The Rarotonga Environment Authority (REA) on February 22, 2023, unanimously approved another 3 months extension for To Tatou Vai (TTV)’s Environment Impact Assessment (EIA) Permit for its on-site discharge treatment plant and the temporary sludge storage facility. This approval comes with permit conditions that require both TTV and NES to adhere to a set of actions to be delivered prior to the permit expiry.
Sourcing suitable technical expertise
Since the last consideration by the REA in November 2022, an initial 3-month period was granted for the National Environment Service (NES) to seek technical advice to review the EIA reports, TTV progress reports, local NGO observations and provide recommendations to the REA for future actions.
It is appropriate for NES to seek technical or expert advice as per Section 12(2)(b) of the Environment Act 2003. The decisions made by the REA should be based on science and expert advice to meet its functions set out in the Act.
Through NES’s partnership programme, technical advice was sought from the Secretariat of the Pacific Regional Environment Programme (SPREP) and the Asian Development Bank’s (ADB) Environmental Safeguards support, to provide the appropriate technical advice under NES’s regulatory mandate for the TTV EIA projects. Two technical experts were identified through ADB’s technical assistance programme – Alan Sewell, an environment specialist with over 30 years’ experience in environmental assessments and major infrastructure projects in the sectors of energy, transport, water resources and natural resources management. The second technical expert is Lyndsay Chapple, who has over 40 years’ experience as an environmental engineer specialising in monitoring and modelling activities. Lyndsay has been involved in the licensing of a wide range of discharges from domestic, commercial, and industrial wastewater generators. Both technical experts have extensive technical expertise, particularly in the Pacific region, in water infrastructure management, wastewater and solid waste management, policy, and governance in environmental safeguards.
Scope of the technical assessment conducted
Based on the request for assistance, the technical experts provided their findings, with recommendations to facilitate discussions on a way forward. The recommendations were formed from an extensive review of the TTV EIA documents, permits conditions, progress reports and other relevant information. It was followed by virtual consultations with NES and TTV staff.
The EIA prepared by Tonkin & Taylor for the onsite discharge water treatment plant was reviewed. The EIA addresses the use of PACI as a coagulant, identified concerns of the communities and the impact on human and ecological resources. There are established appropriate toxicity limits for aluminium discharges and assessments of additional PACI impact on the environment. The second EIA Report by Tonkin & Taylor describes the sludge management process, methods of handling the sludge at different sites and its impact on water surface quality, terrestrial ecology land and groundwater quality.
Other areas covered in the review were the TTV progress reports on monitoring activities and testing results, submission by Te Vai Ora Maori on environmental concerns including overflows, sludge toxicity levels, management of sludge and the impact of discharges from the water treatment plants on the environment. Lastly, it included reviewing of monitoring mechanisms such as aluminium levels, water sampling and assessing aquatic macroinvertebrates.
Recommendations provided to the REA
The technical experts assisted the REA in providing key recommendations for TTV and NES to deliver within the next 3 months.
TTV is to:
- Develop an Environmental Improvement Plan for both Avana and Turangi water treatment plant (WTP) sites aimed at addressing options to reduce sludge and solids carryover options;
- Prepare Operational Environmental Management Plans for each of the 10 WTPs as per Framework in EIA;
- Institute improved operational measures to ensure sufficient capacity of sludge levels, monitoring of supernatant discharges for nonfilterable residues/suspended solids along with the other standard parameters, and trialing reduced PACL;
- Alter monitoring requirements such as reducing dissolved aluminum testing to once seasonal since extensive monitoring has proved it to be consistently within safe limits, photographic evidence of stream bed status of the water intakes and commit to monitoring of benthic invertebrates in the streams;
- Confirm the management and disposal of backwash sludges;
- Confirm final sludge disposal arrangements including investigating using dried sludge as daily cover at landfill;
- Discuss with the Ministry of Agriculture a pilot trial for agricultural use of sludge;
- Prepare a report to the REA on the completion of conditions stipulated.
NES is to:
- Strengthen project permit conditions over the next 3 months based on the recommendations put forward to the REA. This includes new environmental monitoring requirements, reference to guidelines for progress reports and specific mitigation actions and operational procedures for the WTPs;
- Provide TTV with a Terms of Reference guide for preparing subsequent biannual / annual progress reports;
- Review interim report for consideration by the REA towards the end of the 3 months permit extension term.
Capacity development and the next steps ahead
NES and TTV will obtain technical support in undertaking operational environmental audits of all WTPs to ensure compliance with appropriate standards. Further technical support will include training of TTV staff in proposed environmental monitoring including benthic invertebrates, plus support to NES to improve permit preparations and permit reporting templates.
Halatoa Fua, Director of NES and Acting Chairman of the REA, noted ‘the REA has taken a precautionary step to extend TTV’s permit by 3 months, for both TTV and NES to complete in-depth preparations of the recommendations made. The REA will only grant a permit extension if they consider it will not have an adverse effect on the environment. Monitoring and compliance measures will be tightened in the next 3 months to ensure processes are strengthened to protect the environment’.
In planning the way forward, Halatoa further stated ‘I would like to take this opportunity to thank ADB for providing this technical expertise and the timely completion of the report. I would also like to convey our sincere appreciation to Alan and Lyndsay for their technical advice in a specialised area that is critically needed for the Cook Islands’.