Naseby Vision Water Submissions to CODC 24 May 2013

Naseby water quality, CODC plans for improvements, the necessity for improvements, and the impact of proposed rating levels

Submission on behalf of Naseby Vision, 24th May 2013

Information has been drawn from the Naseby Community Plan, 2010, (NCP), Naseby Water Treatment Plant Water Source, Issues and Options, OPUS January 2011 (OPUS), the CODC Annual Plan for 2013/14 (AP), the Drinking Water Standards NZ revised 2008 (DWSNZ) and discussions with the Delta maintenance staff (DM).

Reputedly the Naseby water quality is very poor, and “Boil Water Notices” (BWN) are a frequent requirement, and CODC consultation has identified a demand for better water quality. We suggest that water quality is of some concern, but this pales into insignificance in comparison to concerns re potentially increasing water rates by 263% in the next 8 years. We note that the last BWN was issued in November 2012, ie. six months ago, and there has just been one of the wettest summers ever. Obviously changes made to the management of inflows into the system, and improved filtering has had a significant effect!

The NCP specified total water consumption of 62,000 m3 with a storage capacity of 320 m3, 350 connections and peak consumption per connection of 2340 litres / day. Storage capacity has been improved to 670 m3 and water consumption has decreased probably 25 to 30% since the installation of water meters. We estimate that there are about 50 “permanent resident” connections and some 300 intermittently used cribs. Thus .........

a) With total water usage of 46,500 m3 (assumed 75% of previous usage)

b) With 50 dwellings using 450 m3 / annum = 22,500 m3,

c) Then 300 cribs use 24,000 m3 or 80 m3

This example isn’t meant to be accurate, but merely to indicate some perspective between water usage between permanent residents and “cribbies”. Presently all dwellings pay the same water rates, and we suggest that an increase in water rates to the level of $1,207 / dwelling or $1,706 for water and waste water for Naseby would be an intolerable burden, and likely cause an exodus of some residents, and many of the holiday house owners. This would be a considerable demise for Naseby, in the light of the NCP which was discussing development of the town.

Proposed Improvements in Naseby Water:

OPUS provided 4 options for improvement of water quality for the Naseby supply. The cost was in the range of $150,000 to $380,000. Expenditure of $300,000 and an increase of $12,000 / annum in operating costs was deemed to require a water rate increase of $155 / annum (Russell Bond – Water Services Manager, memo to Council 17th March 2011). This information is difficult to reconcile with the proposed increase in water rates from $477 (2013/14) to $1,259 (2021/22), a $782 increase for potable water only.

Actual Improvements Required for Naseby Water, The DWSNZ:

To quote “DWSNZ set out to protect public health and apply only to health- significant determinands. However because the public generally assesses the quality of its water supply on aesthetic perceptions, guideline values for aesthetic determinands are also provided, although they are not part of the water quality standards.

From this we conclude that the turbidity problems in the Naseby water supply which result in BWNs are for aesthetic reasons only as far as turbidity is concerned. Certainly it is not satisfactory that at the times of significant rain events the levels of faecal coliforms (in effect the “bioassay” of other pathogens such as giardia, cryptosporidium and protozoa) rise to unsatisfactory levels. The solution to this problem is the installation of a UV treatment capacity which also reduces the requirement for chlorine which contributes to an unsatisfactory taste. This treatment should remove any health concerns for Naseby residents.

Turbidity could be reduced with the development of an existing pond juxtaposition to the Treatment Plant, and this would provide a much needed fire fighting reservoir of much greater utility than is available now.

The total cost of these two improvements should be less than $100,000, and would give a more digestible expenditure for residents.

Other Options for Naseby Water:

Already the cost of water for Naseby residents is high! With limited water usage many of the non permanent dwellings could operate satisfactorily on rain water tanks, with or without “point of entry” filters (available at a cost of approx $1,500). Any alternative supply options will cause a lower demand on the Naseby supply, and some rates recognition could be considered for property owners who wished to consider such options.

Preferred Rating Options for Naseby:

Naseby Vision prefers the District rating option for water supply, due to the economic consequences for the town in the event of the projected large increases in water rates under a “user pays” proposal. Clearly however the installation of UV treatment capability will mean compliance with the human health concerns under the DWSNZ specifications, with the only other concern being turbidity which is largely under control now (last BWN) 6 months ago), but which might be improved with a modest cost of development of an existing dam. Note : The specifications in the DWSNZ re turbidity are “guidelines” only, and thus not legal requirements. With the suggested improvements achieved at a relatively modest cost in comparison with Council forecasts, the Naseby Water Supply may well be stable for a considerable period and thus not requiring very expensive future upgrade for some time.

Naseby residents do have concerns about the future rating levels, particularly with the projected $multi-million major upgrades required in Cromwell and Clyde for wastewater and Alexandra for potable water.

We suggest that further detailed consultation is still required with the Naseby residents (with the water group which has been considering the issues now for some years) re the fairest options for the town, and look forward to those in the future.

Submission to the CODC re Water Supply rating in the future:

Summary: The continuation of the present funding model for water supply to residential properties in the CODC area will in the future be a major cause of decline of some of the smaller communities. This particularly relates to Naseby where about 85% of the dwellings are occupied for only 10 to 15% of the time as a maximum. Thus Council should either adopt a subsidised funding model or consider the use of point of entry units which would physically filter the water as well as UV treat it.

Presently the concentration of upgrading water supply systems for rural towns throughout NZ is an expensive legislative requirement for Councils. The costs per resident, on a per dwelling basis are becoming prohibitive. For Naseby the cost on a per dwelling time occupied basis is even more prohibitive.

  1. The Current System: Funded by the ratepayers on a “cost to supply” basis will put an increasing burden on Naseby, Omakau and Patearoa? (Not mentioned in the documentation from the CODC).

    Naseby would end up with water (only) rates of $1,259 up 263% by 2021 / 22. This situation with only about 50 households permanently occupied out of a total of 360 would mean that the town would be progressively more expensive to maintain a dwelling, and in effect would likely bring on a progressive decline for the town.
  2. District Funding and or subsidised funding would a preferable option as outlined in the District Plan document, and would provide substantial reductions for Naseby, Omakau, Ranfurly and Roxburgh.
  3. Clearly small community water schemes which have marginal water quality values require major expenditure to bring the water quality up to the legislated standards. Often this expenditure cannot be justified because of a small number of residents. Naseby is a special case being a holiday destination where about 85% of the dwellings are occupied for only about 10 to 15% of the year – some less than this.

    The Ministry of Health (MOH) has considered the use of “point of entry units” which have a filter plus ultra violet (uv) light to kill organisms. Their deliberations are written up as Section 12, but the specifications have not at this stage been incorporated into law. It is likely in the future that these standards will be recognised as such.
  4. The Council might require Naseby residents to install a filter / uv unit, which could be installed for a cost of about $1,300 which could handle incoming water (to the house) at a rate of 45 litres per minute. Another option is for smaller filter units to be installed under-sink as a requirement for all dwellings – for this to be effective, the uv option would have to be part of this.

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