Watercare Intercepts Planning Process

We read in NZ Herald today, in a story about its Central Interceptor project:

"In a break from tradition, the Auckland Council-controlled organisation has released its evidence supporting the bid for resource consents and notices of requirement for the project ahead of the public hearing on Monday, July 29...."

Can't think why Watercare might do that - unless it feels a need to go on the media front-foot in defence of this particularly problematic and expensive project. NZ Herald is usually a little more savvy in situations like this - don't like to see it used to further any particular agenda.

Risk of being unbalanced. The NZ Herald story says the project will "save Auckland $500,000,000". That's an interesting claim. To date the project cost figure is given as $800,000,000. Now it looks like a net cost of just $300,000,000. Never heard that before. Not in the application either. But it is in the NZ Herald. maybe the Central Interceptor's funding is under threat. Auckland Council is facing the fact it can't go on borrowing money from banks. Driving us all deeper into debt. Pressure from Government is forcing Council to identify priorities. Top priorities.

Is a tunnel for dilute sewage - redirecting sewage overflows from the Waitemata Harbour into the Manukau Harbour - THE top priority? Or is a tunnel for the Britomart Rail link a high priority? That's what Councillors are there for. Identifying priorities.

But I digress. Was writing about NZ Herald's rather cheery story for Watercare. For example, the reporter could have looked into the Auckland Council Officer' report that will be read by the Hearing Commissioners. The Auckland Council report has been available on the internet for a couple of weeks at least. A juicy read if you like that sort of thing. Balanced as well - as it has to take account of Watercare's application AND what submitter concerns are AND come up with recommendations and suggested conditions.

I have already expressed my concerns about the Central Interceptor project, and my submission. And I will be speaking at the hearing.

But for now a few quotes from the officers report (by the way - this is 328 pages long):

In the summary we find this statement:

"Subject to new or contrary evidence presented at the hearing, the recommendation of the
authors of this report is that the NORs be confirmed subject to conditions, and that the
applications for resource consent be granted subject to conditions."

Which is not surprising. But as in all things, the devil is in the detail. A few interesting titbits, before I cover a couple of salient details in the conditions that have been recommended by the Auckland Council officers. Titbits:

Pg 233: "It is noted, that the benefits of the Central Interceptor project can only be realised following
its completion and connection with the existing wastewater network."    (This is an important recognition of the fact that the pipe-based solution cannot be implemented incrementally - as for example North Shore's approach was - and cannot provide public benefits until it is totally finished. This is the classic problem with traditional, centralised, think big infrastructure. Today's thinking is much more de-centralised.)

Pg 67:  "Watercare advises that wastewater flows to the Mangere WWTP will not be significantly
influenced by the Central Interceptor....  Flows into and out of the Central Interceptor will be controlled to ensure the annual mean flow (390,000m3/day) and maximum daily flow (1,209,600m3/day) provided for under the current consent (permit number 30083, which expires on 31 December 2032) will not be exceeded within the term of that consent....   Although the submissions suggest that there will be a doubling of flows to the Mangere WWTP as a result of the Central Interceptor, it is noted that this would be outside the scope of the present discharge consent, and is well beyond Watercare’s own assessment of likely flows even by 2062...."   (An important consideration here is the capacity of Mangere. Especially during wet weather. Mangere does not have the ponds that Rosedale has that give it ability handle wet weather inflows with discharges.)

Pg 15:  "Other associated works at and in the vicinity of the Mangere WWTP include: an air
treatment facility; a rising main to connect to the plant; and an Emergency Pressure
Relief (“EPR”) structure to enable the safe discharge of flows in the extreme
scenario that pump station failure occurs and tunnel storage capacity is exceeded."  (This is an interesting new discharge. When it is used it will essentially divert overflows that did occur on the East Coast into the Waitemata - untreated into the Manukau.)

There will be lots of other important matters in the Officer Report. But I will summarise two that struck me here:

Pg 321:  Discharge Consent Condition 10.3  "Within 3 months of the granting of this consent, the Consent Holder shall prepare an Emergency Pressure Relief (“EPR”) Discharge Management Plan which shall be in accordance with the conditions of this consent and should include, but not be
limited to:
(a) A summary of the key reasonable operational and contingency procedures
the Consent Holder should follow to minimise the potential need for an EPR
discharge;
(b) The EPR Discharge Management Plan covering the initial receiving
environment, water quality and shellfish monitoring sites and procedures
immediately following the discharge and subsequent further monitoring;
(c) The procedure for the rapid provision of signage and any other health
warnings at potentially affected locations to warn the public of the potential
public health risk. This should include at any other coastal foreshore areas
that may also be affected by the discharge that may be accessed by the
public for water recreation or shellfish collection purposes; and
(d) A procedure for determining suitable locations for signage based on an
estimate of the extent of marine waters and shellfish that may be affected by
the mixing zone plume of the discharge depending on relevant variables that
may apply, including relative tidal conditions and the duration and rate of the
discharge.
The EPR Discharge Management Plan shall be submitted to the Manager for
approval within three months of the granting of this consent and the Consent Holder
shall then comply with the approved EPR Discharge Management Plan."

Pg 47:  Other Consents   "The overall Central Interceptor project also involves further regional consents for the CSO Collector Sewer works (overall network and six construction sites), and a network discharge consent....   Pg 235:   "Submission 697 seeks that the Central Interceptor proposal does not proceed to a hearing until Watercare lodges its resource consent application for network discharges. While the authors acknowledge that there is some risk in seeking consent for a specific
infrastructure component prior to the Network Discharge package, this approach will allow
the Network Discharge package to better align with the GAP project in terms of content
and conditions. The authors also consider there is adequate information to determine the
current resource consent applications and for recommendations to be made on the
NORs....."   Pg 21: "A further separate application will be made for existing and future wastewater network discharges in the Central Interceptor catchment area (the Auckland Isthmus) that will be
directly influenced by the proposed Central Interceptor scheme. The application will
relate to the existing operation of the wastewater network and the future operation of the
network as improvements are made either as part of the Central Interceptor scheme, or
as part of Watercare’s day-to-day management of the network...."

In terms of "Other Consents", the RMA has always advised and usually required, that ALL related consents be sought in the one application. In order to allow for integrated planning. I note that officers say: "a further separate application will be made...". When?