Nature Calls update 2023

On the afternoon of Friday 31 March 2023, Horizons Regional Council let us know our consent application had been rejected due to insufficient information.

We lodged our application in December. The next step was for Horizons, which is the consenting authority, to undertake a ‘completeness check’. This is an administrative check required under section 88 of the Resource Management Act (RMA). This occurs before the application proceeds to the next stage of review and consideration.

Section 88 of the RMA gives a consenting authority 10 working days to determine whether the application was complete. We agreed to an extension given the impact on resources during the weather events during this period, which provided Horizons with 47 working days to undertake the review.

We are still working through the detail that has been provided by Horizons Regional Council and will look to meet with them with urgency to get more information to go through the next steps and get some new timelines in place.   

While disappointing, we want to reassure our community that Palmerston North is committed to getting our consent and obtaining the best outcome for our city, our environment and our awa. 

Horizons Regional Council has released the following statement to media: 

"Horizons Regional Council has undertaken a robust and comprehensive review of the application made by Palmerston North City Council to discharge treated wastewater to water and land. We would like to commend and acknowledge PNCC for the large volume of work and scale of assessment undertaken to support their application. The initial review of any consent application received is to ensure that an application contains sufficient information to enable assessment and undertake a robust consent process. Unfortunately the application was lacking information, specifically with respect to the proposed discharge to land component of the application. As a result, Horizons has returned the application as incomplete. Horizons is committed to working with all parties moving forward, to provide advice to ensure that a complete consent application can be lodged."

The consent application for how we’re proposing to treat and discharge our city’s wastewater/resource water over the coming decades has now been submitted to Horizons Regional Council.

After four years of significant technical work and public engagement, our application outlines how we’re proposing to treat the city’s wastewater/resource water to the highest standard currently available in New Zealand.

Mayor Grant Smith says lodging our application is a key milestone for the project.

He says our consent application proposes that wastewater/resource water treated to one of the highest treated wastewater processes in New Zealand for municipal wastewater would be discharged to a combination of river and land.

75% goes to land when the river is below half median flow and 25% will go to the river. When the river is at higher flows, more treated resource water/wastewater will go to the river.

“Having such a high treatment process means this water, when used on land, is considered a resource and could be used for other purposes including irrigation, growing crops or watering parks and reserves. In fact, we should now call it ‘Resource Water’. As part of our consent application, we’ve also made a commitment to have an adaptive management strategy which will look at ways on how we could reduce the amount of wastewater/resource water entering our plant, and commit to technological improvements to reduce the amount of water entering our awa (river).”

Council sought legal advice in 2021 which confirmed that we must continue to lodge and work on our consent application despite proposed government reforms, as it is a legal requirement of our current consent. The Department of Internal Affairs, which is managing the Government’s water reform, has been an observer at our reference group meetings.

Extensive work will continue over the coming months

Council’s Chief Infrastructure Officer Sarah Sinclair says while officially lodging our consent is a major milestone, there will be a significant amount of work that will be continuing while Horizons’ review our application. In essence, this is the start of the project in a physical sense.

“This work includes continuing to negotiate leases or purchasing land for application sites, more river mixing close to where it enters the river, land testing, daily sampling and analysis, ongoing stakeholder, partners, iwi and community engagement, any legal needs in regards to work for the river or land discharge, cost estimates for land and river discharge sites.”

We will continue to work closely with our community, partners and stakeholders

Throughout this project we’ve worked closely with key stakeholders, iwi and hapu, businesses, the farming sector and our community – including two formal public consultations.

Prior to the September 2021 Council decision, a project steering group had been in place. This group was made up of representatives of Council officers, elected members, and Rangitāne as mana whenua for our city.  Following the council decision in 2021, the steering group was disestablished and replaced with a project reference group. This group includes representatives of Rangitāne, Ngāti Turanga-Raukawa, Rūnanga o Raukawa, Te Roopu Taiao o Ngāti Whakatere, Department of Conservation, Environment Network Manawatū, Federated Farmers, Fish and Game (Wellington Region), Food & Fibre Forum, Manawatū Chamber of Commerce, MidCentral DHB and the Trade and Industrial Waters Forum.

The reference group has been our key group for working on this project at consent development stage. In time we will also be setting up an advisory group for the adaptive management strategy planning. At this point in time, we have not determined the make up of that – but we expect council, business, farming and iwi representation.

Horizons’ Regional Council will now start assessing our consent application

Horizons’ and Palmerston North City Council officers met regularly over the past year, and now that the consent has been lodged, staff will meet in the early new year to go through the application in detail.

Horizons’ may ask for more information, which is not uncommon for large infrastructure projects like this.

The process of reviewing, having hearings, and granting consents can take a long time for large infrastructure projects like this.

Council’s Chief Infrastructure Officer, Sarah Sinclair, says that’s why the application has provided a lengthy period of time for any future treatment to commence, technology advancements and discharge changes to be in operation.

“When we reviewed other consent projects of this scale in our region, they took between 3-5 years to complete. We’ve estimated we may then need several more years to get the necessary building consents and for the associated construction.”

Whilst Council is proposing that the new treatment and discharge could be operating in 2033, these timeframes are determined by Horizons’ Regional Council and the Environment Court if there are any appeals.

Information about Nature Calls will continue to be shared periodically throughout the consenting process, where appropriate. We will continue to share updates to ensure our community and the wider region continues to be involved and informed on this important project.

Updates will be available at www.naturecalls.nz

We are applying for consents to discharge highly treated wastewater from the new / upgraded wastewater treatment plant to water, land, air and for a new river discharge structure. 

We’re also applying for short-term consents that would mean we can continue to operate our current wastewater scheme past our existing consent expiry in 2028, just in case it takes more time than expected to get our consent application. 

Our application is only related to the discharge and treatment of the wastewater.

Treatment summary

You can watch a video explaining the current treatment here:

The proposed treatment is outlined in a video here: 

The two key significant new steps to our treatment are introducing the removal of nitrogen, which can at high levels affect plant and freshwater life in our awa (river.) The second new step is microfiltration, which will enable us to remove particles as small as 0.04 microns, which are smaller than the human eye can see, and includes things like bacteria and viruses.

On top of existing treatment processes, this will ensure our treated wastewater is so well-treated it can be considered a resource for other purposes – like growing crops, irrigation or watering land. It is still a couple of treatment steps away from drinking water though, so it couldn’t be used for that.

Discharge to river summary

We currently discharge to the Manawatū River all the time, but under our new application we’re proposing to do this less frequently in the future.  We’re proposing that the treated wastewater (or resource water) would be diverted to land when the river is running at low levels, which we typically see in summer. The reason for that is that when river levels are lower, the impact of adding the treated wastewater has more of a chance of having a negative impact on freshwater plants or species.

Currently the treated wastewater, after four days of treatment, enters the river close to our treatment plant on Tōtara Road. In our application, we explain that we’re planning on moving that discharge point to around 4kms downstream, close to Walkers Road. We’re proposing to move the pipe downstream for a few reasons. The first is that the river is deeper and flowing faster at that area, which means the treated water mixes with the river water more effectively and efficiently. That part of the river also hasn’t changed much over the past century, and the final reason is we’re planning on rezoning land to allow for more housing in the western parts of the city and this means that the discharge structure wouldn’t be close to residential areas. We’ve discussed this location with Rangitāne and with Horizons’ engineers.

Despite high treatment quality and some wastewater to land, we recognise there are still residual negative effects on the mauri of our awa. Instead of an engineered treatment wetland like we’d earlier considered, Rangitāne have advised us that offsetting the residual effects on the mauri of the awa is more appropriate and another part of the awa environment should be restored.

A location for this hasn’t been confirmed and will continue to be worked on as part of the Adaptive Management Strategy.

Discharge to land summary

We’re going to seek a global consent for the land discharge, which is an approach used for other types of infrastructure projects. This means we are saying that we have identified an area of land that we believe can be used for the discharge of wastewater, rather than specifying certain sections of land. This area can be seen in the image below.

Not specifying land means that Horizons’ will likely need us to supply more information.

For irrigation you need soil that drains well and soil testing in the area we’ve identified has confirmed there are the right soil types for the discharge of wastewater. For the amount of treated wastewater/resource water to be discharged we will need between 500-1200ha of land, and extra to provide setback from sensitive activities and resources such as rivers, lakes and streams, houses, schools, marae etc. This would be the largest land discharge area in New Zealand.

We have had discussions with two landowners in this area which could be ‘pilot’ sites for us to further investigate as we move through the consenting process.

There are a range of options for how the land irrigation/discharge could work – this could include purchasing the land, leasing the land and us managing the operation, or contracting it to the landowner to do it.  It is still early stages and conversations will continue.

Until we identify land for the irrigation, we cannot determine how the resource water could be used- eg for crops/irrigation etc.

We have spoken to stakeholders like Fonterra during this project and will continue to do so.

Adaptive management summary

Our reasons for having adaptive management be part of our consent application are based on three key objectives: reducing the amount of wastewater being discharged into the river and the restoration of natural awa landscapes, enhancing the quality of the treatment of the wastewater over the consent period, and looking at the wastewater as a resource.

As part of our consent application, we have provided an example of an adaptive management strategy, but the actual strategy will be confirmed following the consent being approved. Council and Rangitāne will lead the development of the strategy, but other parties could also play roles. Things that could be included are reducing the amount of wastewater entering our plant, diverting more wastewater to land, if we re-use water then potentially diverting more wastewater from both the awa and land discharge sites, using the water in other non-drinking ways eg: for industrial purposes, looking at new or emerging treatment that could enhance the treatment, and re-using other by-products including for energy of our wastewater plant.

In September last year, Council chose to have the highest treatment currently available in New Zealand and made a commitment to continue to reduce wastewater in the city, and to consider it as a resource. The treated wastewater would be discharged the Manawatū River 75% of the time and irrigated on land when the river is at below median levels.

We’ve indicated we will be lodging our consent application with the regulator, Horizons Regional Council on 31 December 2022. 

From then, the regional council considers and may choose to notify the consent application as part of its process. Council will continue to do significant work during this process.  

River discharge location close to being confirmed  

Over the past few months, we’ve been doing further modelling on the river and have identified a potential location for where the highly treated wastewater could be discharged from. Currently we’re modelling what that environmental impact would be, and then we will be able to confirm it. We’re continuing to work closely with iwi on this work.   

Land work is progressing 

The land component of our consent application is our most challenging element to complete in time for our consent to be accepted. A lot of work is planned for the next three months.  

In our last update we said we’d identified a large area west of the city, close to our treatment plant, which potentially had the right soil types for absorbing treated wastewater [see map below]. We contacted landowners within this area in about soil testing in May and have now been able to test three properties. Those tests confirmed that the area had the soil types previously identified in our desk top assessment.

We stated at the time and will reiterate that where we tested does not mean we want to use those properties for the irrigation. People who own property in the area identified in the map will also be receiving this update. 

A summary of the soil testing written in August is now also available. The 3 types of soil that were tested for are known as Gley, Recent/Raw, and Pallic.

The report states that the best soils for drainage are those that are recent/raw, and that if that soil type is used, we’d need around 600 to 710ha of land, and 75,000m3 for storage. This is less land than we indicated in September 2021. 

Gley soils were the next most effective for drainage, but only 38% as effective as the recent/raw type, meaning they’d require more land. 

Pallic soils were deemed to be extremely restrictive and could pose a high risk of significant cost escalation. 

The report only details testing on 2 of the properties, as the third property was for sale and the testing was done as part of due diligence. The testing showed that property was not suitable for wastewater discharge.

Please note, Figure 3 has been removed from the report as it identifies individual testing locations on private land. As these were given on a voluntary basis by landowners, we want to protect the locations and their individual test results.

Soils Interpretive Report

We’re looking at applying for a global consent, where we’d get consent for the discharge for a general area, only needing to identify 1 or 2 properties to use as the example for the consent.

This approach would mean we wouldn’t need to procure all 760 hectares needed during the 30+ year consent, in advance of that land being needed. This limits disruption to the farming community. It also means that any potential new Three Waters Agency would be able to determine the best locations based on its needs.  

We are in the final stages of confirming some pilot properties, based on size and soil types, and will be contacting those landowners directly before mid-October.   

We’ll be asking them what their long-term plans are for their properties and if they have any interest in selling or leasing land to us from 2028, when we will need it.   

First look at upgraded treatment plant now available  

Council is committed to having the best treated wastewater in New Zealand, and our proposed methods will have our treatment amongst the world’s best, and just one step away from drinking water.  

There are 2 significant new steps. The first is introducing the removal of nitrogen, which can at high levels affect plant and freshwater life in our awa (river.) The second is microfiltration, which will enable us to remove particles as small as 0.04 microns, which is smaller than the human eye can see and includes things like bacteria and viruses.   

A new video released today shows what our existing treatment plant will look like with these new steps included. Watch it to compare our current processes to our new process.   

This concept video only shows our current proposal, but we’ve also committed to improving the plant or processes if technological advances could further improve the quality of our treated wastewater.   

As part of our consent application, we’re also looking at adaptive management. This includes:   

Our project reference group, made up of several stakeholders, technical and iwi representatives is working through this.      

We’ve only got a few more steps before lodging our consent 

With the clock ticking, the next step for our Nature Calls project is to prepare the consent application, pulling together the five years' worth of technical work and assessments. Our reference group will continue to meet and work on the adaptive management strategy.

Due to the impact of Covid-19 on our timeframes, and needing more time for lodging our consent, this week Council brought forward already budgeted money from next year’s Nature Calls budget into this year’s budget. As it was already budgeted money, this has no additional impact on ratepayers.  

While the government is working on the Three Waters Reform, we are legally required to continue with this project as it is a requirement of our consent.  

We will provide another update when we lodge our consent. Once it has been accepted by Horizons Regional Council, we will make it publicly available on our website.

Significant work is underway as Palmerston North City Council prepares to lodge its consent for the future treatment and discharge of its wastewater for up to the next 30 years. 

In September 2021, Council confirmed that it’s future discharge would be a hybrid option, with treated wastewater being discharged to the Manawatū River 75 per cent of the time, and during the remainder of the time a combination of land and river. Council also committed to having the highest treatment in New Zealand. 

Since then, eight major pieces of work required as part of our consent application have gotten underway. These include further modelling of wastewater with various population projections for the next 50 years, monitoring the river water quality and ecology, designing the new additions for our treatment plant, determining the pipe requirements for the land discharge, working on mitigations for any impact on the river or land, finding suitable areas for land discharge

Land testing due to start

Chief Infrastructure Officer Sarah Sinclair says the option requires us to locate land where irrigation could occur, but we don’t need to have purchased the land at the time we lodge consent.

“To identify this land, we need to test soil. We will be doing that west of Palmerston North, including some properties in the Manawatū and Horowhenua Districts. We have selected some properties where we would like to test to give us a good cross section of soil types and will be contacting those landowners. We’ll also be letting people in the community know that we are testing, as we may need to test other sites as well.”

Ms Sinclair says testing land is not necessarily an indication that Council would like to purchase that land.  

“Palmerston North City Council have always said we would like land purchases to be on a willing buyer/willing seller basis, so over the coming years we’d be looking to have those conversations and carry out further testing if needed. If large properties come up for sale in Palmerston North’s west, and close to our treatment plant, then we will consider testing it, and may consider purchasing. We will be working closely with landowners over the coming weeks and months directly as we work through this process.” 

Consent application to be lodged this year

Our wastewater consents expire in 2028. We were due to apply for new consents by June this year however over the past two years there have been significant delays to our work programme due to COVID-19 lockdowns affecting both public engagement, and the wide range of scientific and technical tests needed to prepare our consent application.  

We have advised Horizons Regional Council that it will take us until the end of 2022 to put forward our new consent application. Horizons has acknowledged the likely programme delay and is aware of the significant and complex work that Council have done to develop our best practicable option and progress the consent application. 

This wont affect our ability to design and build the new treatment or discharge requirements in time for the 2028 consent expiry.

Ms Sinclair, says although this is a difficult decision, its one we have to make.  

“We take our legal and environmental responsibilities very seriously, but the pressures placed on our technical teams by the pandemic mean we will not be able to complete important scientific analysis for the modelling of our river for the future, wetland options or land testing by June.  Protecting our environment and ensuring the best outcomes for our community have always been our top priority, and we need extra time to ensure we can do just that.” 

She says Council has informed local and regional iwi and hapu and key stakeholder groups that we would need to seek this extension, and have the support of Rangitāne in acknowledging that the delay is necessary to deliver a complete consent application.  

Stakeholders also continuing to feed into Nature Calls

We have already committed to having the best-treated wastewater in New Zealand, but our Council has also committed to constantly looking at how we can do better over the life of the consent. We’re working with our Project Reference Group and technical experts about how we can do this. The key components include how we will reduce the amount of wastewater over time, reducing the volume of treated wastewater entering the river, how we can re-use components of the wastewater and a strategy for how we will respond to any environmental uncertainty or innovative technology over the life of our consent.  

Our Project Reference Group first met in February and meets monthly to help guide Council officers and consultants about the management and treatment of our wastewater in the future, and feed in ideas for the adaptive management strategy. Having such a diverse range of groups involved means everyone gets to hear each perspective.  

More updates throughout 2022

We will continue to provide our community updates throughout the year, and a deeper look at some of the technical work we are doing.  

All information about Nature Calls is available at naturecalls.nz