear that this is a maximum.
Temperature
Parameter
Current GV
Proposed Aesthetic Value
Temperature
Should be acceptable to most
Preferably not more than 15oC
consumers, preferably cool
We support the introduction of a temperature value to make this measure less subjective.
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We propose the word “preferably” be removed as this makes it difficult to assess objectively. It
would be easier for water suppliers to understand their obligations if there was one value, even if it
was raised, or if a mean, median or percentile measure was used.
We request more information on where this is proposed to be measured, and what the acceptable
procedure for doing so may be.
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5
Drinking Water Acceptable Solution for Roof Water
Supplies
Currently, our Parks & Reserves Group manage one system for col ection of roof water, at Arapuke
Forest Park. This is not provided for potable use, so there is no immediate need to make use of this
Acceptable Solution.
We request more information on what level of consultation there has been with the Department of
Conservation, Te Araroa Trust and other organisations that may be providing drinking water in
remote locations.
6
Drinking Water Acceptable Solution for Spring and
Bore Drinking Water Supplies
We wil demonstrate compliance for its water supplies against the relevant Drinking Water
Standards, Quality Assurance Rules, Aesthetic Values and Network Environmental Performance
criteria rather than using the alternative of an Acceptable Solution. For this reason, we are not
submitting on this proposal.
7
Drinking Water Acceptable Solution for Rural
Agricultural Water Supplies
We do not own or operate any water supplies that would come under the definition of Rural
Agricultural. For this reason, we are not submitting on this proposal.
8
Drinking Water Network Environmental
Performance
Overal
We support the proposed environmental performance measures. Protection of te taiao (the
environment) for our communities is of prime importance to us. Data for many of the measures are
already col ected and reported on. In partnership with mana whenua, we are building the principles
of Te Mana o te Wai into what we do as providers of 3 Waters services.
We note that some of the proposed measures are already reported on, in the same or near form, to
other organisations (for example the DIA11 or Water NZ12). We propose that in such cases, rather
than duplication of work effort, reporting is to only one authority. This would reduce the time and
11 Department of Internal Affairs
12 Water New Zealand
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PNCC Submission – Taumata Arowai Rules – 2022-03-28
cost involved in gathering and providing information at our end, and for the information to be
analysed and reported on by the various regulators or interested parties.
We support the staged approach being taken, with three tranches of measures to be introduced, so
that any additional resource requirements in terms of time and cost are effectively managed.
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9
Conclusion
Thank you again for the opportunity to provide feedback on this major step forward for drinking
water quality in New Zealand. We are passionate about providing high quality, safe drinking water
to our communities. This is shown in our daily commitment to continuous improvement, as wel as
our achievement of ful compliance with the Drinking Water Standards for the last two reporting
years covered by MidCentral District Health Board. Palmerston North water in particular has
consistently performed wel , with high resident satisfaction rates and an award for the best-tasting
water in New Zealand in 2016. Our Turitea Water Treatment Plant is accredited under ISO9001; an
achievement in line with our vision of “Smal City Benefits, Big City Ambition”.
We are wel placed to continue to be ful y compliant. We realise that the new regulations wil
require improvements to be made across al supplies and al water suppliers. As you can see from
our submission, we are general y supportive of the proposed changes. The only exceptions are:
Perchlorates. We oppose the introduction of a MAV because we do not know of a laboratory
which can test for it in water and therefore have no way to demonstrate compliance.
Aesthetic value for chlorine. We oppose the reduction of the upper limit for FAC from 1.0 to
0.6 mg/L because we feel this could present a risk to public health.
The areas where we request more information before giving a conclusive opinion are detailed in the
above submission.
We are supportive of the direction in which Taumata Arowai are leading the sector and we are
committed to the journey. There are some existing approved budgets in our Long Term Plan that
have been included to address signal ed changes to regulations, or are for work already planned
that aligns with those changes. The ful cost of meeting the new requirements, however, is not ful y
funded and wil need to be considered alongside the other needs of our water supplies as wel as
balanced with other community needs. We would like to work with Taumata Arowai to develop a
roadmap with identified timelines for meeting compliance and look forward to improving outcomes
for our communities together.
Heather Shotter
Chief Executive
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