Board Meeting:
26-27 November 2012
Agenda Number:
11 (v)
File Reference:
EV0016
LORD HOWE ISLAND BOARD
Business Paper
Issue:
Lord Howe Island Wastewater Update.
Background:
At its May 2008 meeting the Board recognised that septic tank effluent represents a threat to
public health and the Island’s World Heritage values. The Board agreed to have all septic
tanks removed or upgraded within the next 5 years.
During 2009 and 2010 the LHIWMC worked with consultant Worley Parsons to produce a
Wastewater Management Strategy Document.
During 2011 the LHIB administration undertook Community Consultation on the preferred
options identified in the strategy document with the intention of identifying the community
preferred option. The results of the community consultation were presented to the Board at
the May 2011 Board meeting.
At the May 2011 Board meeting the Board decided to pursue an onsite wastewater
treatment solution for the island. Subsequent to this decision the LHIB Administration
produced a revised onsite Wastewater Management Strategy which, following community
consultation during May and June of 2012, was approved by the LHI Board at the
September 2012 Board meeting.
Comment
Following approval of the strategy the LHIB Administration has commenced the
implementation phase. There are several implementation activities that are underway and
the following is a summary of the status of these activities.
1. Development of Site specific design guidelines
It was reported in the September 2012 Board meeting that the LHIB Administration has
commenced further works to assist the community with the implementation of the new
strategy. The LHIB Administration has over the last few months been undertaking additional
works to site specific design controls that will be available to leaseholders to use when
procuring a new system.
One of the challenges to onsite treatment of wastewater is the disposal of effluent. Under
the new strategy the effluent quality requirements for residential wastewater are quite low.
The impact of which complicates the disposal regime. Avoiding surface water logging,
potential for human contact, over nitrification of soil and ground water penetration by effluent
is a requirement of the design of an effluent disposal system. LHIB has engaged Agsol to
undertake further works to identify constraints which impact on the design of individual
leaseholder systems. This work is due to be completed in December this year.
2. Investigations of On-site systems
With the finalisation of the strategy the LHIB Administration has undertaken further work
investigating on-site systems specifically in the context of how they could be installed on the
island. This work has been occurring in parallel to the development of the site design
guidelines. There are several initiatives being explored.
Most of the NSW Health accredited systems will meet the requirements of the strategy if
they are installed, operated and maintained appropriately. Some will need additional
treatment systems (such as reed beds) to remove nutrients.
As mentioned in previous Board papers the LHIB Administration will conduct an EOI process
in early 2013 to identify preferred systems that will meet the requirements of the strategy at a
price point generally acceptable to the community.
As part of this EOI process the LHIB Administration will seek to establish a system price. To
keep prices as low as possible, the LHIB will look to offer incentives to system suppliers.
These incentives could include reduced warfage, reduced plant hire rates, subsidised
accommodation for installers, streamlined DA processes, etc. The benefit for the LHIB is
that these incentives will encourage the community to participate earlier to benefit from these
incentives.
The LHIB Administration is looking at other opportunities to reduce costs and improve
outcomes. One of the options being considered is the shared systems – two or more leases
share a system effectively reducing the cost/leasehold. The LHIB Administration believes
this is potentially feasible. It would require an agreement between leaseholders as to
ownership and maintenance arrangements.
The strategy has been designed to create flexibility in developing wastewater systems.
Reuse of existing infrastructure was seen as an opportunity to not only reduce redundant
infrastructure but also as an opportunity to reduce cost. For example where existing septic
tanks are in good condition there is an opportunity to continue to use these tanks either as a
primary tank which is supplemented by a secondary treatment tank or as an effluent wet
weather storage tank.
The LHIB Administration has committed to show leadership in the on-site treatment of
wastewater and to demonstrate this is considering constructing a couple of demonstration
systems that will demonstrate best practice solutions. The LHIB Administration is
negotiating two systems (a commercial and a residential) that could be constructed early
next year. The demonstration projects would enable leaseholders to see them in action and
see how they perform.
3. Community Awareness and education
It was identified in the September Board paper that the LHIB Administration plans to
undertake further community awareness and education activities on the proposed
wastewater management strategy.
In early November the LHIB Administration wrote to all leaseholders advising them of the
new Wastewater strategy and their obligations to upgrade their systems to meet the
requirements of the strategy.
The LHIB Administration has allocated additional resources to assist with this community
awareness and education process. Over the coming months LHIB will hold information
sessions, one on one consultation, and group consultation sessions. Further LHIB will
provide the community additional information such as Q & A fact sheets, and regular
information bulletins.
In addition to the above activities the LHIB Administration will commence work on a fees and
charges regime that will be implemented as at the start of the 2013/14 financial year. The
development of the fees and charges will consider the costs of systems, maintenance and
monitoring requirements.
4. NSW Government funding opportunities
At the September 2012 Board meeting the LHI Board asked the Administration to write to
NSW Government to ask if there was any opportunity for funding assistance to implement
this new strategy.
The LHIB Administration has written to NSW Treasury as part of its TAM Plan submission
requesting consideration of Capital funding for this program.
5. NSW EPA Correspondence and visit to the island
On 7 September 2012, the LHIB Administration received correspondence from the NSW
EPA regarding the management of Wastewater on the island.
A Copy of this
correspondence is attached for the LHI Boards information. The correspondence was
received as a result of the LHIB Administration writing to EPA (3 April 2012) asking them to
provide comment on the proposed strategy. Follow up correspondence from the LHIB
Administration was sent on 7 August again seeking their input. A summary of the EPA
correspondence and the LHIB response to the comments is attached.
Following receipt of the EPA correspondence, the EPA advised that they wished to visit the
island to discuss a number of issues including wastewater. EPA visited the island during the
week 15- 18 October 2012. Subsequent correspondence from EPA reinforced their earlier
comments regarding the challenges to implement on-site systems. The correspondence
identified suspected pollution breaches with some existing systems.
The LHIB
Administration is following up these issues.
The LHIB Administration will write to the NSW EPA seeking their support to work
cooperatively with the LHIB to implement this new strategy that will see significant
improvements to treatment of the islands wastewater
The LHIB Administration proposes to further refine the strategy based on the findings of the
Agsol study and the comments from EPA however these changes will not affect or delay the
implementation of the strategy as changes would primarily be in regard to the risk
assessment process and the determination of disposal areas. These should not impact in
the short term on the process to procure new systems.
Recommendation:
That the Board note the paper.
Prepared By:
Nicholas Holt
Manager Infrastructure and Engineering Services
Endorsed By:
Stephen Wills
Chief Executive Officer
EPA Correspondence 1 received 7 September 2012.
The following is a summary of the observations and technical comments provided in the correspondence:
EPA Comment
LHIB Response
Whilst EPA has a preference for a centralized option they
acknowledged the Boards preference for an on-site approach
Noted
“The EPA believes that the desired environmental outcomes of
this revised strategy will only be achieved in practice if the
integrity of the decentralized approach is not diluted by
compromising the key elements of the strategy.”
Noted
“We also note that the islanders initially accepted the estimated
costs
of
replacing/upgrading
their
existing
systems……………..This level of support may not be sustained
when the cost implications of a fully decentralized sewage
strategy are known”
Noted details of costings were provided in information presented in consultation
documentation and at community consultation sessions. Further information will be
available to the community during the community awareness and education program
planned as part of the implementation phase.
The effectiveness of the revised strategy …..will be strongly
linked ….to both the willingness of islanders to maintain effluent
treatment systems ….. and the rigor with which LHIB follows up
on identified performance issues”. “This strong regulatory
approach will help provide a level of confidence that the
environmental outcomes can be achieved from a fully
decentralized sewage strategy. “However the Board will need to
allocate significant on-going resources to maintain effective
regulator control…. If the desired outcomes are to be realized and
maintained over the long term.”
This has been identified and the strategy details a comprehensive regulatory approach to
the management of on-site systems. The strategy includes a comprehensive section on
the ongoing management requirements of these systems.
Nutrient levels. EPA advised that most small aerated treatment
systems only achieve between 25-50mg/l where as the NSW
Health guideline specifies 20mg/l. The EPA recommended that
method of deriving proposed effluent standards be clarified and
that disposal areas be based on conservative estimates of likely
achievable effluent quality.
Noted. The nutrient levels apecified in the strategy have been amended to reflect the
NSW Health guideline requirements. LHIB notes the results for most small systems and
the work Agsol is doing to identify irrigation areas has been looking at conservative
figures for nutrient removal to ensure irrigation areas are appropriate. The use of reed
beds will be encouraged as a final polisher of effluent to help achieve the targets where
some systems do not meet the requirement.
Effluent Storage. EPA raised concerns about the intention of the
strategy to minimise the need for onsite storage due to
Noted. The strategy was designed to minimise the requirement for wet weather storage.
Based on the work to date by Agsol, most residential situations will have a requirement
requirement for high quality effluent. EPA noted that LHIB was
examining wet weather storage as part of the work by Agsol and
recommends that the strategy be refined based on the outcomes
of the assessment.
for wet weather storage. This storage will be in the order of 10kl – 20kl. In commercial
situations there may be a requirement for wet weather storage to avoid ground
waterlogging. The strategy will be refined following the work of Agsol
Risk Assessment Process. EPA advised that wet weather
storage needs to be taken into consideration and recommends
the risk assessment process be amended to reflect wet weather
storage and land disposal area is capable of preventing effluent
discharge during wet weather events
Noted and risk assessment process will be refined following the work by Agsol.
EPA recommends justification of a reduced buffer distance to
domestic bores or to amend the revised strategy to be consistent
with the DLG Guidelines
Noted. A 250m buffer around domestic bores is not feasible due to the number and
location of Bores. Appropriately designed and maintained irrigation systems with if
necessary wet weather storage will need to installed.