Foxton Wastewater Discharge

Transcription

[HDC, 2015:C6]
Foxton Wastewater Discharge - Determination of the
Best Practicable Discharge Site
February 2015
This report has been prepared by the Horowhenua District Council with assistance and input
from technical advisors, including Lowe Environmental Impact (LEI) and Beca. No liability is
accepted by Horowhenua District Council, any employee or sub-consultant with respect to its
use by any other parties.
Project Manager:
Gallo Saidy
Prepared by:
David McCorkindale, Gallo Saidy – Horowhenua District Council
Philip Lake, Peter Hill, Hamish Lowe – Lowe Environmental Impact
Limited
Hywel Edwards – Beca Limited
Reviewed by:
David McCorkindale
Approved for Issue by:
Gallo Saidy
Status:
Final
Reference:
Foxton_WWTP_Best_Practicable_Site_Report-150219-final.doc
Date:
February 2015
TABLE OF CONTENTS
1
EXECUTIVE SUMMARY ............................................................................. 1
1.1
Introduction ............................................................................................................. 1
1.2
Background Issues .................................................................................................. 1
1.3
WWTP Design and Location Considerations .............................................................. 2
1.4
Potential Site Assessments and Consultation ............................................................. 2
1.5
Key Criteria for Selecting the Best Practicable Site ..................................................... 3
1.6
Recommended Best Practicable Site......................................................................... 3
2
INTRODUCTION ........................................................................................ 5
3
BACKGROUND ISSUES ............................................................................ 8
3.1
Consenting Background ........................................................................................... 8
3.2
Wider Project Background ...................................................................................... 11
3.3
Planning Considerations ........................................................................................ 13
3.4
Local Government Obligations ................................................................................ 17
4
TREATMENT, STORAGE, AND DISCHARGE REGIME CONSIDERATIONS 18
4.1
Wastewater Flows and Quality ................................................................................ 18
4.2
Storage Considerations .......................................................................................... 18
4.4
Full River Discharge .............................................................................................. 19
4.5
Full Land Discharge ............................................................................................... 19
4.6
Combined Land and Water Discharge ..................................................................... 20
5
LAND DISCHARGE CONSIDERATIONS ................................................... 21
5.1
Suitability of Land in the Foxton Locality .................................................................. 21
5.2
Potential Discharge Areas and Characteristics ......................................................... 22
5.3
Land Purchase and Ownership ............................................................................... 22
5.4
Area Requirements ................................................................................................ 23
5.5
Management and Land Tenure ............................................................................... 23
5.6
Potential for Expansion .......................................................................................... 23
5.7
Soils (hydraulics) ................................................................................................... 24
5.8
Drainage ............................................................................................................... 24
5.9
Buffers and Setbacks ............................................................................................. 24
6
SURFACE WATER DISCHARGE CONSIDERATIONS ................................ 25
6.1
Introduction ........................................................................................................... 25
6.2
Flow conditions ..................................................................................................... 25
6.3
Discharge Location ................................................................................................ 25
6.4
Discharge Rate ..................................................................................................... 26
6.5
Environmental Values ............................................................................................ 26
6.6
Recreational Use ................................................................................................... 27
6.7
Cultural Considerations .......................................................................................... 27
6.8
Discharge Effects .................................................................................................. 27
7
SITE IDENTIFICATION ............................................................................. 29
7.1
Process ................................................................................................................ 29
7.2
Key reports ........................................................................................................... 29
7.3
Focus Group Reports ............................................................................................. 31
8
CONSULTATION ..................................................................................... 34
8.1
Strategy ................................................................................................................ 34
8.2
Historic ................................................................................................................. 34
8.3
Recent.................................................................................................................. 35
8.4
Focus Group ......................................................................................................... 35
8.5
Specific Iwi Engagement ........................................................................................ 44
9
PREFERRED SITE OPTION ANALYSIS .................................................... 46
9.1
Key Considerations and Objectives ......................................................................... 46
9.2
Site Options to Consider ........................................................................................ 46
10
KEY ISSUES ........................................................................................... 50
10.1
General ................................................................................................................ 50
10.2
Land Availability .................................................................................................... 50
10.3
Water Quality ........................................................................................................ 50
10.4
Environmental Impacts ........................................................................................... 50
10.5
Recreational Values ............................................................................................... 51
10.6
Cultural Values ...................................................................................................... 51
10.7
Use of Existing Infrastructure .................................................................................. 52
10.8
Affordability ........................................................................................................... 53
11
CONCLUSIONS ....................................................................................... 54
12
RECOMMENDATIONS ............................................................................. 56
12.1
Preferred Site ........................................................................................................ 56
12.2
Proposal ............................................................................................................... 57
13
NEXT STEPS........................................................................................... 59
13.1
Council Approval ................................................................................................... 59
13.2
Communicate Decision .......................................................................................... 59
13.3
Land Access Procurement...................................................................................... 59
13.4
Investigation and Design ........................................................................................ 59
13.5
Consenting ........................................................................................................... 60
13.6
Timing .................................................................................................................. 60
14
APPENDICES .......................................................................................... 61
Appendix A
Appendix B
Appendix C
Discharge Consents 103925 and 103926
Project Timeline
Figures
1 EXECUTIVE SUMMARY
1.1
Introduction
Horowhenua District Council (HDC) operate the Foxton municipal wastewater treatment plant
(FWWTP) on Matakarapa Island which is surrounded by Foxton Loop and the Whirokino Cut of
the Manawatu River. The FWWTP was originally constructed at this location in circa 1970, and
it currently consists of three oxidation ponds with no mechanical assistance. The treated
wastewater is currently discharged via a surface drain into the Foxton Loop to the west of
FWWTP.
Following the lodgement of a short term interim discharge consent application in August 2014,
which has not been granted, HDC continues to rely on two discharge consents to operate the
FWWTP which were granted by Horizons Regional Council (HRC) in 2009. Consent conditions
attached to the 2009 permits required HDC to investigate land based discharge options. In
addition to this, HDC has made other commitments (notably the Manawatu River Leaders’
Accord) to cease direct discharges to the Foxton Loop and the Manawatu River.
HDC has undertaken a large number of reviews and extensive community engagement during
the term of the 2009 consents in an effort to identify a land based discharge solution. However,
because of the tight timeframes imposed by the 2009 consent conditions, and other wastewater
consenting pressures facing HDC (notably Shannon wastewater treatment plant discharge
consents), a land based discharge scheme has not been identified for Foxton prior to the expiry
of these consents. Consequently, on 29 August 2014 HDC lodged an application with HRC for
a temporary 19-month continuation of these discharge consents. The 19 month consent term
sought was intended to provide HDC with adequate time for further consultation to occur and to
enable HDC to determine the best practicable site, to develop and design a proposal, and to
lodge robust long term resource consent applications for a revised FWWTP and discharge
system.
In order to progress the selection of a location and design for the future FWWTP prior to the
expiry of the temporary discharge consent, HDC need to select the ‘best practicable discharge
site.’ Technical reviews and community consultation to date have been unable to agree
unanimously on the location for the discharge site. With multiple options available, a decision is
needed by HDC on a preferred discharge site taking into account technical, environmental,
cultural, financial, and social factors. In order to assist HDC to make this decision, this report
provides a summary of the process to date, the sites previously assessed, and the reasons for
and against using each potential site for the FWWTP and its discharge. It provides a
recommended treatment and discharge site for long term use.
1.2
Background Issues
The 1997 and 2009 discharge resource consents indicated a commitment by HDC to
implementing land discharges as a means of ceasing or reducing direct discharges of FWWTP
treated wastewater into Foxton Loop. In 2010 HDC signed the Manawatu Leaders’ Accord
which committed HDC to investigate removing the District’s discharges of treated wastewater
from the Manawatu River when the river flow is below half median. This included WWTP
discharges from Shannon, Mangaore, and Tokomaru as well as Foxton.
The Manawatu Estuary has a number of protective measures. It is a Ramsar site within the
coastal environment that recognises its internationally significant wetland ecosystem value. The
Horowhenua District Plan classifies it as an Outstanding Natural Feature and Landscape which
has specific rules that control development and use of the land. Further, the lower Manawatu
River is subject to extensive recreational activities and is considered to be a taonga by local iwi.
Foxton Wastewater Discharge - Determination of the Best Practicable Discharge
1
These features require careful consideration when assessing alternative sites for a treatment
and discharge facility, or using the existing site.
1.3
WWTP Design and Location Considerations
The current and future FWWTP needs to cope with variations in daily flow rates and wastewater
composition caused by Foxton’s residential and trade waste sources. Ideally the FWWTP and
its discharge should be located as close as possible to Foxton in order to minimise reticulation
and pumping costs, but sufficiently distant from sensitive neighbours and open waterways to
avoid environmental concerns.
While ideally irrigation systems will be used to apply the treated wastewater to land, the
discharge options also need to include a means of discharging winter flows when irrigation
demand is minimal and wastewater flows are greater. High winter flows and low irrigation
demand ultimately means that some treated wastewater will enter groundwater and/or surface
water after passing through land.
Section 5 of this report describes the key considerations for selecting suitable land for the land
discharge of FWWTP’s treated wastewater. The most crucial considerations include available
land area, distances horizontally and vertically from surface water and groundwater (including
seasonal variations and flood hazard), proximity to Foxton, and land ownership and access
arrangements, including crop or grazing management.
Section 6 of this report describes the key considerations for controlling the discharge of
FWWTP’s treated wastewater to water. The most crucial considerations include the flow
conditions of the Manawatu River which determine its assimilative capacity and relevant One
Plan target values for contaminants. The Manawatu estuary’s environmental, recreational, and
cultural values are also important considerations. The current FWWTP discharge to Foxton
Loop contributes a very small percentage of the total contaminant and volume load to the
Manawatu Estuary, and its complete removal is not likely to be measureable. Nevertheless the
removal of surface water discharges from the FWWTP is important to the community and has
been committed to by HDC.
1.4
Potential Site Assessments and Consultation
Since 2001 HDC has actively reviewed options for land discharge sites for FWWTP and
consulted with the community and property owners. The consultation prior to 2014 was primarily
with interested parties who were submitters on Long Term Plan (LTP) processes or resource
consent applications for FWWTP discharges. During 2014 a community based Focus Group
was established from a wider spectrum of the community for the purpose of reviewing potential
sites and providing HDC with a more representative community view of the preferred discharge
regimes and sites. Section 8 of this report presents a summary of the meetings, sites and
reports considered, and outcomes of the Focus Group consultation process, including the
parallel iwi consultation process that was initiated during the Focus Group meetings.
Since 2001, HDC and their advisors have completed preliminary feasibility studies of an
extensive range of potential sites for the FWWTP and its discharges. As detailed in Section 9,
over 20 areas and sites have been considered.
While the Focus Group confirmed the community’s intention to cease direct discharges to the
Foxton Loop and Manawatu Estuary, there was no consensus on a single agreed site. The sites
the Focus Group had considered all had limitations and constraints. However, two sites
received the most attention; these being Matakarapa Island and Target Reserve. While not
unanimous, generally the community groups had a preference for using Matakarapa Island. Iwi
2
and some interest groups objected to both Matakarapa Island and Target Reserve (the Focus
Group’s second most popular choice) being used.
It should be noted that the intention to use a land based discharge system has been proposed
for some time. There have been a number of reasons why a specific option has not been
adopted; including access to land, suitable land, buy in from the community on a preferred site,
technical limitations of sites and the acceptability of costs to the community. The reality is
options are complex and there is no one perfect site. The history of debate demonstrates that
this is a complex issue and it is unlikely that all aspects of the community will support whichever
site is selected by HDC.
1.5
Key Criteria for Selecting the Best Practicable Site
The key criteria to be considered for selecting the best practicable site are outlined in Sections 9
and 10 of this report. The key criteria centre on land suitability and availability, water quality and
environmental effects, recreational values, cultural values, the use or abandonment of existing
infrastructure, and financial implications for HDC’s ratepayers. The issues to be balanced are
complex and conflicting in many cases. Each issue should be considered carefully by the
decision makers so that they are informed about the limitations.
1.6
Recommended Best Practicable Site
Matakarapa Island is recommended as the best practicable site for both the FWWTP and the
land discharge. The reasons for this recommendation are:
•
•
•
•
•
•
•
The existing FWWTP is located on Matakarapa Island, which avoids significant
replacement costs;
Sufficient land exists on Matakarapa Island that is elevated above groundwater and
flood hazard levels, which , in combination with suitable soils, means that the site is
suitable for a land based discharge system;
The implementation of land discharges on the island with generous vertical and
horizontal buffer distances from groundwater and surface water will reduce the effects of
the discharges on Foxton Loop and the Manawatu Estuary;
The site is in close proximity to Foxton, but is largely located away from sensitive
neighbouring environments;
This is expected to be the least expensive of the viable site options, meaning that costs
and financial burdens on ratepayers are minimised;
All aspects of the WWTP operation are kept within a compact area which leads to
operational efficiencies; and
Culturally significant sites on the island will require sensitive consideration throughout
the design and consenting process, but it is expected that these sites can be avoided
and adverse cultural effects can be appropriately mitigated.
This site has the most overall advantages compared with any alternative site, and its
disadvantages can be appropriately avoided, remedied, or mitigated. It best meets the key
criteria for selecting the best practicable site for both the FWWTP and its land discharge
system. It should be noted that no single site meets all of the key criteria; all sites considered
within the Foxton locality have disadvantages and design limitations. It should also be noted
that there is very limited time for undertaking further reviews of potential sites within the time
remaining for lodging applications with HRC for long term discharge resource consents
As a consequence of the above recommendation regarding the selection of Matakarapa Island
as the best practicable discharge site, HDC are recommended to authorise the following series
of actions to commence immediately:
3
•
•
•
•
Pursue site-specific investigations of Matakarapa Island for land discharge of FWWTP’s
treated wastewater with urgency;
Prepare conceptual designs for the land discharges at Matakarapa Island;
Work with iwi to identify their concerns, develop mutually acceptable mitigation
measures to be incorporated into the system design; and
Prepare resource consent applications for lodging with HRC by March 2016.
The implications of making this decision as recommended above include:
•
•
•
•
•
An acknowledgement that iwi and some community representatives are likely to be vocal
in their opposition, and some negative publicity may result from this;
Access to the land will likely incur costs and negotiations that may take some time to
resolve;
Resource consenting may be expensive and lengthy as a consequence of opposition
(appeals may occur as well – acknowledging that direct referral to the Environment
Court remains an option for Council);
An acknowledgement that a possible part of the long term solution includes indirect high
rate discharges to Foxton Loop or the Manawatu River via a land passage system
during periods of elevated river flow rates (above the 20th flow exceedance percentile1
(20FEP)); and
An acknowledgement that any reduction in direct discharges to Foxton Loop will
contribute to improving the water quality of Foxton Loop which will in turn improve the
public perception of recreational opportunities, estuary ecological health, and cultural
values.
If Matakarapa Island is not selected by HDC as the best practicable site for Foxton WWTP and
its discharges to land, then the implications are as follows:
•
•
•
•
1
HDC must make a decision (or at least provide a recommendation) on their preferred
alternative site(s) with reasons;
HDC will need to authorise further appropriate site specific investigations that will enable
future decisions to be made regarding designs and costs;
Further negotiations may be required with HRC to extend the timeframe for lodging
applications for long term discharge resource consents, and this may generate negative
political and media responses; and
Rates increases for all ratepayers across the district who are connected to a reticulated
HDC sewage system will increase proportionately with any budget increases for the
FWWTP upgrade.
That is, high flows that occur 20% of the time.
4
2 INTRODUCTION
Foxton is a community of some 2,640 people (2013 Census) located close to the Foxton Loop
section of the Manawatu River near its estuary and river mouth into the Tasman Sea. It has a
steady year round population that, according to Statistics New Zealand data, is slowly declining.
Despite this trend, for long term planning purposes HDC have adopted an assumed population
growth rate of 0.4 % pa over the next 50 years; this was based on the conclusions of a
population forecast report by Infometrics2.
The Foxton Wastewater Treatment Plant (FWWTP) is located on the inside bend of the old
Manawatu River on what is effectively known as Matakarapa Island. The Island is surrounded
by what is now referred to as the Foxton Loop (a former meander of the Manawatu River) with
the Whirokino Cut providing the new route for the river that results in the main river flow
bypassing the Foxton Loop. A location figure is presented in Figure 1. The land on which the
FWWTP is currently located is owned by HDC.
Figure 1: Location Plan for FWWTP
Wastewater from the Foxton Township is currently pumped from a single pump station on
Stewart Street through an elevated pipe bridge over the eastern arm of the Foxton Loop onto
Matakarapa Island and across towards the western side of the Island where the FWWTP is
located on HDC owned property.
2
Review of projections for the Horowhenua District, Infometrics, July 2014.
5
Following treatment through the three pond system, the treated wastewater is discharged by
gravity via an open channel to the western arm of Foxton Loop which ultimately drains into the
Manawatu River estuary. This discharge point (see Fig. 2) is located about 1 km from the
confluence of the Foxton Loop with the main Manawatu River channel at the western end of the
Whirokino Cut.
Figure 2: FWWTP Discharge Layout
In 1997 HDC were granted a discharge consent which committed HDC to investigating and
implementing land discharge of Foxton’s treated wastewater. The 2009 re-consenting decision
confirmed this commitment and specified a number of programmed stages and timeframes that
were to be completed prior to the discharge consent’s expiry on 1 December 2014. In 2010
HDC made a further commitment to investigate removing treated wastewater from the
Manawatu River when it signed the Manawatu River Leaders’ Accord.
In 2012, HDC engaged Lowe Environmental Impact (LEI) and Beca to examine a number of
discharge options for discharges from the FWWTP. This collaborative work between HDC and
their advisors forms part of a strategic and ongoing process of looking at options to manage a
number of wastewater discharges in the district. As part of this work, investigations have been
carried out into the technical feasibility of applying treated wastewater to land for the Foxton
community, and other communities in the district. The work undertaken in this report, and the
previous work, is referred to as the “Land Application Strategy”, which is not a single document
but the term applied to describe the Project Team’s focus on developing sustainable wastewater
solutions that maximise wastewater discharges to land in the Horowhenua District. The initial
studies were conducted at a very high level prior to delving into more detail for the specific
requirements, including those for the Foxton discharge.
This reports draws together the main recommendations and findings of several reports
developed as part of the Land Application Strategy, and the more recent consultation
undertaken through the Foxton Wastewater Focus Group. The report hierarchy and how the
reports link together is shown in Figure 3.
6
Figure 3: Flowchart of Reports and Studies Providing Input to the BPDS Assessment
This report summarises investigation work to date for the FWWTP discharge and also presents
the outcomes of the recent public consultation carried out. It provides a framework for selecting
a single Best Practicable Discharge Site (BPDS) for further investigation and design, and
ultimately the consenting of a sustainable wastewater discharge system for the community.
7
3 BACKGROUND ISSUES
3.1
Consenting Background
3.1.1
Current Consents
As summarised in Table 1 below, HDC is currently authorised3 to discharge treated wastewater
from the FWWTP following the granting of two discharge permits from Horizons Regional
Council in February 2009. A copy of these discharge permits is included in Appendix A of this
report.
Table 1: FWWTP Discharge Consents
Type of Consent
Consent Summary
Consent
Reference
# 103925
Discharge to water
Discharge to land
# 103926
For pond treated wastewater and industrial wastewater to
the Manawatu River (Foxton Loop) at a rate of up to
2,000 cubic metres per day (2,000 m³/day)
For wastewater and industrial wastewater to land at a
rate of up to 2,000 cubic metres per day (2,000 m³/day)
as a result of seepage from the existing unlined
wastewater (sewage) treatment ponds at the Foxton
Wastewater Treatment Plant
During the Hearing for the above consent in 2008 that resulted in the granting of the above
consents, HDC had a strong commitment to investigate and consider land application of
wastewater, in consultation with interested parties. This commitment was driven by the
interests of the community and a preference to lessen the impact of the discharge on the
Manawatu River. It also reflected the requirement of the previous discharge consent granted in
1997 to investigate and progress towards implementing a land-based discharge system. The
consideration of land discharge options was reflected in the conditions of the February 2009
consent. This consent was appealed and through mediation conditions were revised with a final
suite of conditions granted in December 2009. These included:
1.
The Permit Holder shall:
a.
By 1 December 2010 complete a reasonable (in terms of sufficient
scope) and expert analysis of the technical and economic feasibility of
discharging wastewater from the Foxton Wastewater Treatment Plant to
land rather than to surface water. The land to be assessed by the Permit
Holder shall include but not necessarily be limited to, land owned by the
Horowhenua District Council. For the purpose of this Condition the land
owned by the Horowhenua District Council shall include the endowment
land shown in the attached aerial photograph marked “Figure 1”.
b.
By 1 August 2011 carry out consultation process required under the
Local Government Act 2002 in respect of a decision regarding the long
term wastewater treatment and discharge option for Foxton.
c.
Should the report submitted in accordance with conditions 1(a) not
identify a suitable and/or feasible discharge to land option, the permit
holder shall by 1 December 2011 undertake a further expert analysis of
Following the lodgement of an interim consent application on 29 August 2014 which enables
HDC to continue to discharge in the short term (refer Section 3.1.2)
3
8
the technical and economic feasibility of discharging wastewater from
the Foxton Wastewater Treatment Plant to land rather than to surface
water.
d.
Should the permit holder be required to comply with condition 1(c), the
consultation process described in condition 1(b) shall be completed by 1
August 2012.
e.
If condition 1(c) applies, the consent holder shall provide reasons to the
consent authority as to why the options identified in the expert analysis
are not suitable and/or feasible.
In addition, the 2009 decision recorded a number of key comments from the hearing committee,
including:
It is the applicant’s intention that the present discharge to surface water will cease
by 2017 and that by then a land based disposal scheme will have been
implemented.
HDC has not implemented a land disposal system. The primary reason cited was
the inability to reach agreement with nearby landowners regarding the voluntary use
of their land for wastewater disposal.
And
We do however note that the HDC has reaffirmed a commitment to land based
disposal and that has heavily influenced our evaluation of the proposal before us.
And
Mr Cameron advised us “The Applicant does not, therefore, intend to continue the
discharge [to the Loop] indefinitely, but considers that the existing discharge, subject
to the improvements proposed in the Application, are just one, but a very necessary,
part of a greater strategy. On this basis, the Application can properly be regarded as
seeking approval for a temporary discharge”.
And
We find that the applicant intends to move to a land based disposal system and has
volunteered conditions reflecting that intention.
Given the applicant’s intention to continue the existing discharge to the Foxton Loop
only for a limited and defined period of time, we make no finding on whether there
are compelling effects based reasons for ceasing that discharge in terms of actual
and potential effects on the surface water receiving environments (the Foxton Loop,
the Manawatu River and the Manawatu Estuary). We do however record that the
evidence of Mr Adams, Dr Ausseil and Dr Gyopari indicates to us that the effects of
the existing discharge on surface and groundwater are not significant.
And
We find that it would be appropriate to allow three (3) years for the HDC to
undertake technical feasibility studies regarding the discharge of the WTP effluent to
land and to undertake any necessary processes under the Local Government Act
(LGA) required to secure funding for the selected land disposal option. A formal
council resolution from the HDC as to whether or not it will proceed with a discharge
to land shall be made within that three (3) year timeframe.
The HDC shall act with all reasonable haste, notwithstanding the timeframes
discussed….
9
And
Our findings in relation to the above matters are that the proposed discharge to the
Foxton Loop is clearly a temporary measure as the applicant has indicated an
intention to remove the discharge from the Foxton Loop and institute instead a
discharge to land. Therefore it is not contrary to the Objectives and Policies of the
MCWQ and it meets the requirements of Policy 2.1b of the MCWQ and Section
107(2)(b) of the Act. In terms of Section 105 matters it is precisely the applicant’s
intention to fully investigate and cost a land based alternative that has led to the
ongoing discharge to the Foxton Loop being required as a temporary measure. We
are satisfied that this is consistent with Section 105 of the Act.
The terms of Discharge Permits 103925 and 103926 were granted for shorter durations than
requested by HDC. The Hearing Panel’s conclusion was that the duration should be for a term
of four years which was deemed to be sufficient to identify a long term solution while authorising
a sufficiently defined duration for the continued temporary discharge. The decision indicated
that this timeframe was intended to also maintain pressure on HDC to actively investigate and
implement land discharges as a long term alternative solution as soon as practicable. This
timeframe was confirmed during the appeal process.
3.1.2
Interim Consents
Discharge Permits 103925 and 103926 expired on 1 December 2014 (refer Appendix A –
Condition 3). Following Horizons affording HDC the necessary discretion to do so, HDC lodged
a short term renewal discharge consent on 29 August 2014. Lodgement of these renewal
consents within 3 – 6 months of the consents expiring retained HDC’s right to continue the
discharge4 and provided regulatory certainty for the community’s sanitary needs. The following
discharges are therefore allowed to continue until such time as a new consent is granted or
declined and all appeals determined:
•
Discharge of pond treated wastewater and industrial wastewater to the Manawatu River
(Foxton Loop) at a rate of up to 2,000 m³/day
•
Discharge of wastewater and industrial wastewater to land at a rate of 2,000 m³/day as a
result of seepage from the existing unlined wastewater (sewage) treatment ponds at the
Foxton Wastewater Treatment Plant.
As a result of consenting pressures elsewhere in the district, namely the Shannon Wastewater
Treatment Plant discharges, a long term discharge solution for Foxton had not been identified at
the time a renewal consent had to be lodged with Horizons to retain the right to continue the
discharge. In recognition of this pressure, only a 19 month term renewal consent was lodged,
being the short term consent referred to above. The 19 month period essentially provides HDC
sufficient time to undertake the following tasks before a long term discharge consent can be
lodged:
•
Continue to investigate potential discharge to land sites prior to selecting a site;
•
Continue to consult meaningfully with the Foxton Focus Group to assist HDC select a
preferred long term discharge solution and site;
•
Confirm the legal right to discharge to the selected site (i.e. ownership / lease);
•
Undertake the necessary technical work to assess potential environmental effects; and,
•
Prepare a resource consent application to implement the proposed discharge solution.
The short term nature of the consent sought provides a clear signal to HRC and the wider
community that identifying a long term discharge solution for Foxton is a priority for HDC.
4
Under Section 124(2) of the Resource Management Act 1991
10
3.2
Wider Project Background
A number of factors influence the long term discharge solution for the FWWTP. These factors,
as well as the influence on the specific resource consenting aspects of the project, are
summarised below.
3.2.1
Manawatu River Leaders’ Accord
HDC is a signatory to the 2010 Manawatu River Leaders’ Accord (the “Accord”). The Accord is
a multi-party catchment-wide strategy aimed at improving the state of the Manawatu River so
that it better sustains fish species and is suitable for contact recreation. While the Accord is
voluntary and has no statutory status, it has widespread endorsement and is held in high regard
by statutory agencies and much of the community.
The follow-up Accord Action Plan signed in 2011 identifies the consented discharge of
wastewater from the FWWTP as one of four ‘significant’5 sewage discharges within the
catchment. By signing the Accord and Action Plan, HDC made a commitment to investigate
removing Foxton’s treated wastewater from the Manawatu River when the river flow is below
half median.
3.2.2
Strategic Review of HDC Water and Wastewater Assets
In 2011 HDC undertook a strategic review of the water and wastewater schemes throughout the
district to address challenges in those systems6. The review signalled a more strategic
approach to the management of its wastewater (and water supply) assets. The
recommendations from the strategic review formed the basis of the scheduled upgrades to
wastewater plants across the district, including the FWWTP.
3.2.3
Long Term Plan - 2012-22
The Long Term Plan 2012 – 2022 (‘LTP’) sets out proposed priorities, projects and activities
that HDC will focus on over a 10 year period and how those services will be funded. The
budgets set within the LTP confirm a realistic and affordable expenditure for the community for
a particular asset / activity.
HDC operate a harmonised rates system for sewer and water which essentially means that all
ratepayers connected to the Council wastewater network pay the same wastewater rates
irrespective of location. This means that an upgrade of a wastewater plant in one location is
funded by all ratepayers on the district’s wastewater network not only those in the community
benefiting from the upgrade.
Solutions for each community must take into account
environmental, cultural and social factors while remaining affordable for the district as a whole.
Financial analysis performed for the LTP determined that the 10 year water and wastewater
upgrade programme recommended in the water and wastewater strategic review was not
affordable for HDC or the community. The investment program was modified to be completed
over a 20 year period. Nonetheless, HDC has a committed capital spend of $113.5 million over
a 10 year period on water and wastewater infrastructure7.
5
6
Significant in the context of effects as opposed to volumes discharged
“Report on Strategic Water and Wastewater Review”, GHD, December 2011.
HDC Long Term Plan 2012 – 2022, Capital Expenditure Section 3 - includes renewal, LOS and
growth.
7
11
3.2.4
Draft Long Term Plan – 2015-25
At the time of preparing this report Council officers are in the final phase of developing the
‘Draft’ Long Term Plan 2015-25. The Long Term Plan Consultation Document is to be open for
public submission during March and April 2015. The Long Term Plan 2015-25 is to be adopted
by 30 June 2015 and would replace the current Long Term Plan 2012-22.
The Draft Long Term Plan is informed by the Infrastructure Strategy, with the relevant and
necessary works to achieve the goals of the strategy included in the Long Term Plan projects.
Given that the draft 2015-25 LTP is currently in the process of being prepared by HDC officers,
the budgets for wastewater infrastructure may change. In order to avoid any pre-emption of
these budgets for FWWTP, this report does not include specific projected budgeted values.
This is because the Draft Long Term Plan may be subject to potential changes as a result of
submissions.
3.2.5
Draft Infrastructure Strategy (2014)
A new requirement for local authorities resulting from the 2014 amendments to the Local
Government Act requires the preparation of a 30 year Infrastructure Strategy. This takes a
longer view of the core infrastructure context than the 10 years of the Long Term Plan and the
20 years of the Asset Management Plans.
The key purpose of the Infrastructure Strategy is to provide a plan for maintaining the current
Levels of Service provided by Council’s core infrastructure of water, wastewater, stormwater
and roading. It also helps Council identify and close any gaps in these Levels of Service. The
Infrastructure Strategy is critical to a sustainable future and the achievement of the Community
Outcomes.
The Draft Infrastructure Strategy was first adopted by Council in December 2014 and will be
consulted on as part of the LTP 2015-25 consultation process.
The Goals for this Strategy are:
Goal 1 – Ensure adequate infrastructural capacity to meet the demands of current and future
generations whilst being affordable to the Community;
Goal 2 – Increase the reliability and resilience of the existing and future infrastructure; and
Goal 3 – Ensure sustainable use of resources and protection of critical environmental values.
The identification of the best practicable option for Foxton clearly needs to align with the goals
of the Infrastructure Strategy.
3.2.6
Land Application Strategy
The Land Application Strategy (the ‘Strategy’) is the over-arching framework initiated by HDC to
assess a range of discharge options for its wastewater schemes within the district. It is not a
specific report, but an internal staff direction that has evolved to allow land application of
wastewater to be maximised where practically possible. The Strategy was conceived shortly
after HDC became a signatory to the ‘Accord’ and following the strategic review of its
wastewater and water supply assets in 2011.
The overall purpose of the Strategy was (and continues to be) to establish for the communities
of Levin, Shannon, Foxton and Foxton Beach the optimal combination of land area and soil
type(s) for the application of effluent to land from those communities and also to allow for the
purchase, where necessary, of that land in a rational and orderly fashion.
12
Central to the development and progression of the Strategy (and ultimately the identification of a
sustainable long term discharge solution for each community) is the adoption of a Best
Practicable Option (“BPO”). BPO, in relation to a discharge of a contaminant, is defined in the
Resource Management Act (RMA) as meaning:
“the best method for preventing or minimising the adverse effects on the
environment having regard, among other things, to—
a) the nature of the discharge or emission and the sensitivity of the receiving
environment to adverse effects; and
b) the financial implications, and the effects on the environment, of that option
when compared with other options; and
c) the current state of technical knowledge and the likelihood that the option
can be successfully applied.”
In considering potential adverse effects on the ‘environment’, a broad definition of this term can
be applied through this BPO process. A broad interpretation which factors in ecological, social,
cultural and economic factors is consistent with the broad definition of ‘environment’ in the RMA:
(a) ecosystems and their constituent parts, including people and communities; and
(b) all natural and physical resources; and
(c) amenity values; and
(d) the social, economic, aesthetic, and cultural conditions which affect the matters stated
in paragraphs (a) to (c) or which are affected by those matters
3.3
Planning Considerations
3.3.1
New Zealand Coastal Policy Statement
The New Zealand Coastal Policy Statement (NZCPS) took effect on 3 December 2010 and
guides local authorities in their day to day management of the coastal environment. The current
FWWTP site is located near the coast, and while there is no definition or delineation of the
‘coastal environment’ in statutory documentation, the FWWTP site may well be deemed to be
located within the coastal environment, thereby rendering the NZCPS relevant. Resource
consent authorities must ‘have regard’ to the NZCPS when considering consent applications
and Notices of Requirement. The provisions of the NZCPS include both pro-development and
pro-protection provisions which are largely yet to be interpreted in practice. While the way in
which local authorities interpret these ‘at-odds’ provisions is yet to be confirmed through
consent processes, the NZCPS undoubtedly includes much stronger coastal protection
provisions than were previously in place.
It is noted that the Horowhenua District Plan identifies an Outstanding Natural Landscape over
the Manawatu Estuary which extends to the south of the FWWTP (refer Section 3.3.3 below).
HRC’s One Plan defines the extent of the coastal marine area as shown in Figure 4.
13
Figure 4: One Plan Map of the Manawatu Estuary Coastal Marine Area
3.3.2
Operative One Plan
The One Plan, which became operative on 19 December 2014, is a combined plan in the sense
that it comprises both the Regional Policy Statement and Regional Plans. The Regional Policy
Statement section of the One Plan sets out the regionally significant resource management
issues and outlines the objectives, policies and methods that will be used to address the issues.
The Regional Plan specifies the controls on the use of natural and physical resource through
objectives, policies and rules. It is the rules of the Regional Plan that trigger the need for
resource consents.
The One Plan identifies water quality as one of the four big issues into which environmental
enhancement efforts will be focused. The One Plan’s approach for addressing this issue is to
set water quality targets for ecosystems, recreational, cultural and water-use values in
catchments known as Water Management Zones. The One Plan sets water quality targets
within Water Management Zone and Sub-zones.
A number of water related One Plan policies are intended to guide applicants and decision
makers. The most relevant policies relating to this report and any future resource consent
application are identified in Table 2 below.
Policy Ref
Policy 5-3
Policy 5-4
Table 2: One Plan Policies
Policy Wording
On-going compliance where water quality targets are met
Where existing water quality meets the relevant water quality targets,
activities will be managed in a manner which ensures the water quality
targets continue to be met
Enhancement where water quality targets are not met
Where the existing water quality does not meet the relevant water quality
targets, activities must be managed in a manner in order to meet the water
quality targets and / or the relevant values and management objectives that
14
Policy 5-9
Policy 5-10
Policy 5-11
the water quality target is designed to safeguard.
Point source discharges to water
The management of point source discharges into surface water must have
regard to the strategies for surface water quality management set out in
Policies 5-3, 5-4 and 5-5, while also having regard to other matters
including:
• whether it is appropriate to adopt the best practicable option
Point source discharges to land
Including other matters, discharges of contaminants to land must be
managed in a manner which does not result in toxic substances
accumulating in soils or pasture, maximises the reuse of nutrients and water
to the extent reasonably practicable, and results in any discharge of liquid to
land generally not exceeding the available water storage capacity of soil
(deferred irrigation).
Human sewage discharges
On renewal of a consent, existing discharges of treated human sewage into
a surface waterbody must :
i.
be applied onto or into land, or
ii.
flow overland, or
iii.
pass through an alternative system that mitigates the adverse effects
on the mauri of the receiving water body.
When making decisions on resource consent applications for discharging contaminants to water
or land, Policies 14-1 (discharges to water) and Policy 14-2 (discharges to land) requires
Horizons Regional Council to have regard to the appropriateness of adopting the best
practicable option to prevent or minimise adverse effects in circumstances where:
i.
it is difficult to establish discharge parameters for a particular discharge that give effect
to the management approaches for water quality and discharges, or
ii.
the potential adverse effects are likely to be minor, and the costs associated with
adopting the best practicable option are small in comparison to the costs of investigating
the likely effects on land and water.
Policy 14-3 confirms HRC will examine on an on-going basis relevant industry-based standards
recognising that such standards represent current best practice, and may accept compliance
with those standards as being adequate to avoid, remedy or mitigate adverse effects.
When making decisions on discharges to water or land, Policy 14-4 requires the consideration
of utilising alternative discharge options, or a mix of discharge regimes for the purpose of
mitigating adverse effects, and applying the best practicable option. This includes considering:
a) discharging contaminants onto or into land as an alternative to discharging contaminants
into water,
b) withholding from discharging contaminants into surface water at times of low flow, and,
c) adopting different treatment and discharge options for different receiving environments
or at different times (including different flow regimes or levels in surface water bodies).
3.3.3
Horowhenua District Plan
The Horowhenua District Plan is the primary document that manages land use development in
the district. The District Plan is a statutory document which sets the framework of objectives,
policies and methods (including rules) which represent HDC’s and the community’s aspirations
and response to the resource management issues of the district. The District Plan must give
effect to the Regional Policy Statement – the One Plan.
The Proposed District Plan 2013, as amended by decisions, contains provisions which have not
been appealed and therefore are to be treated as operative. These ‘operative’ provisions
include those that would be used to assess any future consent application for Foxton’s
15
wastewater discharges. The Proposed District Plan includes provisions (carried through from
Plan Change 22 to the Operative District Plan) relating to the identification of the district’s
Outstanding Natural Features and Landscapes, and their protection from inappropriate use and
development.
To the south of the current FWWTP (see Figure 5) is the Manawatu Estuary Outstanding
Natural Feature and Landscape as defined by the Proposed District Plan. The extent of the
ONFL (and a Coastal Natural Character and Hazard Area) broadly corresponds with the
delineation of the Ramsar site which overlays the estuary.
District Plan Map 4 confirms the current FWWTP site is zoned Rural and is within a Flood
Hazard Area. The current FWWTP site is also designated (D111) for ‘oxidation ponds’ purposes
in the Proposed Horowhenua District Plan.
Figure 5: Manawatu Estuary Outstanding Natural Feature and Landscape [based on
Horowhenua District Planning Map 40]
Most other sites being considered for land discharge are either zoned Open Space (for
reserves) or Rural within the Foxton Dunefields Landscape Domain. The Rural sites have some
earthworks and building structure controls that are unlikely to restrict any land application of
Foxton’s wastewater. However, any relocation of FWWTP and discharge of treated wastewater
to these sites will require land use resource consent from the regulatory arm of HDC.
16
3.4
Local Government Obligations
HDC has duties and responsibilities in relation to wastewater infrastructure arising from:
• section 130 of the Local Government Act 2002, which requires Council to continue to
provide and maintain wastewater services; and
• section 25 of the Health Act 1956, which obliges Council to provide ‘sanitary works’,
including 'works for the disposal of sewage', if required to do so by the Minister of
Health.
In addition to these specific wastewater requirements, section 10 of the Local Government Act
2002 states that a purpose of local government is to "meet the current and future needs of
communities for good-quality local infrastructure, local public services, and performance of
regulatory functions in a way that is most cost-effective for households and businesses". 'Good
quality' is defined as 'efficient', 'effective' and 'appropriate to present and anticipated future
circumstances'.
17
4 TREATMENT, STORAGE, AND DISCHARGE REGIME
CONSIDERATIONS
4.1
Wastewater Flows and Quality
Incoming raw wastewater is treated in a three stage oxidation pond system. Stage one consists
of a 4.6 ha pond with stages two and three being 0.8 ha ponds respectively. The ponds are
unlined and approximately 2 m deep with a normal operating depth of 1.5 m and a theoretical
working volume of 69,000 m3. The primary pond (stage one) and maturation ponds (stages two
and three) were constructed circa 1970 and 1997 respectively. No screening is provided and
the ponds are aerated naturally.
The average wastewater flow rate through the FWWTP is approximately 1,100 m3/d while dry
weather flow rates are approximately 600 m3/d. The volume of infiltration and inflow (I & I) can
elevate these flow rates. HDC’s monthly wastewater monitoring data for the FWWTP influent
and effluent quality is summarised as median values in Table 3 below.
Table 3: Foxton Wastewater Quality
Parameter
cBOD5
Units
gO2/m3
scBOD5
TSS
Total Nitrogen
Ammonia – N
Nitrate - N
TP
DRP
E.coli
gO2/m3
g/m3
g/m3
g/m3
g/m3
g/m3
g/m3
cfu/100 mL
Influent
500
Effluent
28
Removal
95%
385
59.6
24.8
0.01
8.1
4.3
4.25 x 106
3
74.5
23.8
15
0.1
4.3
2.7
450
81%
60%
40%
47%
35%
4 log reduction
All options for future treatment plant design need to incorporate the need to de-sludge the
existing ponds in order to ensure that their performance is optimised. All designs need to
ensure that the WWTP can cope with the highly variable peak flows that are generated by
Foxton including its trade wastes and storm flows. The discharge regimes need to consider
whether the existing plant design is adequately treating the wastewater for the discharge
method and location sensitivity. It may be necessary to add UV disinfection for example. If the
treatment performance is to be changed then there may be a need to change its foot print.
Electricity will also be required; this is currently not available at FWWTP or any part of
Matakarapa Island.
4.2
Storage Considerations
An undertaking has been given by HDC that there will be no discharge to the Manawatu River
during low flow conditions. To achieve this the treated wastewater must be either discharged to
land or stored for subsequent discharge. If application to land is the preferred option, then there
may be times when the soils are too wet, requiring discharge to water or storage. If a
combination of river and land discharges are to be used then there will be times when the
effluent cannot be discharged to either land or water. Typically this will be in the autumn and
spring shoulder seasons when river flow drops off, yet soil moisture remains high, or possibly in
the case of the FWWTP, then the tide causes limitations.
For a full land treatment scheme with no river discharge the storage must be sized sufficiently to
ensure that under no circumstance the storage is exceeded and there are no discharges to
18
surface water. This requirement for 100 % compliance results in significantly larger storage
than if say a 95 or 99 percentile compliance philosophy were adopted.
4.3
Design Life and Design Codes
The relevant design codes here are the Building Act and the Building Code. Under the Building
Act 2004, as amended by the Building Amendment Act 2013, a “Large Dam” “means a dam that
has a height of 4 or more metres and holds 20 000 or more cubic metres volume of water or
other fluid”, and requires a Building Consent. The height of a dam is defined as “the vertical
distance from the crest of the dam and must be measured,—
(a) in the case of a dam across a stream, from the natural bed of the stream at
the lowest downstream outside limit of the dam; and
(b) in the case of a dam not across a stream, from the lowest elevation at the
outside limit of the dam;..”
New regulations under this Act are due to come into effect in July 2015; these regulations can
be expected to specify safety management requirements. Any new storage facility that may be
constructed would need to be considered against the provisions of the Act and the regulations.
The large storage volume required for a 100% land treatment scheme may fall under the
categorisation of a Large Dam. As such there will be a need to meet stringent minimum design
criteria for storage which relate to seismic design and flooding.
4.4
Full River Discharge
Direct discharge of treated wastewater to surface water is the most common method of
wastewater management in New Zealand. Such discharges are now required to demonstrate
that the nutrient and pathogen impacts will not exacerbate the growth of nuisance aquatic
plants, adversely impact on fish and other biota, and not limit the use of water for contact
recreational purposes.
Further, many iwi find the discharge of municipal wastewater to surface water to be culturally
offensive and abhorrent. In addition there is an increasing perception in the wider community
that surface water discharges should be avoided for social and recreational reasons.
Increasing costs to comply with conditions for direct discharges, in particular nitrogen,
phosphorus and pathogen reduction technology costs, are making the cost to continue direct
discharges more prohibitive for rate payers. This is especially so when having to address
limitations on discharges during low flow conditions in waterways.
4.5
Full Land Discharge
An alternative to surface water discharge is discharge to land. The land is capable of further
treating applied wastewater, with the applied nutrients and water being utilised by crops
(pasture, fodder, trees etc) to improve their growth and yield.
Despite being an alternative, there remain significant limitations to land treatment, particularly in
regard to managing wet weather flows, saturated land conditions and the management and sale
of any crop grown or stock grazed.
Rapid discharge applications to land are a method of achieving land passage for treated
wastewater prior to any possibility of it entering groundwater. It will then be diluted within the
groundwater and ultimately enter either the Manawatu River estuary, nearby drains or coastal
19
lakes, or the Tasman Sea when the groundwater recharges these water bodies through their
beds.
4.6
Combined Land and Water Discharge
Combined land and water discharges (CLAWD) can minimize the adverse impact and improve
the management of water and land discharges. CLAWD systems can be designed to enable the
use of the wastewater resource (water and nutrient) to assist in growth of a crop during low soil
moisture conditions (summer, spring, autumn), while allowing discharge to water where land
application is unsuitable (high soil moisture, low plant uptake). The water discharge component
would be when the impacts on surface water can be demonstrated to be minor (high flows,
cooler temperatures and lower recreational use).
20
5 LAND DISCHARGE CONSIDERATIONS
5.1
Suitability of Land in the Foxton Locality
HDC engaged LEI in 20128 to assess the suitability of land in the vicinity of Shannon, Foxton
and Foxton Beach for development of land treatment systems. The following parameters were
taken into account when assessing the suitability of land:
•
•
•
Soil attributes such as drainage, permeability and the depth to restrictive layers;
Slope and stability; and
Hydrological and hydrogeological attributes such as groundwater mounding risk and
flooding potential.
Compared to the other communities in the Horowhenua district, Foxton has considerable areas
of land in close proximity that are well suited to receiving land treatment of wastewater, primarily
due to sandy soils with high permeability. However, while the land may be able to receive the
wastewater there is also a limitation of many sites having a shallow depth to groundwater (i.e.
drainage limitations).
Figure 6 shows an area with a 5 km radius centred on the FWWTP and includes cadastral
boundaries of each lot.
Figure 6: Foxton Land Treatment Study Area.
Zone A (green) land is predominant. This land is suited to land treatment with theoretically few
limitations, albeit there may be seasonal groundwater limitations. Zone B occupies most of the
remaining land close to the Manawatu River; with this area having the limitations of shallow
8
“Prioritisation of Land for Wastewater Treatment”, LEI, November 2012
21
groundwater, poor drainage and potential flooding. These areas would have to be carefully
managed with wastewater applications.
Even within Zone A land areas, shallow groundwater will often result in reduced suitability
during wetter months. Some pockets of land will be more suited than others, and these are
often irregularly shaped and do not necessarily match or fit within existing property
titles/boundaries. Consequently any land that is considered for use is highly likely to contain a
mixture of soil properties with some areas more or less suited to land application. Site specific
investigations are required to map the variability of key factors and to determine the extent of
suitable land areas on individual properties.
5.2
Potential Discharge Areas and Characteristics
The potential suitability of land for effluent discharges depends not only on the soil attributes,
but also its terrain. Steep sided dunes of variable heights are common throughout the Foxton
area. Such terrain can influence the selection of irrigation designs and can also lead to the
exclusion of some areas. There are also regulatory limitations for reshaping the land, and in
particular the ability to reshape sand dunes.
Areas not in sand dunes are typically flat and are interdunal areas i.e. between sand dunes.
These areas are often lower in elevation and in many cases close to the water table. A feature
of these areas are shallow surface drains, which have been used to assist with controlling the
shallow ground water level. These drains are typically 1 to 2 m wide and 0.5 to 1.5 m deep.
Not only the presence of groundwater, but the orientation of the drains can create limitations for
irrigation design in a land application system.
Land in the Foxton area is low lying and close to sea level. During storm events and periods of
high river flow there is a greater chance of flood water inundating adjacent farm land. A series
of stopbanks have been created to minimise flooding of land in the Foxton area, however
depending on the storm event, and the phase of the tide, land between the stop banks can be
flooded. While flooding doesn’t rule out the use of land for land treatment, irrigation will
obviously not be possible during flooding and infrastructure will need to be protected.
5.3
Land Purchase and Ownership
Ideally the land used for discharging treated municipal wastewater should be owned by HDC in
order to provide certainty of its availability for long-term future discharges. It should also ideally
be located adjacent to or close to the WWTP and the community that the WWTP serves. HDC
already own parcels of land of varying sizes in the Foxton and Foxton Beach locality. Many of
these parcels are recreational reserves or Foxton Beach endowment land that is intended for
future residential development. These areas are generally used by the public and valued for
their recreational or community purposes.
Where land is gazetted as a recreational reserve, its use is governed by the Reserves Act 1977.
HDC’s General and site-specific Reserve Management Plans are required to be adhered to.
Public access is required to be maintained at all times for recreational purposes. Leases may
be granted (and a number have been in the case of Target Reserve), but they must be
consistent with the Reserves Act. Any proposed changes to the Reserve Management Plans
must involve public consultation. Any proposed changes to a reserve’s purpose will also require
public consultation and the Minister of Conservation’s approval. There is no guarantee that a
change to a reserve’s purpose would be successful, and considerable costs and time delays
could result from the process regardless of the final outcome.
22
Should HDC wish to purchase additional land, this will come at a cost that is additional to the
capital expenditure necessary for implementing the discharge infrastructure. HDC could
compulsorily acquire land using the Public Works Act, but this will still involve the payment of
adequate compensation to the current land owner(s).
A lease arrangement for the use of land that remains in private ownership is also an option, but
this would be subject to periodic review and renewal. Land ownership changes could also
increase the risk of future owners being reluctant to renew leases or wishing to change the
lease terms. Conflicts with any existing leases will also require mutually acceptable resolutions.
5.4
Area Requirements
The required land area will vary depending on the application depth of irrigation and the nature
of the system used (e.g. rapid infiltration bed). LEI’s Land and Water Discharge Scenario9
report indicated that anything from 5 ha to 120 ha would be required. A key consideration for
determining the land area is how to manage the winter flows when irrigation demand is less or
non-existent. This period of limitation also typically occurs during a period of high inflows due to
infiltration and ingress, compounding the issue of having to manage high volumes of
wastewater in winter.
If the existing WWTP is not used additional land will be required for storage ponds and even the
WWTP itself. Storage ponds may be necessary for storing treated wastewater when
environmental conditions do not allow land application to occur. LEI’s initial scenarios6
indicated pond storage volumes of 2,000 – 245,000 m3 could be required, depending on the
discharge regime controls.
5.5
Management and Land Tenure
If the land discharge sites are to be grazed by stock, then active management of the stock and
irrigation rotation periods will be required by both HDC and the farmer. A key aim will be to
ensure that grazing areas have had the required resting periods between irrigation and grazing.
It will also be necessary to ensure that soil moisture levels do not result in damage from
waterlogging or compaction by stock. Any cropping or hay-making regime will need to be coordinated with the irrigation schedules to ensure that all activities occur at appropriate times.
If plantation forestry is used for irrigation, forest management will need to integrate with the
irrigation management, including harvest periods. The irrigation system design will need to suit
forestry operations and also be operated to match the hydraulic and nutrient requirements of the
trees.
5.6
Potential for Expansion
The land application area needs to be sufficiently generous beyond the minimum requirements
in order to allow for future population growth, and possibly also for future combination of Foxton
Beach and Foxton wastewater discharges. It would also be desirable so that rotations of land
areas can be more readily managed, and so that additional land can be irrigated if it becomes
apparent that the designs are not sustainable for the environmental conditions.
9
“Land and Water Discharge Scenarios”, LEI, October 2012
23
5.7
Soils (hydraulics)
Free draining sandy loam soils are preferable to finer textured poorly draining clay and peats.
The rate at which moisture drains through soils is critical for determining the depth, frequency,
and return period of irrigation. Soil hydraulics also influence the likelihood and extent of any
groundwater mounding caused by drainage rates that are greater than the surrounding land and
its natural drainage rates of rainfall. Typically soils in the Foxton area are predominately sandy,
however in lower lying wetter areas the soils have a lot of organic material and can be peaty.
5.8
Drainage
Surface drainage is important for management of the land, but it can limit the land areas able to
be used for irrigation. Drainage rates and depths to groundwater are also important factors, as
they can limit the wastewater application rates and seasonal suitability. These are important
considerations in order to protect groundwater from contamination and/or mounding, which in
turn can be necessary to protect nearby surface water bodies from contamination.
Seasonally shallow groundwater is a limiting factor for year round wastewater irrigation in the
Foxton locality. Areas of seasonal ponding or stormwater overland flow paths need to be
designed around or avoided altogether. All areas within flood hazard zones and regularly
inundated should ideally be avoided, but land and irrigation management practices can be
implemented to enable the use of such land areas between any flooding events.
5.9
Buffers and Setbacks
Normal buffer setback distances of 20 m are typically required from all open waterways and
drains in order to protect them from contamination. Where open waterways are common across
a land parcel, the imposition of such buffers can be very restrictive and result in impracticable
land areas (e.g. narrow strips) being available for irrigation.
Much larger buffer distances of 150-200 m are commonly imposed for protecting nearby
sensitive residential activities. This could be a critically limiting factor for the suitability of some
land parcels around Foxton.
Of particular relevance is not only irrigation but also any waste treatment and storage facility.
There will be a perception of its impact and people will want to ensure it is ‘not in their back
yard’. This may extend buffer distance requirements to several hundred meters and as a result
create limitations of locations that can be used.
There is a need to achieve a balance between a site’s proximity to sensitive neighbours
downwind and its proximity to Foxton for minimising reticulation and pumping costs.
24
6 SURFACE WATER DISCHARGE CONSIDERATIONS
6.1
Introduction
All surface waters in the area surrounding Foxton reach the Manawatu River. There are a
number of small drains and waterways, all of which flow towards and into the river. The
sections below focus on the Manawatu River, as that is the sole surface water receiving body in
the area surrounding Foxton.
It should be noted that this section discusses surface water discharges for completeness. As
indicated in previous sections there is a preference (and undertaking) from both the community
and HDC that surface water discharges will not be used. Despite this preference, it may still be
necessary or advantageous to discharge in a manner that allows discharges to enter water after
passing through or over land. The key factors determining the need for this are:
•
•
•
•
•
•
•
6.2
the availability of sufficient land area;
the practicality of constructing suitably large storage ponds and maintaining adequate
pond storage volumes for inflows and storage required during times when land
discharges cannot occur;
suitable river flow conditions such as greater than 20th flow exceedance percentile;
groundwater flow direction towards water bodies from the land discharge site;
proximity (vertically and/or horizontally) of the land discharge site to open waterways;
high seasonal groundwater conditions; and
soil water holding capacity.
Flow conditions
River flow can be described using a range of common terms:
• Half median flow (HMF) – half of the annual median flow below which conditions are
referred to as low flow conditions;
• Median flow (MF) – annual median flow conditions; and
• 20th flow exceedance percentile (20FEP) – higher river flows that exist for 20 percent of
the time.
Typically lower river flows occur in summer and through into April. However, historical river
conditions suggest that low flow river conditions can occur throughout the year, but the
frequency and duration of low flows are less in the winter period. Similarly, high flows can occur,
with extensive flood and high river flows, in January and February, such as in 2004.
6.3
Discharge Location
The current wastewater discharge location is to the western leg of the Foxton Loop
approximately 1 km from its confluence with the Manawatu River, and approximately 9.0 km
upstream of the River’s discharge to the sea. The Manawatu River at the FWWTP discharge
location is subject to a significant tidal influence. It also receives significant influx from coastal
lakes and urban and rural drains, particularly Kings Canal which flows into Foxton Loop at the
junction of Purcell and Harbour Streets. Foxton Loop receives a portion of the outflow from the
Moutoa Floodway when it operates during large storm events.
25
The current discharge is in a reach of the Manawatu River that is part of HRC’s Coastal
Manawatu Water Management sub-Zone (WMsZ)- Mana-13a. River flow statistics that apply to
this site are provided in Table 4.10
Table 4: Foxton WWTP and Manawatu River Flow Rates
Manawatu River
Teachers
Whirokino
Foxton WWTP
College (L/s)
(L/s)
Discharge
(L/s)
Half median
33,317
39,980
Median
66,633
79,960
13
20th exceedance percentile
148,476
178,171
(20 FEP)
6.4
Discharge Rate
The current consent allows for discharges up to 2,000 m3/d which equates to about 23 L/s to the
Foxton Loop. The average wastewater flow rate through the FWWTP of 1,100 m3/d equates to
about 13 L/s, while the dry weather flow rate of 600 m3/d equates to about 7 L/s. this is a small
portion of the total river flow, as indicated in Table 6.3.1.
The discharge rate, directly or indirectly, will largely depend on the discharge Option chosen.
Consideration of any wastewater to surface water discharge will need to consider the rate of
discharge with the river flow to ensure river targets for nutrients are met or not exceeded. The
One Plan specifies a range of water quality targets, with some nutrients more critical than others
under different flow rates. For example below the 20FEP soluble inorganic nitrogen and
dissolved reactive phosphorus are important, whereas above 20FEP ammonia concentrations
are more critical.
6.5
Environmental Values
The Manawatu Estuary is a wetland site that is internationally recognised and protected under
the Ramsar Convention. The Ramsar Convention promotes the conservation and maintenance
of the ecological character of wetlands while also allowing the sustainable development and use
of wetlands by communities. Currently 2,178 sites around the world are listed under Ramsar as
wetlands of international importance. The Manawatu Estuary was registered in recognition of
the diversity of birdlife and fish species, the largest area of saltmarsh in the ecological district,
and the number of archaeological sites of significance to pre-European Maori. Figure 7 shows
the Ramsar area of the Manawatu Estuary.
“Shannon and Foxton Wastewater Treatment Plants: Assimilative Capacity of the Receiving
Environment”, Aquanet, 2012
10
26
Figure 7: Ramsar Area of Manawatu Estuary (Courtesy of Department of Conservation)
6.6
Recreational Use
Many people use the Manawatu River, Foxton Loop, and the lower Manawatu River Estuary, for
both contact and passive recreation. Uses include boating, sailing, kite surfing, water skiing,
paddle boarding, jet skiing, fishing and bird watching. It is an important whitebait fishery
resource, being one of the most significant areas on the lower North Island’s west coast.
Although people in the region use the lower Manawatu River for recreational pursuits all year
round, the contact recreational period typically coincides with the summer time low river flow
periods and diminishes as the river flow increases, and especially during times of higher flows.
6.7
Cultural Considerations
Throughout New Zealand it is recognised that iwi find the discharge of treated municipal
wastewater to surface waters to be culturally offensive and abhorrent. Many iwi state a
preference for discharging the effluent to land to enable contact with papatuanuku (earth
mother) and to protect the waterway’s mauri (life supporting capacity).
The Manawatu River has been a significant food resource for Maori. There are also many sites
of significance (both Maori and early European) on both banks of the Manawatu River between
Opiki and the Tasman Sea. In particular, Matakarapa Island and Foxton area have a large
number of significant sites.
6.8
Discharge Effects
In 2013 Aquanet Consulting Limited prepared a report that considers the Manawatu River’s
potential to receive wastewater (assimilative capacity) based on river flow11. The following
“Shannon WWTP: Assimilative Capacity of the Receiving Environment”, Aquanet Consulting
Ltd, 2013.
11
27
assumptions have been used in the assessment of the assimilative capacity of the Manawatu
River at Whirokino near the current point of discharge for the FWWTP.
•
•
•
The river flow at Whirokino is assumed to be the equivalent to Teachers College + 20%
(an approach that is used and recommended by HRC);
Periods of slack water and/or flow reversal due to tidal influence increases as river flows
decrease; and
When the background water quality is worse than the targets, the assimilative capacity is
calculated as the amount of treated wastewater that can be discharged so the discharge
does not cause any increase in concentration in the receiving environment of more than
the detection limit for the given constituent.
The assimilative capacity of the river can be defined by the amount of a given contaminant a
river can receive at a given point in space and time without compromising the river’s values,
either solely or cumulatively with other discharges. At a given point (e.g. a discharge point) the
total assimilative capacity of a flowing waterbody in relation to each contaminant will vary in
time, depending on the volume of receiving water available for dilution. The direct implication is
that the assimilative capacity of a river should not be seen as a constant quantum. However,
for simplicity assimilative capacity is often described based on a flow band or averaged over a
year.
Aquanet found that there is some assimilative capacity in the river at Whirokino at all flows. The
assimilative capacity availability increases with river flow rate. Based on the current wastewater
discharge composition, the volume of wastewater that could be discharged within the calculated
assimilative capacity remains below the average FWWTP discharge volume until the flow in the
river reaches approximately 150,000 L/s. Flows above this occur approximately 25% of the
time. This means that below this river flow rate some of the wastewater should be discharged to
other receiving environments (e.g. land) and/or stored for later discharge.
In December 2013 Cawthron Institute12 assessed the assimilative capacity of the Manawatu
Estuary under various river flow rate regimes and tidal phases. Cawthron reviewed HRC
monitoring data for Whirokino in each river flow rate band and compared the data with the One
Plan target or trigger values for each relevant contaminant. Cawthron found that upstream
sources of contamination had already exceeded the One Plan target values before it reached
Whirokino. This means that limited assimilative capacity is available in the Manawatu River for
Foxton’s discharges and predominately on outgoing tides. Cawthron noted that flows and
assimilative capacity within Foxton Loop were different from the main stem Manawatu River,
and Foxton Loop was unlikely to have adequate assimilative capacity for Foxton’s WWTP
discharges. Cawthron also noted that Foxton’s discharges only constitute 0.02% of the total
flows through the Manawatu Estuary, so any effects attributable to its discharges are unlikely to
be significant overall.
“Foxton Wastewater – Estuary Assimilative Capacity Assessment. Report No. 2440”, Cawthron
Institute, 2013
12
28
7 SITE IDENTIFICATION
7.1
Process
As a result of the 1997 Foxton wastewater consenting process HDC started considering land
application options. Submissions on consent applications in the last 25 years have indicated a
preference from the community that land application be utilised for discharges from the
FWWTP.
As a result of consent requirements, HDC have investigated the feasibility of utilising a number
of areas for land application in the last 10 years. These areas have been highlighted along with
their pro’s and con’s in various reports prepared for and by HDC.
Since 2013, HDC has sought to actively engage with iwi and interested parties in order to gain
improved mutual understanding of every party’s key concerns and values as well as hoping to
agree on a site and discharge methods that are widely acceptable to the community and HDC.
The reports that have been prepared to date are summarised in the following section.
7.2
Key reports
7.2.1
2009/10 Land disposal site identification and consultation
HDC and MWH undertook a desktop study of HDC owned parcels of land and some privately
owned land in the Foxton and Foxton Beach locality. There was consultation with various
interested parties for their views on preferred land treatment sites. Two sites on Matakarapa
Island and one near Foxton Beach WWTP were recommended for further assessment and
consultation.
13
7.2.2
2011/12 Strategic Water & Wastewater Review and Long
Term Plan
GHD14 assisted HDC with a district wide review of WWTP assets and identified a number of
concerns with the FWWTP site. They recommended closure of FWWTP and combining it with
the Foxton Beach WWTP in response to these concerns. The 2012/22 LTP provided funding for
implementing this.
7.2.3
2012/13 District Wide Land Application Strategy Reporting
Beca and LEI assisted HDC develop a strategy for implementing land treatment of
Horowhenua’s wastewater. This involved a number of reporting outcomes, including:
• Land assimilative capacity report15: LEI prepared a summary of the potential for utilising
land to apply wastewater, identifying limiting parameters of factors such as nutrient,
hydraulic and management limitations.
• Land prioritisation report16: LEI prepared a report identifying land areas that were more
suitable than others based on soil limitations, drainage properties, flooding potential and
a range of other parameters.
“Foxton Wastewater Land Based Disposal Options Study – Progress Report for June 2010”,
MWH, June 2010
14
“Report on Strategic Water and Wastewater Review”, GHD, December 2011
15
“Assimilative Capacity of Land Near Shannon, Foxton and Foxton Beach”, LEI, September
2012
16 “Prioritisation of Land for Wastewater Land Treatment”, LEI, November 2012
13
29
•
•
River assimilative capacity report17: Aquanet Consulting prepared a report which
investigated the assimilative capacity of the Manawatu River and Foxton Loop for
contaminant discharges.
Land and water discharge scenarios18: LEI prepared a report summarising the
predictions of preliminary modelling of various combinations of land and water discharge
scenarios for Shannon, Foxton, and Foxton Beach WWTP’s. This report estimated the
discharge volumes, land area requirements, and pond storage requirements for each
combination.
7.2.4
2013 Cawthron Institute Estuary Assimilative Capacity
Assessment
Cawthron Institute19 reviewed existing information and prepared a summary which considered
the potential to utilise the Foxton Loop and the Manawatu River for wastewater discharges.
This determined that the Manawatu River has limited assimilative capacity, if any, at the estuary
due to upstream contamination sources causing the One Plan’s water quality targets to be
exceeded under some or all river flow rates. Despite this conclusion, Cawthron determined that
the FWWTP formed only 0.02% of the flows into the Manawatu estuary and that it could be
acceptable to discharge during outgoing tides, particularly when river flow rates exceed 20FEP.
7.2.5
2014 Broad Option Assessment of Discharge Options
Beca and LEI prepared a review of wastewater discharges20, summarising information available.
This included a brief review of land investigation options and the receiving environment, and
presented a number of options for the location of the FWWTP and its discharge. Specific sites
assessed included Foxton Beach WWTP, Matakarapa Island, Waitarere Forest, Foxton landfill
transfer station site, and the Newth Road area south of Foxton. Specific discharge scenarios
assessed included Foxton Beach WWTP treatment and discharge, full river discharge,
combined river and land irrigation discharges, and full land discharge to forestry or pasture at
non-deficit and disposal rates. Each potential discharge regime was assessed for suitability,
advantages, design requirements, and constraints at each location.
The report recommended ceasing the current river discharge and recommended further
investigation of land discharge or combined land and water discharge based at Matakarapa
Island. Alternative favourable options for land discharge were identified at Waitarere Forest and
north of Foxton Beach. The use of Foxton Beach WWTP was not supported for treatment or
discharge of Foxton wastewater.
7.2.6
Property Valuation Reviews
Two separate property valuation reports prepared in May 201321 and March 201422 considered
various potential sites in the Foxton area.
The May 201310 report assessed the likely ranges of land values and rental values per hectare
for several categories of land. This was a broad study of pastoral and forestry blocks around
“Shannon and Foxton Wastewater Treatment Plants: Assimilative Capacity of the Receiving
Environment”, Aquanet, September 2012
18 “Land and Water Discharge Scenarios”, October 2012
19
“Report No 2440. Foxton Wastewater – Estuary Assimilative Capacity Assessment”, Cawthron,
December 2013
20
“Foxton WWTP Discharge Broad Option Assessment”, Beca, 2014
21
“Foxton Rural Land Valuations”, Morgans Property Advisors, May 2013
22 “Initial Scoping Report: Foxton Wastewater – Land Based Disposal”, Total Property Strategies
NZ Limited, March 2014
17
30
the Waitarere, Koputaroa, Motuiti, Whirokino, Foxton, and Foxton Beach areas. It indicated that
the lowest value land was forestry on sand country, including Waitarere Forest.
The March 201411 report assessed a small number of specific properties for their suitability for
land discharge of Foxton’s wastewater. The key criteria were location, land area, land use, and
seasonal groundwater conditions. The Knight and Jarvis properties on Matakarapa Island, FRP
property on Palmer Road immediately west of Foxton Beach WWTP, Waitarere Forest, and
Easton Farm on Oturoa Road were assessed. It concluded that the most likely feasible sites
were the two Matakarapa Island properties and Waitarere Forest.
7.2.7
2014 Review of Environmental Data
In 2014 LEI reviewed the available environmental data relating to the FWWTP and Manawatu
estuary. The report23 concluded that FWWTP discharges did not appear to be the sole cause of
poor water quality changes in the Foxton Loop, which has sources of contamination that have
already degraded its water quality and are independent of the Manawatu River sources. A key
finding was the water quality in the Foxton Loop was often worse than that being discharged
from the FWWTP.
7.3
Focus Group Reports
7.3.1
Background
HDC initiated and coordinated a community focus group process to canvass community
preference for various discharge sites. This process is discussed in Section 8 below. The
process saw the preparation of a number of small reports, which are described below.
7.3.2
Preliminary Feasibility Study of Matakarapa Island and
Target Reserve, April 2014
LEI reported on the preliminary feasibility of using Matakarapa Island and Target Reserve for
land treatment. Four conceptual options were outlined and assessed for their suitability under
environmental, social, cultural, and financial criteria. The options assessed were:
1. Matakarapa Irrigation, involving the use of the existing WWTP and irrigating the entire
treated wastewater outflow onto land near the WWTP;
2. Matakarapa Irrigation and Rapid Infiltration, with a reduced irrigation area and the use of
rapid infiltration beds to be constructed on site;
3. Target Reserve, involving constructing a new WWTP, irrigating the entire treated
wastewater outflow onto land at Target Reserve, and decommissioning the existing
WWTP; and
4. Target Reserve, Matakarapa WWTP, involving the ongoing use of the existing WWTP,
but pumping the entire treated wastewater outflow to Target Reserve and irrigating it
onto land there.
7.3.3
Preliminary Investigation of Target Reserve, June 2014
This preliminary investigation report prepared by LEI indicated that Target Reserve is currently
constrained in its ability to be used for storing and irrigating treated wastewater by:
• its reserve status and associated Reserve Management Plans;
“Summary of Existing Environmental Data for Foxton Wastewater Treatment Plant”, LEI,
August 2014
23
31
•
•
•
•
•
active public use of most of the southern two-thirds of the Reserve;
leases authorising and protecting specified uses of a large proportion of the Reserve;
the moderate number of fairly close rural-residential neighbours;
its proximity to Round Bush Reserve, the Foxton Lakes, and potentially other sites of
significance to iwi within Target Reserve and nearby; and
shallow groundwater and drains, particularly within the grazed northern portion.
Significant investment in reticulation infrastructure would be required, and a possible relocation
of the WWTP to Target Reserve. If the existing land used was to be maintained then a higher
degree of treatment would be required.
The legal issues form one of the most complex and difficult hurdle to utilising Target Reserve.
Modifying the terms of the relevant leases, potentially excluding public access to parts of the
reserve, and changing the Reserve Management Plans require significant legal processes and
public consultation processes to be successfully completed.
7.3.4
2014
Preliminary Feasibility Study of Darleydale Farm, June
Darleydale Farm, located between Wall Road and Motuiti Road north of Foxton, is a potential
site for discharge and possibly also the WWTP itself. The significant distance from Foxton and
its substantial reticulation cost on top of the purchase price for the land was seen as a road
block for using this site. Relocating the WWTP would further increase the costs. Seasonally
high groundwater could be a limiting factor for this property.
7.3.5
Preliminary Conceptual Design Feasibility Study of
Matakarapa Island and Target Reserve, June 2014
Target Reserve was tightly constrained by land availability and did not have potential for
including Foxton Beach wastewater flows in future. It also faced serious legal difficulties due to
its reserve status and lease arrangements. Financial considerations and sensitive receiving
environment were also important. Matakarapa Island was constrained by cultural and heritage
considerations as well as its proximity to the environmentally and recreationally sensitive Foxton
Loop and Manawatu estuary.
7.3.6
Waitarere Forest Preliminary Feasibility, August 2014
LEI’s preliminary feasibility report on the use of Waitarere Forest identified that it was a good
environmental solution, but the route of the pipeline would determine whether it was an
economically feasible option. The most direct route requires drilling beneath the Manawatu
River and traversing flood control and esplanade reserve lands. The alternative routes follow
roads and would probably be economically unaffordable. A further disadvantage of this site was
the opposition of the forest leaseholders and potentially also the cultural insensitivity of using
land that is being held by the Crown for Treaty of Waitangi claims settlements. In addition,
relocating the FWWTP from its current location would add further costs.
7.3.7
Koputaroa Road Preliminary Feasibility, September 2014
LEI’s brief preliminary feasibility report on the use of the Guy Farm on Koputaroa Road
identified that the land was low-lying with a complex network of shallow drains. There was also
flood hazard concerns. It was also economically unaffordable due to its distance from Foxton
and the need to cross the Manawatu River.
7.3.8
Motuiti Road Preliminary Feasibility Study, February 2015
A feasibility assessment of land on the south eastern side of Motuiti Road identified issues
similar to the Darleydale Farm assessment. The key limitation on its feasibility will be the
distance from Foxton, as it is further east along Motuiti Road than Darleydale Farm. The terrain
32
is generally more elevated and variable than Darleydale Farm and contains significant relatively
steep and high dunes. There are a number of surface drains which discharge to the east into
the Manawatu River.
33
8 CONSULTATION
8.1
Strategy
While there is no duty to consult under the Resource Management Act 1991 (RMA),
consultation with stakeholders and the community results in a more complete and robust
assessment of options available. It also facilitates better community and stakeholder
relationships in the longer term. A renewed focus on engaging with its community has been a
key driver for HDC in recent times.
Consultation with stakeholders and the community has been an integral part of the process to
identify a best practicable discharge site, and ultimately impact on the success of any future
consent application process. While some of this engagement has been clearly driven by
previous consenting decisions, HDC have sought to be proactive in engaging with the
community with this site identification project.
The Project timeframe (i.e. the current resource consent expiring 1 December 2014 and the
need to lodge a long term renewal consent within approximately 16 months of the short term
renewal consent being lodged) dictates that a focused and targeted approach to consultation is
needed for this Project.
To ensure a robust and meaningful consultation process is delivered; a multi staged approach
was established:
1. Establishment of a Focus Group to assist HDC with the development of potential
discharge options, optioneering of the options developed, and selection of a preferred
long term solution – the best practicable option;
2. Technical and cultural consultation on the best practicable option; and
3. Wider community engagement post option selection to refine the long term solution.
8.2
Historic
In the last 15 years, and prior to the last two, consultation focused around HDC setting Long
Term Plans and as part of consent renewals. Both processes sought input on a solution, with
limited involvement on the development of the solution.
Community and interest group involvement was largely limited to submissions on resource
consent applications and LTP proposals. There was limited input and consultation with Tangata
whenua and there was no or limited effect given to any Memoranda of Understanding
processes. Statutory Parties, such as HRC, the Department of Conservation and the District
Health Board were consulted as a matter of default in the recent consenting processes.
The current resource consent specifies parties to be consulted about the site and discharge
methods to be used in future proposals. The listing of these parties comes from the list of
submitters to the 1997 and 2009 resource consent processes.
In early 2009 HDC consulted directly with the nominated parties (Manawatu Estuary Trust,
Tanenuiarangi Manawatu Incorporated, Ngati Raukawa, Horizons Regional Council, and Public
Health). They also consulted with neighbours to the HDC properties and reserves identified as
potential discharge sites. The responses to this consultation was mixed, and no site had
unanimous or majority support from the parties that replied. MWH prepared a report (see
Section 9.2.1) which summarised the outcomes and recommended further investigation of
Matakarapa Island and land near Foxton Beach WWTP as the most favoured options.
34
8.3
Recent
Recent community consultation has involved the formation of a Focus Group with a cross
section of community members. The Focus Group process is summarised in Section 8.4 below.
Other community consultation has included the 2012-22 LTP process and discussions about
affordability with the Foxton Community Board.
The development of the Focus Group has allowed the inclusion of a range of interest groups,
such as Save Our Rivers Trust (SORT), The Manawatu River Estuary Trust, Fish and Game
and Water Environment Care Association (WECA).
The District Health Board and Department of Conservation have had an involvement in previous
consultation, but this has been though previous consenting processes. More recently their
involvement has been through the Foxton Focus Group.
8.4
Focus Group
8.4.1
Overview
The Foxton Focus Group, membership of which includes statutory and non-statutory agencies
and representatives of the community at large, was initiated by HDC. This was in response to a
commitment to engage with the local community to develop long term options for the Foxton
wastewater discharge solutions.
The Focus Group was formed to provide a common platform where the views of the entire
community and all other interested stakeholders could be represented in the process of
identifying and choosing the best practical option for the Foxton Wastewater scheme. It was
intended to be a sounding board for advice and direction on important matters related to
choosing the best practical wastewater discharge option and the subsequent preparation of the
associated resource consent application(s).
The Focus Group approach was a change from the traditional consultation and engagement
methods of Council on projects of this nature. A driver behind the formation was the logic that
by engaging the Focus Group in the process at this early stage, it would potentially help
streamline the consultation process associated with the resource consent application process.
The logic being that much of the information would be made available to stakeholders through
the Focus Group process and therefore before the lodgement of any consent application.
Learning from the recent experience of the Shannon Wastewater project it was recognised that
early involvement of stakeholders in the process would be important to the overall success of
the project.
A series of evolving meetings were held with the Focus Group, commencing in February 2014.
This included guiding the group through a process of understanding the issues required to
develop a sustainable wastewater system for Foxton and allowed members to share and
understand values regarding wastewater management held by all people and parties involved in
the group. In addition to the members sharing their values and objectives, a number of
summaries and reports were prepared by the HDC project team and presented to the group.
The aim of these reports was to provide preliminary advice on the feasibility constraints and
opportunities for using a number of sites for treatment and/or discharge of Foxton’s wastewater.
A summary of the meetings is detailed below; the associated reports are summarised in Section
7.3 above.
8.4.2
Membership of the Focus Group
The initial invitation to attend the Focus Group was with the intention of keeping the group to a
manageable size. Identified stakeholder groups were invited to send a single representative to
attend the meetings. The composition of the original Focus group invited was:
35
•
•
•
•
•
•
•
•
•
•
•
•
•
Mayor and 2 Councillors (Elected Members)
2-3 Members of the Foxton Beach community nominated by the Foxton Community Board
2 Council Officers
Foxton Wastewater Scheme - Technical Expert
Horizon Regional Council Officers
Representatives from the Local Iwi (Rangitane, Ngati Raukawa, Muaupoko and Ngati Apa)
A representative from WECA
A representative from Save Our River Trust (SORT).
A representative from Department of Conservation (DoC)
A representative from Fish and Game
A representative from the High Users – Turks
A representative from Manawatu Estuary Trust
A representative from Public Health Unit (Mid Central Health)
Requests were received from some groups for addition members to also attend the meeting as
support personnel. These requests were granted. As the Focus Group meetings progressed
the attendance and membership of Focus Group varied with new members attending at the
request or suggestion of those already involved. In most cases once someone had attended
one Focus Group meeting and provided their contact details they were invited to attend future
meetings. The changing mix of attendees at the meetings, was particularly noticeable for those
representing Iwi.
A consequence of this change in membership was that the Focus Group lost the balance of
being a representative group and ruled out the ability to fairly use the group for any voting
processes. A further impact of this was the differing knowledge base of those attending the
meetings. Members who came to the first meeting and attended all the meetings and received
the reports and information has a very different level of understanding to those who only came
to the last one or two meetings.
The overall purpose of the group was to start at the beginning of the option identification
process, taking members through the various option identification and evaluation steps before
recommending an option to be presented to the Foxton community Board and Council.
Through the Focus Group process Iwi were invited to be involved. An inclusive approach was
taken with the invitation to Iwi to send representatives to attend. In the case of Ngati Raukawa
and their local hapu in the Foxton area, Council Officers arranged with Iwi members that the Iwi
would be responsible for extending the invite to interested/affected Iwi and hapu. There was
representation from Ngati Raukawa, Ngati Whakatere, Rangitane and Muaupoko Tribal
Authority. Although the wastewater treatment plant project was of interest to all Iwi and hapu
associated with the Manawatu River, through the consultation process Ngati Whakatere
identified themselves as having a historic association with the land on Matakarapa Island.
In addition to being invited to be part of the Focus Group, Iwi were provided with opportunity to
meet directly with Council Officers in a parallel engagement process. During the consultation
process it was decided that a number of the sites being considered has special relevance and
significance to iwi and they were given an opportunity to collectively report to the Focus Group
on their view for a preferred site for managing wastewater. This process is summarised in
Section 8.5 below.
Despite being invited Ngati Apa and the Muaupoko Cooperative Society chose not to attend the
Focus Group meetings. They have continued to be sent information about the project and
Focus Group meetings.
36
8.4.3
Focus Group Meeting Summary
Meeting 1: 13 February 2014 meeting – Horowhenua District Council Chambers:
Purpose
The purpose of this meeting was to set the scene, introduce all participants to each other,
outline the purpose and terms of reference for the Focus Group, and discuss the process of
engagement between HDC and the Focus Group.
Content
The meeting assumed a zero knowledge base for those attending about wastewater
management and the Foxton context. The current FWWTP was described and its criteria for
future design were presented. The presentation included HDC’s historical efforts with
investigating land discharge options for the FWWTP and the likely key issues regarding
selection of WWTP location, design, and discharge methods and location. Broad areas of land
that were potentially suitable for land treatment of FWWTP discharges were mapped as a
discussion starter. The Focus Group discussed details of the engagement process, design
details of the current FWWTP, and broad environmental effects of land versus water
discharges.
Outcomes
The Focus Group approved of the suggested approach and agreed to participate.
Meeting 2: 2 March 2014 meeting – Te Whare Manaaki:
Purpose
For this meeting an independent facilitator (Virginia Baker) was specifically brought into run the
meeting and impartially facilitate the identification of the key values and issues for determining
the preferred site and discharge method for any WWTP upgrade. The purpose of this meeting
was to brainstorm and then collectively rank the key values and issues for determining the
preferred site and discharge method for any WWTP upgrade using environmental, social,
cultural, and financial criteria. Another purpose was to survey the Focus Group’s initial
preferred treatment and discharge sites.
Content
The Foxton Focus Group identified and ranked their key values and issues relating to the
current FWWTP location and its discharge, as well as the values behind their preferences for
future changes. The discussions subsequently centred on the suitability and key issues for
Matakarapa Island and Target Reserve as the most preferred sites.
Outcomes
Land based treatment and discharge was the preferred option for Foxton Focus Group
members. All iwi preferred Target Reserve, while most other Focus Group members preferred
Matakarapa Island. The Focus Group requested HDC to prepare a preliminary feasibility report
on land treatment options at Matakarapa Island and Target Reserve.
Meeting 3: 8 April 2014 meeting – Te Whare Manaaki:
Purpose
The purpose of this meeting was to present and discuss LEI’s report on the preliminary
feasibility of using Matakarapa Island and Target Reserve for land treatment.
Content
The options preferred by LEI were based at Matakarapa Island, primarily because of financial
implications of any Target Reserve system. However, some members of the Foxton Focus
37
Group were strongly in favour of Target Reserve primarily due to cultural and environmental
concerns with Matakarapa Island.
Outcomes
There was a strong division of preferences for and against both Matakarapa Island and Target
Reserve. HDC were requested to provide the next meeting with a summary of previous
consultation on all potential sites.
Site Visit: 13 May 2014 - Matakarapa Island
Purpose
Based on information shared in previous meetings about the previous use and cultural
significance of Matakarapa Island a hui to the Island was organised for those interested.
The area surrounding the WWTP was viewed and as well as the location of the old church on
the northern part of this Island.
The visit allowed those attending to put the significance of the site in perspective, including the
size of the dunes, proximity to the Foxton Loop and Foxton itself.
Meeting 4: 20 May 2014 meeting – Horowhenua District Council Chambers:
Purpose
The purpose of this meeting was to review the outcomes of HDC’s previous consultation on
potential WWTP and land discharge sites, and to progress the Focus Group’s preferred options.
The meeting was also to provide an update on the Iwi consultation that had been undertaken
and provide Iwi this opportunity to present the cultural history and values associated with
Matakarapa Island.
Content
HDC provided a summary of previous consultation on all potential sites, and LEI’s preliminary
feasibility report on using Matakarapa Island and Target Reserve was presented and discussed
further. At this meeting Iwi were invited to present the cultural history and values associated
with Matakarapa Island. Te Kenehi Teira gave a detailed account of the historical use of the
island and the associated cultural values. The presentation referred to a map Te Kenehi had
compiled identifying cultural sites of significance.
Outcomes
The Focus Group requested HDC to undertake a further desktop assessment of Target Reserve
and to consider other sites.
Meeting 5: 6 June 2014 meeting – Te Whare Manaaki and Site Visit to Target Reserve:
Purpose
The purpose of this meeting was to present and discuss preliminary investigation reports on the
feasibility of land discharges and/or relocated WWTP to Target Reserve and Darleydale Farm
(located between Wall Road and Motuiti Road north of Foxton). The meeting followed a site
visit to Target Reserve.
Contents
The Target Reserve preliminary investigation report was presented to the Focus Group. A
preliminary feasibility assessment of Darleydale Farm, located between Wall Road and Motuiti
Road north of Foxton, as a potential site for discharge and possibly also the WWTP itself.
Outcomes
38
The Focus Group agreed to no longer pursue Darleydale Farm as an option due to its distance
from Foxton and overall cost. The Focus Group requested HDC to reconsider Target Reserve
and Matakarapa Island as well as more seriously considering conceptual design options for
these sites.
Site Visit: 10 June 2014 - Wastewater Treatment Tour
In an effort to help Focus Group members develop their understanding of different types of
effluent land discharge systems a bus tour to a variety of wastewater treatment systems was
organised. The tour provided the opportunity for Focus Group members to see the different
systems operating and have them explained. The tour included visits to the following sites:
•
•
•
•
•
•
•
•
•
Levin Wastewater Treatment Plant’s land treatment site known as The Pot (Hokio Sand
Road, Levin)
Foxton Beach Wastewater Treatment Plant
Himatangi Beach Wastewater Treatment Plant
Sanson Wastewater Treatment Plant
Feilding Wastewater Treatment Plant
AFFCO Feilding meatworks wastewater land treatment site
Tui Brewery wastewater land treatment site, Mangatainoka
Fonterra Pahiatua wastewater land treatment site
Masterton Wastewater Treatment Plant (Homebush)
In addition, the Riversdale Wastewater Treatment Plant’s land treatment site was described and
discussed. It was not possible to visit this site due to insufficient available time on the day of the
tour.
Meeting 6: 19 June 2014 - Horowhenua District Council Chambers:
Purpose
The purpose of this meeting was to present and discuss conceptual design assessments for
land discharges onto Target Reserve and Matakarapa Island. The intention was to outline the
options being considered, check that nothing had been missed and provide an opportunity for
the Focus Group members to share their perspective on these options.
Contents
The conceptual design assessments for Target Reserve and Matakarapa Island were discussed
and the Focus Group debated the pros and cons of each option.
Outcomes
The Foxton Focus Group were approximately evenly split with their preferences for and against
each site. The Focus Group requested the consideration of Waitarere Forest as another
potential option.
In reminding the Group of the need for Council to lodge a consent application with Horizons by
September, the Group pleaded with Officers to seek an extension from Horizons. It was felt that
more time was needed before a site could be selected. The cultural concerns identified with
Matakarapa Island needed to be weighed up and considered further. Iwi requested more time
to be able to consider these impacts and to investigate alternative sites. The meeting
concluded with Officers committing to exploring options with Horizons to provide additional time
for this process and in particular further considerations of the cultural considerations.
39
When confronted during this meeting with statutory time limitations of needing to lodge a
consent application with HRC to allow the existing FWWTP to continue legally discharging, the
Foxton Focus Group unanimously supported the lodging of an application for a short term
continuation of the existing discharge to Foxton Loop in order to meet the need for more time to
facilitate the identification of a long term solution.
Meeting 7: 8 December 2014 meeting - Manawatu College Hall:
Purpose
The purpose of the meeting was to provide an update on the progress since the previous Focus
Group meeting in June, in particular an update on the lodgement of the short term consent with
Horizons. The intention was for this to be the final Focus Group meeting for the site selection
phase of the project and if possible for a single preferred site to be identified.
The meeting was also the opportunity for Iwi to provide feedback on the series of hui that they
had held since the meeting in June.
Contents
The Focus Group were provided with a recap of the process and key matters considered so far
including an update on the short term consent application lodged with HRC.
A presentation by Robert Ketu, Peter Hirawani and Willy McGregor was made explaining the
Poutu model of wellbeing and concluding by stating that Iwi did not support discharging to
Matakarapa Island or Target Reserve. Several members of the Focus Group spoke offering
alternative views.
At the end of the meeting the Focus Group was reminded of the timeframes Council was
committed to working towards. In recognising that there was not a single shared view on the
preferred site by the Focus Group, the Focus Group members were then provided with a form to
take away with them and complete allowing them to identify their preferred option and providing
reasons for their selection. Focus Group members were asked to provide their responses to
Council to inform this report.
Outcomes
The feedback and preference on suitable sites is presented in Section 8.4.2 below.
8.4.4
Post-meeting Preference Feedback
During the 8 December 2014 meeting all Focus Group members were asked to record on a
feedback form their overall order of preference of discharge site and their reasons for and
against each site. The form was completely open for each member to nominate their top three
choices of site; no prompts were presented as potentially acceptable or unacceptable sites. A
range of responses were received reflecting the very mixed opinions and preferences within the
group. The following comments highlight the range of responses received:
WECA
-preferred Darleydale Farm for the following reasons: “WECA has visited all
the sites that have been raised in discussion - Darydale Farm - Wall Road
is the only available site that meets all our criteria, is available to HDC, is
not under development, has no known cultural issues, and has room for
ponds, irrigation and future expansion. The soil type is ideal, there is power
adjacent to site, and there is good road access. Looking ahead, the site is
large enough to accommodate Foxton Beach sewerage if required. The
only obvious drawback is distance from Foxton (Cost) but similar distance
from Foxton as Target Reserve is.”
40
Viti Taylor
-objections to the use of Matakarapa Island included the following
comments: “Affects our river, our Kaimoana, estuary at Foxton Beach. Te
Urupa and our tupuna are our treasure. A very important historical and
cultural site on Matakarapa. My mother Winiwini (Paora) Chambers was
raised up on the island. My father-in-law, Wen Taylor also had a strong
connection with Matakarapa.”
Dr R Hoskins
-described his extensive involvement in environmental restoration of the
Foxton area and listed a large number of reasons why he believed
Matakarapa Island was the only logical choice for future treatment and land
discharges of Foxton’s wastewater. A selection of his reasons are as
follows: “Whilst all nutrients may not be removed by plants, ultraviolet light
from the sun would deal to the E. coli and the sand of the island would at
least be a filter before any waste reached the water table or the river. This
would be a win for growing any kind of plants in the dry summer months
and a win for the river.” “There is sufficient land away from the few Urupa
that are known. There is sufficient land on Matakarapa Island to irrigate
treated waste water. There is sufficient land significantly above flood level
for the purpose of land irrigation. There is sufficient room for expansion of
the treatment ponds if Foxton has a population boom.”
Robert Warrington -“None of the options put forward would be described as preferable for
varying reasons” and provided the following comments supporting this
stance: “None of the options would ever be preferred until Maori Taonga
are protected, this includes Urupa and the fishery. Works such as a
wastewater facility are obtrusive to papatuanuku. An equal value of
restoration work should be implemented elsewhere. Put another way, you
can place it where you like BUT protect the Taonga entirely (both physically
and spiritually), and provide utu for the imbalance to papatuanuku. If that
means finding another site because protection is not akin to guaranteed,
then so be it.”
Heeni Collins
-“All hapu oppose the continued treatment of wastewater on Matakarapa.
Further options should be investigated such as south of Motuiti Road.”
F&G
-Wellington Fish and Game preferred Target Reserve for the following
reasons: “Due to the over allocation of the Manawatu River from a
cumulative perspective and by discharging to land this option seems the
most appropriate in terms of our policy to advocate for Hunters and anglers
within the region. There have been many success stories of waste water
irrigation to many high ranking golf courses around the world and WFG see
no reason this same strategy cannot be applied in this context. The con
here is obviously the cost to the community.” Their comments in relation to
Matakarapa Island were as follows: “we believe there would need to be far
greater discussion on this as there seems to be a lot of ambiguity
surrounding the process of utilising the area. The obvious pro here is the
already established ponds, and the removal of the discharge from the loop,
however what is the flood potential?”
Christina Paton
-preferred Darleydale Farm, and gave the following reasons: “Area enables
complete re-location of treatment plant, and ponds. Ample area for landbased disposal… Manawatu River not compromised. No known Iwi
conflicts. No known recreational conflicts. Separate from residential zones.
Excellent access - roading power supply. Potential to be processed as a
non-notified consent and no appeals - that is a significant saving.”
41
Table 5 summarises their responses (in no particular order).
42
Table 5: Focus Group Post-meeting Preferences
Most Preferred Key Reasons Given in Responses
Site
Darleydale Farm
Meets all criteria. There is no sensitive development nearby, no cultural
or recreational issues, plenty of land area, available for purchase.
Matakarapa
Most realistic cost, sufficiently isolated from town while also not too far
Island
away. Existing infrastructure and plenty of land available. Can readily
avoid sensitive sites and flood hazard. Potential for restoration of
heritage sites as well as environment. Could link to tourism opportunities.
Target Reserve
Irrigation of golf course has been successful internationally. Could assist
with extension of native biodiversity. Not too distant from existing WWTP.
Manawatu River is over allocated for contaminant discharges.
New unidentified Matakarapa Island has family heritage significance (including urupa and
site (other than parents previously living there), flood hazard, and pollutes Manawatu
identified)
River which is a source of kaimoana and should be avoided.
While a number of responses indicated a very strong desire not to use Matakarapa Island, no
alternative was volunteered in many of the submissions opposing Matakarapa Island. Some
land south of Motuiti Road was mentioned by two participants, but not precisely identified. The
preference of not using the island is fully appreciated and understood by the HDC project team,
but not identifying an alternative does not assist the decision of a preferred site. However, it
does highlight the conundrum facing HDC in making a decision, in that while it is easy to
say no, it is hard to find a site to collectively say yes to.
8.4.5
Preferred Approach from Focus Group
As the Focus Group process evolved and various reports were presented two clear preferences
emerged that were rigorously debated; being Matakarapa Island and Target Reserve. It was
clearly stated by HDC staff that there were technical and financial limitations with both of these
options; as with all the other options which has been presented.
While it was intended by HDC staff that there would be a single preferred site identified during
the process, it was also indicated that there would be no power of veto by any one group
represented on the Focus Group. It was also made clear that HDC was the decision making
authority and the elected community members (councillors) would make the final decision on a
preferred site.
In early Focus Group meetings the majority response preferred the use of Matakarapa Island.
Iwi were less supportive, with mixed views also about Target Reserve. In the later meetings iwi
preference did not change, and some interest groups concurred (e.g. WECA), wanting to avoid
Matakarapa Island (and Target Reserve). Iwi did not suggest an alternative site. Community
Board members and some interest groups (SORT) indicated a preference to use Matakarapa
Island.
Halfway through the series of focus group meetings there was clear preference on using either
Matakarapa Island or Target Reserve. While no other new sites were added that were
considered more suitable, in the latter meetings some participants, namely iwi and WECA,
opted not to prefer either of these sites. No alternative site was volunteered by these groups
that were any different to sites that had been previously discounted (including Darleydale Farm).
At the final meeting all parties were agreed on the desired intention to cease direct discharges
to the Foxton Loop and Manawatu Estuary. While not unanimous, generally the non-iwi groups
had a preference for using Matakarapa Island. Iwi objected to both Matakarapa Island and
Target Reserve being used.
43
While there was a consensus by the group on favouring a land based treatment and discharge
option, there was no consensus on a single agreed site. The sites the Focus Group has been
focussing on all contain limitations and constraints. The project however needs to move
forward and a preferred site and treatment and discharge option needs to be recommended and
consent application prepared and lodged.
The Focus Group are to be informed of the options that Officers will in time be recommending to
the Foxton Community Board and full Council.
Officers have indicated to the Focus Group Members that once a preferred option has been
chosen by Council, they would be provided the opportunity to continue to be involved during the
design phase of the project.
8.5
Specific Iwi Engagement
Prior to commencing the Focus Group, it was recognised that the project was going to have a
high level of cultural interest. Firstly in relation to the land and water treatment and discharge
options and then secondly the potential for identified sites to be culturally significant.
Consideration was given to how Iwi should be involved in the process. It was recognised that
Iwi needed to be part of the Focus Group but it was also appreciated that there would be
occasions where it was necessary and appropriate for Council Officers to be engaging directly
with Iwi on those matters of cultural importance. This essentially created an engagement
process for Iwi that ran parallel with the Focus Group process.
Officers met with Iwi on several occasions through the process. It was during these discussions
that Iwi members began to share about the cultural values and sites of significance in relation to
the areas being considered.
During discussions about the use of Matakarapa Island Iwi representatives identified and
presented a summary of the historic use and occupation of the island. There were also
discussions about the significance of the Target Reserve area and the adjacent Round Bush
reserve.
Site visits to both Matakarapa Island (13 May) and Target Reserve (6 June) were undertaken
specifically with Iwi and some Focus Group members. During the site visit to Matakarapa Island
representatives of the Iwi and hapu present provided a map and indicated locations of specific
activities that have occurred in the past.
As a result of the clear historical association with Matakarapa Island, and to a lesser extent
Target Reserve, Iwi were given an opportunity by HDC to coordinate a series of hui and report
back to HDC and ultimately the Focus Group on issues that related to iwi and wastewater
management. Consideration was also to be given to the potential cultural benefits that could
arise from utilising Matakarapa Island in terms of the enhanced access and protection that could
potentially be achieved for the site’s significance. This process was to be coordinated by Ngati
Whakatere. It was intended that the result of the discussion would nominate preference with
respect to a site for the discharge of wastewater.
This opportunity effectively paused the Focus Group process and provided Iwi time and an
opportunity to collectively gather and present their thoughts and provide HDC officers with
feedback. The feedback would be by or on behalf of the elders of Ngati Whakatere and the
other Iwi. Initially the collective Iwi hui was scheduled for 28 September 2014, however this was
then rescheduled for 16-19 October 2014. The feedback to Council Officers from this hui was
to be provided after the hui. Despite requests by Officers no feedback was provided and further
Iwi hui were requested. The consequence was the reconvening and reporting back to the
Focus Group was effectively paused while these hui were occurring.
44
When it became necessary to advance the project; a date for the final Focus Group meeting
was set for 8 December 2014. This provided a catalyst for Iwi to respond. Council Officers
were invited to attend a meeting on 1 December 2014 at Te Whare Manaaki with
representatives of the iwi group for a report back on their findings. No written report was
provided. At this meeting an oral account was provided of iwi connection to the Manawatu
River. The Poutu Marae model of wellbeing was outlined. It was made clear that the collective
opinion was wastewater should not be applied to Matakarapa Island or Target Reserve and any
wastewater should be kept out of the river.
Despite a request for a preferred site to be identified in the initial brief, no alternative sites were
provided during the feedback meeting. Reference to land in the general area inland from
Foxton was made, but no specific site was identified.
The collective Iwi group was provided an opportunity to report back to the Focus Group. This
presentation occurred at the final Focus Group meeting held 8 December 2014. A brief
presentation was provided by Robert Ketu, Peter Hirawani and Willy McGregor describing the
Poutu Marae wellbeing model, the relevance and connection of iwi to water and the significance
of the Manawatu River and the relationship to local Iwi. The presentation did not discuss
specific sites or values of individual sites. The conclusion reached by Iwi was Matakarapa
Island and Target Reserve were not suitable and HDC had to find alternatives.
HDC had requested prior to the Focus Group meeting, and following the meeting, a written
summary of the hui process, who had attended, and confirmation of the group’s position. This
response was to be used to assist with informing this report. This has not been provided
despite several requests in December 2014 and January 2015, and consequently the account
of iwi values for this report has had to be interpreted by Officers.
During the engagement process the responsibility for sharing the Iwi perspective has been
taken by different members. Early in the process Troy O’Carroll, Te Kenehi Teira and Robert
Ketu have had this responsibility. As the process continued Robert Ketu became the leading
spokesperson (on occasions supported by others) for Iwi and it was indicated to Council officers
that he had the mandate to speak on behalf of the other local Iwi and hapu.
45
9
PREFERRED SITE OPTION ANALYSIS
9.1
Key Considerations and Objectives
Key considerations and objectives for the long term solution to the discharge of treated
wastewater from FWWTP are as follows:
•
•
•
•
•
•
•
•
•
•
9.2
Avoidance of a direct surface water discharge;
Preference for land discharge as the primary or perhaps sole discharge method;
Acknowledgement and management of culturally significant sites;
Acceptable environmental effects that do not significantly adversely affect
habitats;
Enhancement of surface water conditions via reduced discharged contaminant
loads to promote greater recreational use;
A system that is not adversely affected by flooding;
A system that is not adversely affected by or generates unacceptable
groundwater effects, including mounding;
A system that can accommodate higher winter flows associated with typical
sewer network limitations;
A system that can be managed with the resources available within the
community; and
A system that is affordable to the community.
Site Options to Consider
The following is a list of sites that have been identified and considered since 2001 by various
consultants and community representatives as potential locations for the Foxton WWTP and/or
its discharges to land:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Matakarapa Island (HDC land, Jarvis land surrounding FWWTP, and Knight land south
of FWWTP and Jarvis land);
Target Reserve (South, Golf Course, and North);
Foxton Racecourse;
Ferry Reserve;
Beach Reserve (South);
Beach Reserve (Front);
Beach Reserve (Rear);
Palmer Road Endowment Land;
Foxton Beach WWTP (Palmer Road);
FRP property on Palmer Road immediately west of Foxton Beach WWTP;
Wetland Area of Foxton Loop immediately north of existing WWTP discharge;
Stewart Street area including Foxton’s landfill transfer station site;
Newth Road area south of Foxton;
Waitarere Forest;
Easton and Lewis Farms on Oturoa Road, east of Waitarere Forest;
Levin WWTP with discharge to the Pot on Hokio Sand Road;
Darleydale Farm between Motuiti Road and Wall Road;
Guy Farm on Koputaroa Road; and
Farm land between Motuiti Road, Bowe Road, and Austin Road.
Other general areas such as between Foxton Beach Road and Foxton Loop, and between State
Highway 1 and Foxton Loop have also been considered.
46
Of the sites identified, there are four obvious preferred sites. This includes:
• Waitarere Forest;
• Darleydale property (Motuiti Road general area);
• Matakarapa Island; and
• Target Reserve.
While the area surrounding the Foxton Beach WWTP could be considered, and was the
preference in the 2012 LTP, this general area is no longer considered viable. This is because
of recent property ownership changes, increased residential development in the area and a
change to the District Plan allowing development in the area surrounding the WWTP.
The four preferred options are evaluated in Table 6.
47
Table 6: Potential Site Evaluation
Criteria
Waitarere Forest
Location
Potential Design
Environmental
Acceptability and
Requirements
RMA
Social and Recreational
Acceptability
Cultural Acceptability
Burial
Occupation
Water
Quality
and Mauri Effects
Access to Land and Legal
Issues
Darleydale property
(Motuiti Road general
area)
Matakarapa Island
Target Reserve
3 km south of existing
treatment plant across far side
of Manawatu River
• Existing treatment plant site
or relocated to Waitarere
Forest or Stewart Street
• Pipeline south under river
(3 km) or following roads (610 km)
• Sprinklers within forest
5 km from community and 10
km from existing treatment
plant
• Could use existing or
establish new treatment
plant
• Would require new rising
main of some 7 km or
more.
• Irrigation likely to be to
pasture
using
either
sprinklers or travelling
irrigators.
Existing treatment plant site 23 km from Foxton with land
discharge nearby
• Existing treatment plant,
potentially
with
some
minor improvements
• Sprinklers or travelling
irrigators onto pasture or
forestry
• Possible high rate land
passage
system
near
Manawatu
River
near
southern end of Island
• Mostly elevated dry land,
acceptable likely depth to
groundwater.
• Full discharge to land away
from river & residents.
• Consents needed for river
crossing
• Away from people and
recreational activities – out
of sight and out of mind
•
1 km from community and 7
km from existing treatment
plant
• Upgraded
existing
treatment plant with UV
treatment and additional
storage, or new high
performance compact plant
design at Target Reserve
• New rising main of some
4 to 6 km depending on
pump station location
• Dripper lines within golf
course and/or forestry area
• Seasonally
shallow
groundwater with some
surface drains that flow
past Round Bush to
coastal lakes
•
No known concerns. Well
away from all existing
recreational areas.
•
• Cultural status unclear.
Would need to consider any
previous occupation.
• Discharge would be away
from Manawatu River and
assist with restoring Mauri
of river.
• Ongoing land access not
certain as could be used in
treaty settlement.
•
No known concerns.
•
Seasonally
shallow
groundwater with some
surface drains.
•
•
•
•
•
Need to purchase land or
impose easements to coshare land
•
Close to Foxton Loop
Estuary
ONL
restricts
development
Elevated land available
away from flooding hazard
levels and groundwater
Despite land discharge the
public
impression
of
recreational effects on
Foxton Loop will remain
Strong iwi links with many
significant sites including
church and several urupa.
Mauri
concerns
for
adjacent Foxton Loop.
Need
to
formalise
easements for sewer main
& road access
48
•
Impacts
strongly
on
established
recreation
groups and users.
•
•
Sensitive site for iwi
Round Bush nearby and
downstream
is
also
significant to iwi
•
Gazetted
recreation
reserve status requires
changing, which will be
Criteria
Affordability24,25
Waitarere Forest
• Forest Company concerned
about irrigation increasing
groundwater levels and
killing trees.
• Forest Company unwilling.
• Greater than $10 M capital
costs
• Moderate to high operating
costs
• Will add at least $80 to
annual rates
• Access arrangements and
lease or purchase of land
not included above
Darleydale property
(Motuiti Road general
area)
Matakarapa Island
•
•
•
•
•
Greater than $14 M capital
costs
Moderate to high operating
costs
Will add at least $112 to
annual rates
If land could not be leased,
land purchase cost could
be $3-4 M.
•
•
•
•
Land owners willing to
enter
into
lease
agreement.
Estimated $7.5M capital
costs
Low to moderate operating
costs
Will add approximately $60
to annual rates
Access arrangements and
lease or purchase of land
not included above
Target Reserve
•
•
•
•
•
very difficult and may be
impossible
Long term leases need
changing if possible
Estimated $13.5M capital
costs
High to very high operating
costs
Will add approximately
$108 to annual rates
Costs of changing reserve
status and leases not
included above
Costs are bases on typical costs and an indicative design. Variation may be +/- 40 %, but the variation would be relative and apply equally to
all options i.e. if costs have been underestimated then the same under estimation is likely to apply to all options and the comparative magnitude
between options may not change significantly. Refinement of costs will require conceptual design to be undertaken, which has not been
considered necessary at this stage.
25 The impact on rates is based on a harmonized district rate where every $100,000 in capital expenditure adds approximately $0.80 to an average
property wastewater rate.
24
49
10 KEY ISSUES
10.1
General
When evaluating options for discharge sites there are key issues HDC needs to consider to
balance the needs and expectations of the community. There are environmental, social,
recreational, cultural and financial reasons to adopt and reject certain options. HDC needs to
make a decision that ultimately balances values and makes compromises to arrive at a solution
that is not only suitable for the current community, but future generations. This creates a
conundrum for Council as the compromises may not be acceptable to all members of the
community; however the compromises can potentially be managed through both direct and
indirect mitigation.
10.2
Land Availability
HDC have been committed to implementing a land discharge solution for Foxton WWTP for
many years. The community, interest groups and iwi have strongly supported this stance.
HRC’s One Plan also encourages land discharges over direct discharges to water. The current
and previous discharge resource consents for FWWTP have specifically required HDC to
undertake active investigation and implementation of land discharges prior to making future
discharge consent applications.
The key difficulty faced by HDC is the limitation of suitable land near Foxton. All land has
limitations, either technical, community or cultural. The proximity to neighbours, property size,
soil conditions and drainage are key considerations. No one piece of land will be ideally suited,
however compromises will allow a number of areas to be potentially used.
The key issue facing HDC is that there are very few options for land, especially when
considering the area needed, its availability and technical limitations.
10.3
Water Quality
Although environmental monitoring of Foxton Loop water quality has not conclusively
demonstrated any measurable adverse effects from FWWTP discharges, removal of this source
of contamination is nevertheless an important milestone that will assist with improving Foxton
Loop’s water quality and ecosystem health. Aquanet and Cawthron both noted that the
contaminant load contributions from the FWWTP discharge are currently negligible in the
Manawatu Estuary due to the upstream contaminant loads already exceeding or approaching
the One Plan target values. Therefore while every contribution helps, the complete removal of
the FWWTP discharge from the Manawatu River is unlikely to make a significant, or even
noticeable, impact on improving current water quality in the Manawatu River.
The key issues facing HDC is the rational for making changes and spending rate payers’
money, when they may not have a measurable effect. Being able to quantify the current and
future impact, and then explaining the technical significance of the impact to interested parties
will be critical.
10.4
Environmental Impacts
All options of land discharge, regardless of the selected site location, will result in some
improvement in the water quality and ecological values of the Foxton Loop and the Manawatu
Estuary. The improvements in water quality, as noted above, may be indistinguishable from the
existing and historic water quality due to the domination of other contamination sources and the
50
minor or negligible contribution from FWWTP. Nevertheless, any improvement resulting from
removal of this contamination source from Foxton Loop is important and valued by the
community and Iwi.
With appropriate design and management, land discharge of Foxton’s treated wastewater will
result in no more than minor effects on the soil, plant, and groundwater environments. Any
residual wastewater contribution to surface water bodies will be reduced from the current
situation by virtue of the plant uptake and land passage processes, followed by dilution within
groundwater, prior to any possible contact with surface water.
The key issue facing HDC is convincing the community that land passage and drainage losses
will be acceptable and will be minor. The reality is that there will be some drainage losses
irrespective of the system and its location, especially during winter. Greater nutrient and
contaminant removal is possible, but this comes at a cost and HDC will need to convince the
community that the level of nutrient removal from the river system that is ultimately adopted is
appropriately considered against the costs versus the benefits.
10.5
Recreational Values
Removal of the FWWTP discharge from Foxton Loop and Manawatu Estuary will improve public
perception of recreational opportunities within these connected waterways. Any high rate
discharge to the Manawatu River only during high river flow rates (eg above 20FEP) will
minimise effects on recreational values, as recreation is unlikely to occur in this locality during
such high flow events. However, this may still be viewed as having an unacceptable effect on
recreational values (even with land passage occurring before it can potentially enter the river).
Land discharge within Matakarapa Island or close to the Manawatu Estuary may be perceived
as having a reduced but still unacceptable effect on recreational values. Application of treated
wastewater to reserve land, such as has been proposed for Target Reserve among others,
would likely be perceived by many community members as having a worse effect on
recreational opportunities than the current Foxton Loop discharge.
The key issue facing HDC is that the two options seen as being the most feasible (Target
reserve and Matakarapa Island) are close to areas of high recreational use. While mitigation
and system design can be adopted to ensure there is minimal impact on recreational use, the
community will need to be convinced.
10.6
Cultural Values
Waste discharges and earth disturbance within or near any culturally sensitive sites are not
acceptable to Iwi, as they aren’t to the rest of the community. While there are known sites on
Matakarapa Island, there are likely to be others that are unknown. This equally applies to sites
other than Matakarapa Island that can be used for wastewater management (treatment and
discharge).
Information gleaned to date from Iwi and other historic records, including the owners of land on
Matakarapa Island, have indicated that significant sites are typically limited to specific areas.
While this does not imply remaining areas have not been used or traversed in the past, this
dilemma applies to all land in the Foxton area which has a rich history, both pre and post
European settlement.
The reality is we need to manage land use activities, including waste management within the
confines of the surrounding land. This land use needs to be sensitive to historic land use,
including providing recognition for urupa and taonga. While specific areas can be avoided, any
51
effects of the general use of land may be mitigated by the provision of generous buffer zones
around known sites and the planting of appropriate vegetation in dedicated reserve areas.
The Iwi feedback during the consultation process on a preferred site has indicated three areas
of concern, being:
• Protection of significant sites;
• Avoiding the loss of fisheries; and
• Enhancing the mauri of waterways.
Significant sites need protection. They should be defined and a plan put in place to work with
land owners to create such protection. It should also be remembered that with the exception of
Target Reserve, all land being considered has limited public access and there may not be
protection of significant sites, not through wilful destruction, but simply the unawareness the
sites exist. With land being in private ownership the current land owners can undertake land
management activities without approval within the limitations of the current laws. With any land
used there is the potential for agreements to allow for collective management of dedicated
areas, thereby providing protection that would not have previously existed.
Maintaining fisheries and food gathering opportunities for iwi is an important. Avoiding
waterway discharges and adoption land discharge goes a long way to improve water quality.
However, the impact of possible changes with the Foxton discharge should be put in
perspective with the larger impact on water quality. The Foxton discharge will be a contribution
to enhancing water quality, but on its own will not be the answer. The impact and changes in
fishery values need further discussion to ensure there are not unrealistic expectations of
improvements in water quality by Iwi, and the rest of the community.
The key issue facing HDC is many areas surrounding Foxton are of significance to tangata
whenua. While specific areas can be avoided, general areas cannot, as there would be no land
able to be used that is within the capabilities of the HDC to access.
10.7
Use of Existing Infrastructure
Irrespective of the discharge site, the ongoing use of Matakarapa Island for wastewater
treatment enables the use of the investment that has occurred at that site since 1970. The
ponds require de-sludging, but otherwise there is little need for significant maintenance of the
existing WWTP.
Abandoning the existing WWTP and constructing a new WWTP elsewhere effectively doubles
the cost to HDC and ratepayers for the Foxton scheme. Not only would new treatment facilities
be required, but there would also be the need to remediate the current site.
The new WWTP will probably be more expensive to construct and operate than the existing
WWTP, as it is likely to involve taking up the opportunity to install more technologically
advanced treatment. If a sensitive discharge site such as Target Reserve, or a sensitive WWTP
site such as adjacent to the Foxton landfill transfer station were to be used, then a much more
expensive compact treatment plant that produces high quality effluent would be required.
The reticulation costs for constructing a pipeline to the discharge site increase with distance and
increases in elevation, as do the daily pumping costs. A recreationally sensitive site such as
Target Reserve would require more expensive dripper irrigation instead of cheaper and less
complex spray or travelling irrigators.
The key issue facing HDC is the gains to be made in abandoning the existing infrastructure from
establishing a new treatment site which will come at significant cost.
52
10.8
Affordability
District wide harmonisation of HDC’s rates spreads the cost of all HDC wastewater
infrastructure across all ratepayers within the district who are connected to a reticulated HDC
wastewater system. This ensures that small communities such as Foxton are not forced to bear
the entire costs of constructing and operating their community’s wastewater system; as the
costs are shared across Horowhenua’s other towns. However, this also means that Foxton
ratepayers will be contributing to the costs of constructing and operating the other Horowhenua
communities’ wastewater systems. Consequently HDC need to bear in mind that all costs on
every wastewater system have a direct financial impact on every reticulated ratepayer across
the district, and greater expense on each system results in greater costs to all of these
ratepayers including Foxton’s.
A reasonable, but nevertheless limited, budget has been set in the current LTP for upgrading
the FWWTP. The LTP budgets for wastewater and water upgrades across the district have
been spread over 20 years in recognition of the unsustainable and unaffordable effects that
more rapid upgrades would have on rates increases for the district’s ratepayers. Any significant
increase in expenditure on FWWTP will exacerbate these pressures on ratepayers. It therefore
is very important that the total costs of upgrading FWWTP are kept as close as possible to the
current LTP budgets.
The key issue facing HDC is how much to spend on a treatment and discharge upgrade, and in
particular the marginal benefit of extra costs of one site over another, when there may be no
tangible gain to the community.
53
11 CONCLUSIONS
HDC and the community have considered a large number of potential sites for land discharges
of Foxton’s treated wastewater over many years. A small number of sites have been reviewed
several times over. Consistently over the years of reviews and investigations, Matakarapa
Island has been recommended as the most practicable and least costly choice. A large number
of the recent Focus Group participants supported this site. However, tangata whenua and
some interest groups have equally consistently opposed this choice due to its cultural
significance and proximity to the Manawatu Estuary.
All parties are agreed on the desired intention to cease direct discharges to open waterways
such as Foxton Loop and Manawatu Estuary. However, the limitations on land discharges may
still force HDC to use high rate land passage discharge when river flow rates are high (above
20FEP) irrespective of the chosen site. This will result in some discharge to groundwater and
ultimately surface waterways, albeit having passed through land first and occurring only during
flooding conditions when recreational use is unlikely.
HDC need to urgently decide on the most appropriate location for the land discharge of Foxton’s
wastewater so that detailed site investigations and conceptual designs can be undertaken in
preparation for an application to HRC for long term discharge resource consents.
Wastewater management for the Foxton community does not have a single easy solution. If it
did; a solution would have been implemented a number of years ago, or at least during the term
of the current resource consent as required by its conditions. The fact that solutions have been
discussed since the 1990’s and not implemented highlights that there are irreconcilable
differences in opinion as to what is suitable, practicable, and/or affordable.
There are key factors that create challenges for managing sewage at Foxton that, while
individually they commonly exist/occur, are less likely to collectively exist at other communities.
The particular combination and inter-relationships of these factors for Foxton make it very
unique and challenging to find a single integrated solution that addresses and resolves all of
these factors. These are described below.
Location limitations – The Foxton community is squeezed in between SH1 and the Manawatu
River Loop. The surrounding areas to the east and north, to a distance of some 3 to 5 km, are
occupied by lifestyle properties and farm land with intensive land use. There are some areas
with less intensive land use that could be used for land application, but they typically have
challenges for developing a sustainable land application system.
The general area to the south and west is and has been significantly influenced by the
Manawatu River. The river has high cultural, social and recreational values and existing poor
water quality. These factors create limitations for using land in this area.
As a consequence of the low-lying nature of the alluvial Manawatu plains in the Foxton locality,
groundwater is often close to the land surface during wetter months, particularly winter and
spring. The sandy soils are excessively drained to a shallow depth and are not well suited to
retaining nutrients from wastewater application.
Existing infrastructure – Current wastewater reticulation is a gravity sewer draining to the south
west side of the community and then sewage is pumped to treatment ponds some 1.7 km away
on Matakarapa Island. There has been significant investment in this infrastructure since 1970
and to abandon it would require reinvestment in new infrastructure (and land ownership or
access) elsewhere, at significant cost.
54
Water quality impacts – Minimising the impact on receiving water following a discharge is
challenging in the Foxton area. Within a 5 km radius of the community there is the Manawatu
River, Foxton Loop, Manawatu Estuary and Ramsar area, all of which can be sensitive to
nutrients which enter water. All land drainage around Foxton enters the Manawatu River and
ultimately the estuary. As with many coastal areas groundwater is close to the surface, and in
the case of the Foxton area there are numerous surface drains which discharge to the
Manawatu River. Consequently most potential land discharge sites will have drainage from a
land application system that soon ends up in the Manawatu River.
Cultural acceptability – Foxton has a diverse and rich cultural history. It is especially significant
to tangata whenua, with the Manawatu River regarded as a taonga. Not only are wastewater
discharges to water frowned on by iwi, but so is the use of areas that have historic significance.
The area around Foxton has many sites that are special to Iwi and care is needed to manage
and diligently develop wastewater discharge solutions so as to ensure they are not degraded or
adversely impacted. Many early European settlement heritage features are also located within
and around Foxton and Foxton Loop.
Affordability – The Foxton community is small and does not have a wealthy population.
Fortunately the HDC have a harmonized rating policy, which helps to spread the costs of
individual projects over the district’s ratepayers. Despite this sharing of costs, many other
communities within the district also require infrastructure improvements; and this means that
Foxton residents also have to share in their costs. Consequently care is needed to ensure that
not only Foxton ratepayers can afford the cost of any changes, but the affordability to the entire
community, bearing in mind also that additional costs will be incurred for future upgrades of
infrastructure for the other communities.
55
12 RECOMMENDATIONS
12.1
Preferred Site
HDC are recommended to approve Matakarapa Island as the best practicable site for Foxton
WWTP and its discharges to land.
All discharges would be applied to land, and preferably using an irrigation system. Costs and
the affordability of any wastewater solution for Foxton are a major factor in this
recommendation. The reasons for recommending this site are outlined below.
Infrastructure and Certainty of Land Access
There is existing infrastructure that can be used, thus offering significant savings on
alternatives. There is greater certainty of land procurement, with land owned by HDC as well as
Knight and Jarvis having the potential to be used either independently or in combination to
implement land discharge. HDC’s land has scope for development because the WWTP ponds
occupy less than half of the land area within these land Titles, and the undeveloped land area is
mostly elevated land with some low-lying land adjacent to Foxton Loop.
High Flows
Managing higher winter flows creates a challenge for all sites in the area, due to the presence of
high groundwater levels. A high rate land passage could be a feature of the land discharge
system in order to allow for more rapid discharges during times of elevated river flow rates.
This would minimise the amount of land required for irrigation and would also assist with
minimising the required pond storage volumes. All discharges would be forced by these
systems to pass through land prior to any possibility of wastewater entering groundwater or
surface water (Foxton Loop or Manawatu Estuary).
Consequence of Location
The perception and impact of discharges in close proximity to both the Manawatu River and the
Foxton Loop are likely to generate significant public opposition. Using Matakarapa Island will
result in a relatively short horizontal separation distance to the river and its positioning close to
the Ramsar Area and Estuary. However, the reality is that all land in the greater Foxton area
(with the exception of Waitarere Forest) drains to the Manawatu River and there will be a
residual nutrient contribution to the river system from all sites which have been considered. In
fact, areas of Matakarapa Island potentially offer greater distances of soil travel (vertical) prior to
reaching groundwater than many other sites in the area due to the elevation of the sand dunes.
Generous buffer distances can be achieved within the potentially available land areas on
Matakarapa Island.
Manawatu River Nutrient Enrichment
The current discharge has a minor contribution to existing nutrient enrichment in the Manawatu
River, with water discharged from the FWWTP on occasions better than what exists in the
Foxton Loop. This by no way means nothing should be done; but there is a need to put the
actual and potential effects in perspective, especially if direct discharges are to be avoided and
it is only drainage water, containing a small portion of the current nutrient load, which ultimately
reaches the Manawatu River. The location of the discharge site, being Matakarapa Island, will
ultimately need to be debated on technical facts and not perception and emotion.
Management of Cultural Sites
The known culturally sensitive sites on Matakarapa Island can be readily avoided when
designing the locations and layouts of the land discharge system(s). A standard Accidental
Discovery Protocol can be used to manage any discoveries.
56
Impact on the Mauri of the Manawatu River
Iwi opposition to the impact on the mauri and effects on fishery values needs to be put in
perspective of the alternatives and that which is realistically possible for this community. Land
application of wastewater is understood to be a key aspect in restoring the mauri of waterways.
This can be achieved as well on Matakarapa Island as it can be anywhere else in the area
surrounding Foxton. The impact of using Matakarapa Island on fishery values is dependent on
the nutrient and contaminant load to the surface water system. Due to all sites in the Foxton
area being hydraulically connected to the Manawatu River, potential impacts will occur
irrespective of the site; however such impact should be put in perspective of the actual
contaminant contribution of drainage water when compared to the residual and background load
from upstream in the Manawatu River.
Affordability
The financial implications of keeping the existing WWTP in its current location and minimising
reticulation distances to the land discharge system are very significant compared with all of the
alternative options. This alone should be a reason to prefer Matakarapa Island, even if
alternative discharge sites were equally suitable as Matakarapa Island.
12.2
Proposal
As a consequence of the above recommendation regarding the selection of the best practicable
discharge site, HDC are recommended to authorise the following series of actions to commence
immediately:
•
•
•
•
Work with iwi to identify their concerns, negotiate acceptable mitigation measures, and
modify the conceptual designs as appropriate; and
Prepare resource consent applications for lodging with HRC for processing before the
next consenting deadline of 1 March 2016.
The reasons for these recommendations are:
•
•
•
•
•
•
•
The existing FWWTP is located on Matakarapa Island, which avoids significant
replacement costs;
Sufficient land exists on Matakarapa Island that is elevated above groundwater and
flood hazard levels, which , in combination with suitable soils, means that the site is
suitable for a land based discharge system;
The implementation of land discharges on the island with generous vertical and
horizontal buffer distances from groundwater and surface water will reduce the effects of
the discharges on Foxton Loop and the Manawatu Estuary;
The site is in close proximity to Foxton, but is largely located away from sensitive
neighbouring environments;
This is expected to be the least expensive of the viable site options, meaning that costs
and financial burdens on ratepayers are minimised;
All aspects of the WWTP operation are kept within a compact area which leads to
operational efficiencies; and
Culturally significant sites on the island will require sensitive consideration throughout
the design and consenting process, but it is expected that these sites can be avoided
and adverse cultural effects can be appropriately mitigated.
57
This site has the most overall advantages compared with any alternative site, and its
disadvantages can be appropriately avoided, remedied, or mitigated. It best meets the key
criteria for selecting the best practicable site for both the FWWTP and its land discharge
system. It should be noted that no single site meets all of the key criteria; all sites considered
within the Foxton locality have disadvantages and design limitations. It should also be noted
that there is very limited time for undertaking further reviews of potential sites within the time
remaining for lodging applications with HRC for long term discharge resource consents
As a consequence of the above recommendation regarding the selection of Matakarapa Island
as the best practicable discharge site, HDC are recommended to authorise the following series
of actions to commence immediately:
•
•
•
•
Work with iwi to identify their concerns, develop mutually acceptable mitigation
measures to be incorporated into the system design; and
Prepare resource consent applications for lodging with HRC by March 2016.
The implications of making this decision as recommended above include:
•
•
•
•
•
An acknowledgement that iwi and some community representatives are likely to be vocal
in their opposition, and some negative publicity may result from this;
Access to the land will likely incur costs and negotiations that may take some time to
resolve;
Resource consenting may be expensive and lengthy as a consequence of opposition
(appeals may occur as well – acknowledging that direct referral to the Environment
Court remains an option for Council);
An acknowledgement that a possible part of the long term solution includes indirect high
rate discharges to Foxton Loop or the Manawatu River via a land passage system
during periods of elevated river flow rates (above 20FEP); and
An acknowledgement that any reduction in direct discharges to Foxton Loop will
contribute to improving the water quality of Foxton Loop which will in turn improve the
public perception of recreational opportunities, estuary ecological health, and cultural
values.
If Matakarapa Island is not selected by HDC as the best practicable site for Foxton WWTP and
its discharges to land, then the implications are as follows:
•
•
•
•
HDC must make a decision (or at least provide a recommendation) on their preferred
alternative site(s) with reasons;
HDC will need to authorise further appropriate site specific investigations that will enable
future decisions to be made regarding designs and costs;
Further negotiations may be required with HRC to extend the timeframe for lodging
applications for long term discharge resource consents, and this may generate negative
political and media responses; and
Rates increases for all ratepayers across the district who are connected to a reticulated
HDC sewage system will increase proportionately with any budget increases for the
FWWTP upgrade.
58
13 NEXT STEPS
13.1
Council Approval
Considerable effort has gone into canvasing the views of the community by HDC staff and their
advisors. There are mixed views and there has not been unanimous approval of a preferred
discharge site established during community consultation. The reasons for and against various
sites have been identified elsewhere in this report. HDC staff have tried to logically work though
and develop solutions for issues and allow a single preferred option to be developed. This has
resulted in a recommendation by HDC staff and their advisors that not all of the community will
accept, at least initially. In order for further investigations to proceed and greater commitment to
be given to the preferred option, it is considered appropriate that the community’s elected
officials have an opportunity to debate and form an opinion on a preferred option.
The site selection process has been clearly explained to the Focus Group. The expectation is
that this report will be presented to the Chief Executive to direct Officers on the option to
present to the Foxton Community Board, Council and to the Focus Group members at a
workshop. The process would involve a report being presented that identifies the option that
the Council intends to pursue through the resource consent process.
The decision on proceeding with the identified option ultimately sits with the full Council.
Following the workshop the report would be presented to Council seeking a resolution to
proceed with the application for resource consent. There is an expectation that the Focus
Group is kept informed of these steps in the process (where commercial sensitivity allows). As
has been previously indicated in this report the Focus Group would have the opportunity to
continue to be engaged in the design phase of the project.
13.2
Communicate Decision
The decision needs to be communicated to HDC’s management team as well as being made
available for public consultation as part of the LTP and resource consenting processes. The
reaction and management of this decision should be considered. This may require this report,
or parts of it, to be made available to interested community members.
13.3
Land Access Procurement
The process to date of identifying land options has not resulted in confirmed access to specific
parcels of land, as that would be pre-empting the outcomes of the site selection process. In fact
several land access options are available (even on Matakarapa Island), with this approached
deemed necessary to ensure HDC were not forced into a position of having to accept
unreasonable requests from land owners.
Should Councillors be mindful to approve the use of Matakarapa Island, and endorse the
preferred option, further discussions will be needed with the property owners and their
confirmation sought to ensure a solution can be legally established. This will also require land
owner approvals for site investigations to allow design and resource consenting to proceed.
13.4
Investigation and Design
The key investigations that need to be completed are as follows:
•
Groundwater investigations to confirm depth to groundwater, diurnal (tidal) and seasonal
variations, any mounding beneath around the existing WWTP ponds, flow directions,
and water quality;
59
•
•
•
•
•
•
•
•
•
•
•
Soil permeability assessments;
Archaeological survey;
Conceptual designs;
Detailed scenario modelling calculations for determining storage pond volume and land
area requirements;
Preparation of the Best Practicable Option report that describes the most appropriate
discharge systems for this site;
Geotechnical investigations for stability of ponds and other structures;
Surveying and earthworks estimation;
Landscape architect assessment of the effects of any earthworks and structures on the
natural landscape, including any proposed mitigation measures;
Preliminary cost estimates of proposed designs;
Discussion and development with iwi of cultural mitigation options; and
Preparation of consent documentation.
13.5
Consenting
HDC has continued to consult with the Foxton Focus Group as well as advance technical
assessments into various discharge options in advance of identifying a preferred long term
discharge solution. Now a preferred long term discharge option has been identified, HDC need
to undertake the followings tasks in order lodge a robust and complete long term discharge
resource consent application:
• Undertake the necessary technical design work;
• Undertake the necessary investigations and assessment of effects;
• Ensure HDC has the legal right to discharge to the preferred site (i.e. through site
ownership or long term lease); and,
• Continue to consult with stakeholders and the wider community to refine the preferred
discharge solution.
A timeline for lodging the long term discharge solution was presented to Horizons in the short
term renewal consent application (Appendix E of the application). Quarterly updates of progress
against this timeline are being provided to Horizons.
13.6
Timing
The available time is very tight for achieving all of the required investigations and design as well
as preparing all the required documentation for lodging the appropriate resource consent
applications with HRC and the regulatory arm of HDC for processing by 1 March 2016. The
timeline for this is presented in Appendix B.
Site investigations need to have commenced prior to the end of February and conceptual
design work underway by April.
60
14 APPENDICES
Appendix A
Appendix B
Appendix C
Project Timeline
Figures
61
APPENDIX A
APPENDIX B
Project Timeline
APPENDIX C
Figures

Foxton Wastewater Discharge

Transcription

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