Board Meeting: March 2015 Agenda Number: 13 (viii) File Ref: EV0016 LORD HOWE ISLAND BOARD Business Paper ITEM Wastewater Management Program BACKGROUND The Lord Howe Island On-Site Wastewater Management Strategy (the Strategy) was adopted by the Board in late 2012 and then implemented from late 2013. The Strategy consists of two volumes, a Strategy document and Design Guidelines. Since the implementation commenced, there have been a number of matters which have required the Board to vary timeframes for the Strategy implementation and regularly clarify technical and planning elements of the Strategy to provide guidance to leaseholders, supplier and installers. This has resulted in some inconsistencies in on the ground results, frustration from suppliers and leaseholders, and escalating costs for the Board in assessing development assessments for wastewater systems. Whitehead and Associates have been providing advice to Board staff on wastewater development proposals and assisting in provision of technical advice to suppliers and installers. In September 2014, the Board considered a Planning Proposal to amend the LHI Local Environmental Plan, 2010 (LEP) to provide leaseholders with a simple and more efficient process when they upgrade their wastewater systems. The planning proposal sought to define wastewater systems on land zoned 2 Settlement as ‘exempt development’ and permit the ‘development with consent’ of wastewater systems on land zoned 1 Rural, 5 Special Uses, 6 Recreation and 7 Environmental Protection. This item is the subject of a separate Board paper. CURRENT POSITION Since adoption of the Strategy in 2012, and implementation from late 2013, the Board has: Approved Owner Consents only for new systems for 9 leases, 3 of which are commercial. Approved one DA for a system, which is yet to be installed. Approved the installation of 8 systems for 10 leases. This equates to 20 leases or 18 systems out of approximately 230 existing systems (< 10%) on the Island where some action has commenced to meet the Strategy. Early in 2015, Whitehead and Associates were engaged to conduct a review of the 2013 Wastewater Management Strategy and Design Guidelines to consider: 1. Disinfection of wastewater prior to disposal, regardless of surface or sub-surface. Page 1 of 3 2. Buffer distances from groundwater wells \ bores, drainage lines and standing water bodies, particularly looking at viral die-off modelling and nutrient attenuation modelling. 3. Clearer definition of residential and non-residential. 4. Treatment standards and testing requirements for non-residential systems. 5. Reuse of treated effluent. 6. Appropriateness of alternative land disposal techniques not considered in the original Strategy. The aim of the review was to simplify the process for leaseholders, suppliers, installers and the Board, so that the new wastewater systems could be more efficiently installed and the objectives of the Strategy could be achieved. The result of the review is included as Attachment 1 – Strategy and Attachment 2 – Design Guidelines. There are too many changes to be able to provide a copy in Track Changes in Word, so the attachments represent a clean copy of the new documents. In summary, the major outcomes of the review of the documents include: 1. Enforcement of the requirements to disinfect wastewater prior to disposal for all systems on the Island, regardless of surface or sub-surface effluent disposal. The consequence of this change is that five reed bed systems approved by the Board for installation do not have disinfection and are therefore non-compliant. The proposed approach with these installed systems only is to discuss an affordable disinfection method with the supplier and leaseholders to achieve compliance. 2. Reduction in the buffer distance between disposal areas and the ocean from 100m down to 35m. 3. Retention of the buffer distance between disposal areas and active groundwater wells \ bores at 50m. 4. Removal of the Decision Trees from the Design Guidelines. 5. Clearer guidance on system design and sizing, including provision of a model for calculating irrigation areas, with acceptable Lord Howe Island specific values for variables. 6. Allowance of systems not accredited with NSW Health to be installed, but only in circumstances currently permitted by NSW Health. 7. Inclusion of sand mounds as an acceptable method of disposal of secondary treated effluent. 8. Defining wastewater system types as: a. Domestic and Small Commercial Residential – up to 10 persons or 2,000L\day with no commercial kitchen. b. Commercial Residential Properties – more than 10 persons or 2,000L\day with no commercial kitchen. c. Larger Commercial Residential Properties – more than 10 persons or 2,000L\day with a commercial kitchen. d. Non-residential Properties e. Recycled Water Reuse Except for Recycled Water Reuse, all of the examples have the same standard of treatment required, but have varied frequency of testing. Following implementation of this revision of the documents, it is planned to update the documents again in late May 2015, following the proposed changes to the LEP and to simplify the risk assessment levels. It is not proposed to undertake a formal community consultation review of the documents. However, the documents will be provided to Island installers and mainland suppliers for Page 2 of 3 comment, and a householder will be issued advising leaseholders of the documents placement at the Board offices until 31 March 2015. RECOMMENDATION It is recommended that the Board: 1. Approve the revision to the Wastewater Management Strategy and Design Guidelines. 2. Approve their release to the community, Island installers and mainland suppliers for comment by the end of March 2015, and then implementation by the end of April 2015. Prepared __________________ Andrew Logan Manager, Infrastructure & Engineering Services Endorsed __________________ Penny Holloway Chief Executive Officer Page 3 of 3