Martinborough Wastewater Treatment Plant Connections
Updates
August 2023
Martinborough Wastewater Treatment Plant: Cancellation of Abatement Notice A1020
17 August 2023
On 12 May 2023 South Wairarapa District Council advised that effective immediately, applications for new wastewater connections in Martinborough are being put on pause in Martinborough for the time being. This is because the town’s wastewater plant has failed to meet performance and compliance standards.
An abatement notice received from Greater Wellington Regional Council (Greater Wellington) for the Martinborough Wastewater Treatment Plant (MWWTP) non-compliances required us to:
- Cease. And be prohibited from commencing all unauthorised discharges from the MWWTP,
- Submit a proposal for corrective actions to bring the WWTP into full compliance by 1 December 2022, and
- Comply by 15 August 2023.
Actions taken and the outcome
Our initial proposal submitted to Greater Wellington last December was not accepted while they assessed whether continued non-compliance would significantly impact on the environment, that is, whether a staged approach to corrective actions would be acceptable. Once it was confirmed that a staged approach was acceptable, we then worked with Wellington Water Limited (WWL) and Greater Wellington to develop a corrective action plan and contingency plan (in the event the corrective action plan does not achieve the results expected).
We are pleased to advise this has been accepted by Greater Wellington.
The agreed plan is focussed on addressing the immediate non-compliances related to the existing design and capacity of the plant over the next year, from August 2023 to August 2024, through the delivery of three separate packages of work. These are:
- Desludging planning
- Additional monitoring of wastewater to inform future upgrades
- Investigation and optimisation of the Ultraviolet disinfection equipment.
Next steps
During the implementation of the one-year programme we will be collecting information that will enable us to design for Martinborough’s growth capacity issue. To be clear, the one-year programme addresses compliance and getting us back to design capacity (which was based on zero population growth from 2016); it does not increase the capacity of the MWWTP for growth. The growth capacity programme will be confirmed off the back of the data being collected over this next twelve months.
The programme does not address land disposal capacity, which will be increased in future years. The current Stage 1B consent conditions that require discharge to land during lower river flow conditions remain difficult to fully comply with due to limited land available and its reliance on favourable weather conditions.
The budget for the one-year programme still sits at the amounts indicated in the Better Off Funding – Project Substitution Decision Report presented at the 7 June Council meeting and approved by Councillors in the 2023/24 Annual Plan. The full amount required will only be finally confirmed once a decision on geobag disposal for sludge is made and a sludge survey is completed.
The three new packages of work issued three ‘To Do’ abatement notices
In accepting our corrective actions plan and contingency plan, Greater Wellington on 15 August 2023 cancelled the original abatement notice issued in August 2022 and have now issued three ‘To Do’ abatement notices aligned with the three packages of work that will be cancelled as we complete the work.
Greater Wellington have incorporated two further requirements within the new abatement notices. On, or before, 28 February 2024 and 31 August 2024:
- Organise and hold two Community Liaison Group (CLG) meetings.
- Initiate contact with Rangitāne o Wairarapa and Ngati Kahungunu ki Wairarapa to:
- Provide a summary of progress in meeting the requirements of ‘To Do Abatement Notices A1061 – A1063’; and
- Provide a proposal for, or any updates to, the development of a Tangata Whenua Values Monitoring Plan.
The MWWTP project team will now work towards delivering on the timeline agreed with Greater Wellington and creating appropriate milestones and forecasts so we can complete our Better Off Funding application for $500k.
Greytown Wastewater Treatment Plant
Planning is also underway on the desludging of Greytown WWTP at the same time as Martinborough, although it is not part of the formal abatement notice process we have been completing with Greater Wellington. As the Greytown site does not have the same designations in place as Martinborough, the timeline for consenting the disposal for that plant could extend beyond the original timing envisaged.
The issue
Applications for new wastewater connections in Martinborough are being put on pause in Martinborough for the time being because the town’s wastewater plant has failed to meet performance and compliance standards. This is effective immediately.
The plant has also reached its design capacity as population growth and annual connections have far exceeded expectations.
Significant performance and compliance issues resulted in Greater Wellington Regional Council (Greater Wellington) issuing an Abatement Notice for the plant in August 2022. The public health risk from previous discharges to the river is very low and independent specialists engaged by Greater Wellington assessed the environmental risks as negligible.
An abatement notice means the Council is required to act to remedy the identified issues and return the plant to compliance by a certain date and remain in compliance thereafter.
In addition, specialist advice from Council’s water services provider, Wellington Water Limited (WWL), is that additional connections would further compromise the plant’s performance, increasing the risk to the environment, public health and safety. There is also the possibility of more severe enforcement action from Greater Wellington.
This means that the Council is obliged to pause applications for new connections to the Martinborough Wastewater Treatment Plant (MWWTP) effective immediately.
Context
South Wairarapa District Council (asset owner), and our water services operator Wellington Water (asset manager), received an Abatement Notice from Greater Wellington Regional Council (our regulator) for the Martinborough Wastewater Treatment Plant in August 2022. Greater Wellington issued this due to the frequency of non-compliance discharges from the plant to land and water. Council has been instructed by Greater Wellington through the Abatement Notice to cease and be prohibited from commencing all unauthorised discharges from the MWWTP by 15 August 2023 and continue to comply thereafter.
It is worth noting that the public health risk from previous discharges is very low and independent specialists engaged by Greater Wellington assessed the environmental risks as negligible.
WWL, alongside South Wairarapa District Council, are urgently working on a delivery plan to bring the plant back to full compliance as soon as possible, while keeping Greater Wellington updated on progress. Greater Wellington have indicated that further enforcement action remains a possibility if the MWWTP is not operating within its consent conditions.
The plant requires significant investment to resolve the current consent non-compliances and Council is considering all options for this.
Why has this happened?
The MWWTP has been in operation since the 1970’s. The plant has not had the levels of investment needed over its lifetime to maintain its treatment capacity and operational resiliency. The MWWTP requires new pumps, Ultraviolet (UV) systems, screening and treatment systems, among other things. We have also seen higher than expected growth, both in terms of population and new service connections, since the resource consent was renewed in 2016. This has put extra pressure on the plant, pushing it beyond its capacity limits.
In addition, we have the impact of ageing infrastructure across the whole water network. A key issue is Inflow and Infiltration. This occurs when groundwater and stormwater find its way into the wastewater pipes, often due to leaky pipes underground or cross-connections. This increases the volume of water entering the treatment plant, particularly during periods of high rainfall, again pushing the treatment plant beyond its operational capacity.
What are we doing about it?
Council has prepared a Compliance Delivery Plan that sets out how Council plans to address the issues with the MWWTP. A compliance delivery plan is expected to be submitted to Greater Wellington by the end of May 2023 and, assuming it is accepted by them, funding will be secured, and work will begin.
The draft wastewater compliance plan includes a range of operational upgrades and improvements, which are still being finalised. Our estimate is that this will take up to two years and then will be followed by a second stage of work to increase capacity which will take several years to deliver. Growth studies to support the second stage of work will be carried out simultaneously with the compliance work over the next two years to fully inform design.
Funding for both components of the staged plan is not yet confirmed. Some initial funding to start work is included in our proposed 2023/24 Annual Plan, however, significant additional funding from either Council’s 2024-34 Long-term Plan (LTP) or via the new Entity post-Water Reform will be required.
Funding for the second stage, removing capacity constraints, will go through the appropriate consultation and approval processes for the 2024-34 LTP.
We will keep the community updated on key milestones as we and Wellington Water work together towards making the plant fully compliant.
What does this mean for local community and businesses?
This means that the Council is obliged to pause applications for new connections to the MWWTP effective immediately.
South Wairarapa District Council appreciates the impact this decision will have on developers and people seeking to build new homes in the region. We regret having to make this decision which we know will temporarily slow growth in the region. We will pause new connections for only as long as needed.
Council has already started working with customers who have a connection request in train to clarify their status. All permits, resource management and building consents that have been received and approved by Council will be honoured and a connection to the wastewater network made.
Documents
Martinborough Wastewater Treatment Plant Overflow Incident Investigation and Report – January 2020
Martinborough WWTP Abatement Notice – 15 August 2022
Memo – Martinborough WWTP Proposed Corrective Action Plan – 30 November 2022
SWDC Letter – Martinborough WWTP Abatement Notice Response – 1 December 2022
Martinborough WWTP Assessment of Effects During Remedial Works Project – 13 March 2023
Memo – Martinborough WWTP Capacity – 21 April 2023
Memo – MWWTP technical memorandum – 22 June 2023
Abatement notice A1064 – August 2023
Abatement notice A1065 – August 2023
Abatement notice A1066 – August 2023
Joint Review Report SWDC/WWL – September 2023
FAQs
Why haven’t we had more notice of this issue?
The Abatement Notice from Greater Wellington Regional Council has triggered this issue. Prior to that time and following the Abatement Notice, approvals from WWL for new applications for connection have been forthcoming.
WWL has now given us new technical advice. As a responsible territorial authority, we cannot risk further strain on the plant, with the consequential risks to mana whenua interests, the health of the waterways, public health, environmental impacts and legal action against the Council.
Why do we have to do this right now?
Specialist advice is that granting any new connections to a plant that is non-compliant and subject to an abatement notice carries a high risk. The Council has no other choice but to comply as recommended.
What alternative options to being connected to the town wastewater system (such as septic tanks) do new applicants for building consents have ?
A domestic on-site wastewater treatment and disposal system is an alternative to a direct connection to the wastewater treatment plant. Greater Wellington Regional Council is responsible for managing discharges to land, and are available to advise you on your options: www.gw.govt.nz/your-council/contact-us.
Greater Wellington’s proposed Natural Resources Plan has a permitted activity rule (Rule R63) for domestic on-site wastewater systems. If you are unable to meet the requirements of the permitted activity rule, then you may require consent.
What did Council do when it received the Abatement Notice?
15 August 2022 – Council received the Abatement Notice from Greater Wellington. Proposed corrective action plan commenced.
1 December 2022 – Council responded to Greater Wellington with a corrective action plan, as required.
13 March 2023 – Report from independent scientist to assess the effects of continued non-compliance with the land-discharge limits and efluent quality standards on water quality and ecology in the Ruamā hanga River.
21 April 2023 – WWL wrote to Council advising approvals for all new connections to cease.
All documents can be found on this page.
Isn’t some level of growth possible if we take immediate actions to improve the capacity of the plant?
South Wairarapa District Council and Wellington Water are taking immediate actions to improve the plant’s performance and bring it back to compliance, but this will take time and require significant investment.
The first step is to get approval from Greater Wellington on our compliance delivery plan and we will update the community again once this is achieved.
We will then keep the community updated on agreed key milestones as we work towards bringing the plant back to full compliance.
What if I already have a consent application in train – will it be approved?
South Wairarapa District Council appreciates the impact this decision will have on developers and people seeking to build new homes in the town. We regret having to make this decision which we know will temporarily slow growth in the region. We will pause new connections for only as long as needed.
The Council has already started working with customers who have a connection request in train to clarify their status. All permits, resource management and building consents that have been received and approved by Council will be honoured and a connection to the wastewater network made.
What happens if a developer has already invested in design and engineering work to lodge an application that will no longer be possible?
Companies and individuals considering new development, and who are currently preparing to make an application, should contact the Council and discuss their situation.
When will new connections be possible again?
We hope to have the Plant back to a compliant state within 24 months. At the same time, we will be working on a plan to increase the capacity of the plant to accommodate future growth.
The WWL advice is that new applications could be considered:
• After the plant is fully compliant
• When there is a plan in place to increase capacity
Council will make an assessment of the situation as each key milestone is met and will communicate their decision to the community at that time.
Do any other South Wairarapa wastewater treatment plants face the same risk in the future ?
Due to higher-than-expected growth in our region and the inflow and infiltration issues in our networks, we are facing the same design capacity constraints at all our South Wairarapa treatment facilities and are working closely with WWL to appropriately assess the requirements and incorporate the results into our investment planning.
Are any other councils facing a similar situation?
Yes, there is a precedent as Hamilton City Council is facing similar constraint issues within their three waters network and is currently reviewing their Connections Policy with a view that some applications for connection may need to be declined.
What does an Abatement Notice mean in legal terms?
An abatement notice is issued under section 322 of the Resource Management Act 1991. By failing to comply with the notice Council would be committing an offense under the RMA 1991. Irrespective of the notice, Council is still at risk of prosecution or other enforcement activity if the activity or inactivity in question contravenes the RMA, a resource consent, or a rule under a Plan. Greater Wellington has the right to pursue additional or alternative enforcement action at all times.
What are Council’s next steps?
South Wairarapa District Council and Wellington Water are taking immediate actions to improve the plant’s performance and bring it back to compliance, but this will take time and require significant investment.
The first step is to get approval from Greater Wellington on our compliance delivery plan and we will update the community again once this is achieved.
We will then keep the community updated on agreed key milestones as we work towards bringing the plant back to full compliance.
