Board Meeting: March 2012 Agenda Number: 13(iii) File Reference: EV 6 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. The Board further resolved that the Lord Howe Island Wastewater Management Committee (LHIWMC) be formed to undertake a risk/cost benefit analysis of proposed options, finalise options and the implementation strategy for final long term sewerage management on Lord Howe Island. During 2009 and 2010 the LHIWMC worked with consultant Worley Parsons to produce a Wastewater Management Strategy Document. In March 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 agreed to the following recommendations: 1. That the LHIB accept the community preferred option of an on-site wastewater management strategy for the island. 2. That LHIB Administration undertakes more studies to determine the appropriate effluent quality requirements to be met by these on-site systems. These studies will include: a. Nutrient balancing of island soils to determine the capacity of the soils to accept wastewater; and b. Consultation with Government agencies on requirements for environmental protection. 3. That LHIB investigate proprietary onsite systems that are suitable for dwellings of up to 10 people, including: a. an analysis of what proprietary systems are on the market and what effluent quality they can achieve; b. Cost analysis of various systems based on them meeting these quality standards including life cycle costing; c. Maintenance and operating procedures; and d. Island resources to undertake the maintenance of these systems including training requirements. 4. That LHIB undertake more community consultation to ensure community understanding and support to determine: 5. 6. 7. 8. a. What are the wastewater effluent quality standards to be met by on-site systems? b. Given the wastewater quality standards is there a requirement for a reticulated effluent disposal system? c. How does the community fund any community infrastructure? d. How do leaseholders pay for the upgrades of their systems? LHIB Administration determines any fees and charges to be applied to leaseholders including any penalties for non-complying systems. After completion of the studies and the community consultation LHIB Administration revise the LHI Wastewater Strategy to: a. Identify the effluent quality requirements to be achieved by on-site systems; b. Identify some LHIB preferred proprietary systems that meet the effluent quality requirements; c. Detail the monitoring and testing requirements of the systems; d. Systems servicing more than 10 people (lodges, clusters) need to be design by an appropriately qualified system designer and that the systems are designed to meet the required quality standards That after determination of the wastewater quality requirements, the LHIB Administration write to all leaseholders advising them of the required effluent quality requirements and the time frame for their system to be upgraded to meet this requirement. That the timeframe for upgrading of all systems to meet the requirements of the revised Wastewater Management Strategy remain as June 2013. This date may be reviewed if it is determined that a reticulated effluent disposal system is required. Following the May 2011 Board meeting, the LHIB administration has commenced implementing the recommendations approved by the Board. The following is a summary of progress against each of the recommendations: 1. Noted and being implemented; 2. LHIB has developed proposed effluent quality standards to be incorporated into an Onsite Sewage Management Strategy. In developing these effluent quality standards LHIB reviewed published standards and guidelines including: NSW Department of Health Sewage Management Facility, Sewage Treatment Accreditation Guideline (May 2005)); Department of water and Energy Interim NSW Guidelines for the Management of Private Recycled Water schemes (May 2008) Environment & Health Protection Guidelines On-site Sewage Management for Single households, NSW Government (January 1998) Management of National Water Quality Management Strategy National Guidelines for Water Recycling: Managing Health and Environmental Risks (November 2006); LHIB has also considered the work undertaken by GHD for the new Bureau of Meteorology House (MET House). LHIB will monitor that development as a test case for the implementation of new wastewater quality guidelines for the LHI. The specification developed by GHD in consultation with LHIB has been developed around a proprietary system with additional treatment of microfiltration and chemical dosing. 3. LHIB has investigated proprietary on-site wastewater systems for domestic applications through undertaking the following actions: a. The LHIB Administration has contacted all NSW Health accredited suppliers of on-site sewage treatment systems seeking information on i. Effluent quality produced by their systems; ii. The maintenance requirements of their systems; iii. The costs of these systems The results of these investigations have been mixed with some suppliers willing to provide some of the information whilst others haven’t provided anything. Most provided some information on effluent quality but only a few were able to provide data on nutrient removal as this is not a requirement for NSW Health accreditation. No suppliers were willing to provide estimated costs. All were willing to provide a quote for a particular system if requested but not for general purposes. They sited too many unknowns in relation to freight, ongoing maintenance costs, ground conditions, status of existing systems etc. When discussed about an indicative Capital cost in the order $15k-$20k per system installed several suppliers did not think that was unreasonable. Some suppliers do have service agents on the island. In regards to maintenance plans the requirements are established by NSW Health and are a requirement to maintain accreditation. b. Through the Met House development, LHIB has gathered some intelligence on the systems considered as part of the procurement processes for the wastewater system. This system produces an effluent of a very high standard that is effectively class A non potable water. The cost of the system is in the order of $20-25,000 installed and there is a local plumber who can undertake ongoing maintenance. c. LHIB has selected a range of existing private systems on LHI and has undertaken wastewater effluent quality analysis to determine what the quality of effluent these systems are currently producing. The results of these tests are attached for the Board’s reference. Key findings of these testing is as follows: i. Against the standard of what an AWTS is required to achieve under NSW Health accreditation for an environmentally sensitive area all systems fail to meet the requirement. ii. In regards to disinfection none of the systems meet the requirement. ; At the time the samples we taken several of the systems were not working correctly and for some the tester had to return to the premise to undertake the tests. This alone demonstrates that systems are not being maintained properly. With this process the dates for testing were agreed prior with the leaseholder so there should have been no excuse for systems to not be operating properly. I note that these systems were selected because they were identified by LHIB as systems most likely to produce good results. What the tests show is that poor system management and maintenance will result in even the best wastewater systems not operating correctly. Effective maintenance plans that are enforced are critical to ensure the islands wastewater strategy is effective. Based on this process, the LHIB Administration has concluded that following finalisation of the strategy LHIB needs to take a leading role in guiding the procurement and selection of wastewater systems to require appropriate maintenance and testing regimes are established. This will assist leaseholders to obtain value for money for their systems and that the community and environment benefits from appropriately operating systems. 4. The LHIB Administration plans to undertake further comprehensive community awareness and education process on the proposed wastewater management strategy subject to the LHI Board approval do so at this March meeting. 5. LHIB has not progressed work on the fees and charges at this stage. These will be considered after finalisation of the Wastewater strategy document and details of systems costs are established and a financial impact assessment undertaken. Costs of systems, maintenance and monitoring requirements need to be considered before these fees and charges can be determined. 6. The revision of the current wastewater strategy has been completed and a copy is attached for LHI Board consideration. The Administration finalised the development of the draft strategy so that community awareness and education process can be undertaken. 7. Following the finalisation of the strategy document LHIB will formally advise leaseholders of their obligation to upgrade their systems. It is proposed that as part of the future community consultation process leaseholders will be advised of their future obligations. 8. The date of 2013 for the upgrade of all septic systems is still current. The strategy identifies septic systems as high risk systems and as such a licence to operate valid for 12 months will be issued to those leaseholders. This meets the requirement to have all septic systems upgraded by 2013. All existing systems will be assessed for risk and Leaseholders notified. Systems will be assessed against the criteria in the risk strategy. All systems will initially be assessed as either high or medium risk until such a time as the leaseholder can demonstrate that the system complies with the requirements of the strategy. Systems identified as medium risk under the strategy will be issued a licence to operate a wastewater system for a period of up to 3 years in order to upgrade their systems to comply with the Wastewater management strategy. The following program has been developed for this program Identification of Preliminary Wastewater Quality requirements and preferred proprietary systems December 2011 Finalisation of Wastewater Quality Requirements March 2012 Draft wastewater strategy for LHI Board consideration March 2012 Community consultation April /May 2012 LHIB approval of revised Wastewater Strategy May 2012 Letters sent to Leaseholders re upgrade of systems June 2012 Upgrade of all septic systems end 2013 Upgrade of balance of systems End 2015. Recommendation: It is recommended that the Board note this paper and endorse the draft LHI On-site Sewage Management Strategy for community consultation purposes. Prepared By: Nicholas Holt Manager Infrastructure & Engineering Services Approved By: Stephen Wills Chief Executive Officer