Raglan wastewater discharge consent

Assessing the options available to us makes up a large part of the investigations required for the consent application process. Therefore, we’ve engaged planning, environmental and engineering experts Beca to assist us, and our service provider Watercare Services Limited, in putting together our resource consent application, along with other specialist sub-consultants to help with land suitability, marine modelling, public health and coastal ecology investigations and assessments.

Waikato Regional Council is currently processing the short-term consent application and has indicated the consent will be publicly notified in due course.

This short-term consent will give more time to thoroughly tease out all the options and engage with iwi and the community on them. We want to get this right and we are willing to take the time to do that.

With the advice received and the consideration that ongoing investigations are complex, we believe the best term sought for the interim consent was 36 months. We will continue to investigate a long-term sustainable wastewater treatment and discharge solution during this time.

It is worth noting that this does not stop Council applying for consent for the long-term term consent sooner. The pace of stakeholder engagement and development of the ultimate solution will impact directly the submission date of the long term consent.

Pressure on the timeframes associated with preparing an application before the current consent expires in February 2020 was a concern expressed by the stakeholder group and the Council project team. We don’t want the current consent to expire.

Iwi, the Raglan community and other stakeholders have expressed a strong preference for a discharge to land option, and, as a result, we’ve been investigating potential land discharge/land treatment options since 2016.

Since early 2019, we have widened our investigations to include other alternatives and we’re currently assessing potential treated wastewater reuse and discharge to water options and combinations of the same. Given the complex technical engineering, environmental and cultural considerations involved in the option assessment process, these investigations are ongoing.

As part of these investigations, we also have to consider the capital, operational and whole-of-life cost of the options as well as the affordability to the community. 

In order for the long-term preferred option to be properly investigated and to enable the continued operation of the wastewater treatment plant while that process is carried out, we have lodged a short-term consent for a period of 36 months. This consent will authorise the existing discharge and coastal occupation activities to continue. Once the preferred long-term option has been identified, a long term resource consent application will be lodged.

We started our thinking at a 12 month short term consent, however feedback from external experts tells us that 36 months was most realistic (this timeframe also provides for some contingency). This timeframe was supported by Waikato Regional Council, the consenting authority.  

Also adding to the complexity of this situation, during the period that this consent has been worked on, we entered a multi-decade contractual arrangement with Watercare Services Limited. Watercare now provide all of Council’s three water services to the community. We believe that the key to getting the best long term outcome for the Whāingaroa/Raglan community is the inclusion of Watercare’s expertise and innovation, alongside stakeholders, in the process to assist the creation of the best solution.

For more than six years, Waikato District Council has been working towards a better and more sustainable way to deliver water services across the district. This process has considered different regional structures and models. After several iterations it was determined by Council in 2018 to engage with Watercare, who are Auckland Council’s Council Controlled Organisation (CCO) for water and wastewater services.

A 29 year arrangement has been put in place for Watercare to deliver the three waters services for Council as of 1 October 2019. A Waters Governance Board (a delegated decision making body of Council) is now in place to ensure the contract delivers on the objectives of Council. With this relationship now in place, we can leverage Watercare’s considerable technical expertise and procurement experience to get the best outcomes for the Whāingaroa/Raglan community regarding the wastewater treatment plant and its consent.

The investigations on the longer term solution will not stop with the lodgement of the November application. Work done for non-marine solutions will continue. We know that a part land based (re-use) solution is technically available, where key components for success include both land availability and affordability.

We need to consider both private and Council-owned land options. We need enough time to work through these, keeping in mind that some timeframes (around private land options) are to an extent outside of our control.

It is important that our key stakeholder’s and the wider community understand that  the sensitivity of such work means that step-by-step updates on progress might not be possible due to commercial sensitivity/possible negotiations and  investigating land based re-use options has been the main work undertaken to date. This will continue.  

Waikato District Council now seek informal feedback on the Assessment of Environmental Effects (AEE), prior to the formal notification period of the short-term consent. The purpose of seeking feedback at this time is to inform the ongoing development of the long-term wastewater management, treatment and discharge option for Raglan. The short-term consent application and AEE can be found at the bottom of the page.

The table below represents a short list of mitigation options. This focus allows our project team to concentrate on necessary investigations required for the final discharge application of treated wastewater. The application will include a ‘preferred option’ from this list, where under the Resource Management Act (RMA), the application will also need to outline why other potential mitigation methods were discounted.

Please read the Dept of Conservation information sheet that covers Toxoplasmosis risk to the Hectar and Maui Dolphin. A key educational message is to “Please bury any kitty litter droppings in the garden, rather than flushing them”

The Raglan WWTP discharge consenting project is underway, where there is an open invite for all to be involved (monthly community meetings occur, where individual discussion is welcomed also.

The Project Team are keen to hear from any large land owner within 10km of the plant, who may be open to discuss ‘in principle’ access to land (purchase/lease) for treated wastewater irrigation. This is part of exploring discharge options, where landowner engagement always starts as knowledge building exercise, with no unwanted commitment attached. The call for expressions of interest now is to avoid any missed opportunities.

Please contact Stephen Howard (Watercare Planner) on 021 921745 or Stephen.Howard@water.co.nz if any additional information is needed.

• Please contact Stephen Howard in respect to the WRC Technical Assessment Review if additional information is sought (021921745)

The short term consent application suggests amending the Total Suspended Solids (TSS) treated wastewater limits. The reason for this is to reflect the actual performance of the wastewater treatment plant (which is typical for a pond based wastewater treatment plant).

The suggested change to the TSS consent limits is also informed by the findings of Human Health Risk Assessment from NIWA (included in the short-term AEE) which determined that the concentrations of TSS in the treated wastewater do not adversely impact the effectiveness of the UV disinfection unit to reduce indicator bacteria concentrations.

There were concerns raised when the existing pipeline was originally consented and concerns have since been raised about treated wastewater being discharged into the marine environment.  There is also a requirement to investigate discharge options under the Resource Management Act (RMA).

As part of the preparation of this resource consent application, different options are being investigated to consider the treatment of the wastewater (this affects the quality of the water discharged) and the location of the discharge. 

A number of public drop in sessions will be held which provide you an opportunity to discuss the project and the options with the project team.  There will also be the opportunity for you to contribute to the sensitive sites maps (recreational use areas, food gathering/kaimoana areas, etc) at the drop in sessions.

Let the project team know you would like to be kept updated by emailing info@waidc.govt.nz, we will add you to our email updates

Due to the nature of the resource consent application Council believe this will most likely be publicly notified by Waikato Regional Council (WRC make the final decision on notification, so this decision is up to them).  In the event an application is publicly notified anyone can make a submission to WRC on the application which will be considered when processing the application.  In the event that the application goes to a hearing you can indicate in your submission if you would like to be heard at the hearing.