From the CEO
It has been an extremely busy period over the past three months for the water industry. Each business has dedicated significant resources and time to pursue efficiencies as part of the Fairer Water Bills initiative. Water Corporations are now building these efficiencies into their Corporate Plans in time for 1 July. In addition to managing the Fairer Water Bills initiative the OLV are also progressing a review of the Economic Regulatory Framework and VicWater looks forward to contributing to this review.
By the time this edition is published we will have run this year’s Finance Conference which is expected to be another great event. Delegates will hear from Professor Graeme Samuel AC, the independent reviewer for the Fairer Water Bills initiative and future economic regulation, Vinh Giang, a motivational speaker who uses magic as his metaphor and recently appointed Sector Director of Environment at VAGO, Roberta Skliros.
An important part of our annual calendar of events are the dinners with the Minister for Water. These dinners are hosted at the Treasury Corporation of Victoria and are an invaluable opportunity for the industry to raise and discuss a broad range of topics and to highlight the great work that is being done across the industry. These dinners were held in May this year and were a great success.
I am pleased to be able to give you a sneak peak at some of the high calibre presenters that we are working to secure for the VicWater Annual Conference; Sam Cawthorn, an author and professional speaker who specialises in personal and corporate resilience; Piers Clark, Commercial Director from Thames Water in the United Kingdom and Fiona O’Loughlin, the well-known Australian comedian for the dinner entertainment.
In May, VicWater facilitated an interactive session to elicit comments from the industry on a review of the State Policy Planning Framework. This workshop was made up of three sessions and was facilitated by John Glossop from Glossop Town Planning. John focussed the workshop discussions around the main issues from the water sector’s perspective; the planning vision, infrastructure, environmental values and risks, landscape and built environment and housing. The outcomes and comments received at this workshop formed the basis of an industry submission.
In April the VicWater Board travelled to Warrnambool to hold not only their meeting but also to view some of Wannon Water’s innovative and exciting projects. The Board visited the site of the internationally recognised roof water harvesting project and they also visited an extremely exciting project looking at how goldfish can be used to help reduce the cost and environmental impact of sewage treatment. In addition to the site tours the VicWater Board also invited a number of local water sector dignitaries to join them in an informal dinner to foster industry sharing and understanding. Wannon Water, Corangamite CMA and Glenelg Hopkins CMA joined the VicWater Board for this dinner. The VicWater Board conduct one regional Board visit each year, which is a highlight of the VicWater Board calendar, providing an opportunity to learn more about the role of water across the state and the unique contribution that water corporations make to the communities they serve.
Finally I would like to welcome James Cleaver to the VicWater team. I am very excited about James joining us and believe that he will contribute enormously to VicWater as well as the broader industry. James brings with him extensive experience and strong networks that he has established in his time at both the MAV and the Murray Darling Basin Commission.< PreviousNext >
James Cleaver - New VicWater Employee
Newly appointed to the Policy and Projects Co-ordinator role at VicWater.
I was born in Melbourne and have lived here most of my life, except for three years in Canberra and two years in California, USA.
I am a keen cyclist, including pinning on a number for an occasional race. I am also a part owner of a bike shop in Melbourne.
Water industry experience – how long you have worked in the industry and any previous experience in the industry?
I began my career with the Murray-Darling Basin Commission (MDBC) in Canberra. I started there in July 2006 when the drought moved into a critical phase – each month, minimum inflow records were being smashed – it was a remarkable time.
More recently, I have been working at the Municipal Association of Victoria, with responsibility for all water policy and transport, including councils’ role in the OLV’s Melbourne’s Water Future Initiative.
Where do you see the value in VicWater’s working groups and steering committees?
All the VicWater groups provide opportunities for water corporation board members and officers at many levels to connect across industry and with government. These connections make us all more effective at doing our jobs and achieving our organisation’s objectives.
From your perspective what is the top issue affecting you in your current role; and/or your business; and/or the water industry at the moment?
There is a huge amount going on in the industry at the moment. I am lucky that I have had a bit of background in the OLV’s policy program, among other things, so I can hit the ground running.
Anything else you want to add?
I am really happy to be on the team and I look forward to meeting as many of you as possible.< PreviousNext >
Jon - Theobald - VicWater Leadership Award Winner
I am the Environment Manager at South East Water.
I live on the Mornington Peninsula with my gorgeous wife and beautiful 3 year old daughter. We love the beach and spending time in the garden. Our greatest battle is against the local wildlife consuming our vegie patch before we get to reap the rewards.
Water industry experience – how long you have worked in the industry and any previous experience in the industry?
I started with South East Water back in 2007, as the water conservation manager. This was during Melbourne’s biggest drought. Prior to that I spent a number of years working in the Department of Defence as an Environmental consultant.
What VicWater group(s) do you participate in?
I actively participate in the VicWater/EPA water industry group. This group aims to deliver innovative environmental policy reform. It focuses on achieving great outcomes, looking past barriers and the limitations of current approaches.
In 2010, I participated in the VicWater Industry Leadership Program. A program focussed on developing my leadership potential.
What value does your involvement in the VicWater group(s) bring to you personally; and your employer?
The VicWater groups provided me with multiple opportunities for self development, as well as occasions to learn from other colleagues and organisations. It also provides the setting to share with my cohorts the challenges facing the water industry.
Additionally the VicWater groups assist in uniting the water industry to provide unified front and challenge the current regulatory environment.
From your perspective what is the top issue affecting you in your current role; and/or your business; and/or the water industry at the moment?
The top issue affecting my role is the huge opportunity presented through the current regulatory reform process. Moving towards a risk based policy framework would allow greater flexibility in designing and planning the future infrastructure to ensure it mitigates the associated risks. This ideally delivers the best community outcome at the lowest cost.
This theme is consistent with the challenges facing the water industry. That is, to ensure our customers embrace the value provided to them via adequate sewerage and water services. I believe the community is becoming further and further detached from valuing such services. It was only two generations ago that the majority of sewage from houses was emptied into open drains that flowed into street channels. I’m sure today’s sewerage system would be seen as” good value” to anyone that had to cross over an open drain containing raw sewage.
Anything else you want to add?
When I found out that boiling water freezes quicker than cold water, I knew that the water industry would be a fascinating environment to spend my working life in.< PreviousNext >
David Sheehan - Coliban Water
David Sheehan was appointed as General Manager Water Quality Performance & Regulation at Coliban Water in February this year. In this interview he looks back at 30 years in the water industry and looks ahead at the challenges facing Victorian water corporations
Coliban Water Managing Director Jeff Rigby said: “David is a valuable addition to our Executive Management Team. After a thorough recruitment process he was the standout candidate to lead our Water Quality Performance & Regulation team.
“The team is responsible for several key strategic initiatives which David’s in-depth knowledge and experience in drinking water quality regulation will help deliver.”
Mr Sheehan has worked in the water industry for more than 30 years. He started at Sydney Water as a professional cadet just four weeks into his microbiology degree at the University of Technology, and is enjoying the challenge of being back at a water corporation.
“I am delighted to be at Coliban Water and excited to take on the challenges in water quality that Victorian water corporations are facing,” said Mr Sheehan. “I spent nine years at the Department of Health preaching the theory of risk management and this role provides me with a great opportunity to put that theory into practice.
“My previous role gave me an overview of how drinking water quality is managed across the state and I have been lucky to be involved with national and international committees that deal with drinking water quality. I can bring that intelligence to this role.
“What we do in Victoria is still close to the benchmark for drinking water quality management anywhere in the world. Our Safe Water Drinking Act 2003 was the first of its kind in Australia and one of the first in the world to put in law the requirement that water corporations have risk management plans for the supply of drinking water.”
This proactive approach to the risk management of drinking water quality is quite different from when Mr Sheehan started his career at Sydney Water in 1984.
“When I started at Sydney Water the water industry was pretty much a pumps and pipes business. It is a more professional and dynamic industry now with the adoption of risk management, and water corporations are a lot more customer-focussed.
“With the Safe Water Drinking Act there is complete transparency about the quality of drinking water across the state. When you have a totally transparent system you end up with less criticism.”
Although major water quality incidents are rare, Mr Sheehan has had first-hand experience of incidents from his time at Sydney Water and the Department of Health.
“I was working in one of Sydney Water’s microbiology laboratories at Sydney Water during the 1998 Cryptosporidium incident which affected three million customers. It was a highly publicised incident and caused major public alarm. One of the positive outcomes was that it paved the way for improvements in how water supplies were managed.
“With other major incidents like bushfires and floods it can often be a case of not being able to verify if the water is safe to drink and you always have to err on the side of caution. Understandably, there was a lot of community concern around water quality following the tragic Black Saturday bushfires, and we were lucky that the fires didn’t impact Melbourne’s catchments.
“The Upper Yarra Reservoir incident in 2007 [where heavy rainfall after the drought conditions produced turbid inflows] was another major incident with boil water notices issued to approximately 6,000 customers. Likewise, the January 2011 Floods put a lot of sediment into reservoirs which affected water quality and resulted in boil water notices. These incidents were well handled by the affected water corporations.”
Mr Sheehan is a strong advocate for the crucial role operational staff play in maintaining water quality and says water corporations potentially undervalue the reliance they have on staff to achieve the desired outcomes.
“Water operators should been seen as allied health professionals. If they do their job well they make communities healthy; if they do it poorly they can make them sick.
“There can be an over reliance on technology to deliver all the solutions. Technology provides a lot of security and confidence, but it’s only as good as the systems that back it up. There’s got to be a human element in there. Visual observations still have a big part to play in ensuring the delivery of safe drinking water, backed up with sensible and reliable monitoring data.
“The biggest reduction in risk comes when you move from end point monitoring, where you are checking what’s happening at the customer tap, to checking how treatment processes are working. If your barriers are working well then all you should be doing at the customer tap is verifying that everything is fine.”
Mr Sheehan is aware of the challenges facing the Victorian water industry and the expectation that water corporations have to do more with less but, as he puts it, “public health should be considered as a non-tradable commodity”.
“Health standards are based on good science and understanding, and that’s your line in the sand. You can’t trade off health.
“Water is an undervalued product. There is a perception that because it falls from the sky it just turns up at your house. Prices are getting closer to the actual cost recovery for the collection, treating and distribution of drinking water and disposing of wastewater.
“There is a huge amount of infrastructure and resources involved in making sure that when people get up in the morning they can flush the toilet, have a shower and fill up the kettle for a cup of tea.
“What other product can you pay $2 for and get a tonne of it delivered to your house?
Convincing some customers that having access to safe drinking water and wastewater services is good value for money is a challenge facing all water corporations, as is the possibility of a drier climate.
“Coliban Water has also had to deal with severe drought and a whole of water cycle management approach can provide more security of supply, but how do you best use the water resources available and still protect public health?
“The four larger towns in our region – Bendigo, Castlemaine, Echuca and Kyneton – are on growth projections and the rest are either stable or declining.
“The goal is to provide everyone with access to a safe drinking water supply. With Bendigo, for instance, every new development raises questions on how our business will supply water and service them. It is also important to consider alternative and cost effective solutions to deliver water to smaller towns.
“Water is not a limitless resource and we will have to consider a range of options in the near future, and how we best utilise these options, and still deliver a safe, reliable and affordable product to our customers is one of the exciting challenges the water industry faces.”< PreviousNext >
Water Industry Body Inspects Local Innovations
Local innovations in water and sewage treatment were in the spotlight when the Victorian Water Industry Association (VicWater) Board held their regional tour in Warrnambool in April 2014.
The tour included inspections of Wannon Water’s innovative Roof Water Harvesting project site and aquaculture fish hatchery ahead of the VicWater Board meeting held in Warrnambool.
Wannon Water Acting Managing Director Andrew Jeffers said the site tours provided an excellent opportunity to showcase some of Wannon Water’s more recent innovations to the wider Victorian water industry.
“At Wannon Water we are continually striving to develop smarter and more affordable water and sewerage services for our customers and local communities,” Mr Jeffers said.
“We have built innovation into our corporate mission and values to help us capture creative ideas to continually improve what we do, such as harvesting roof water in new housing developments, using goldfish to aid in sewage treatment or providing treatment of salty trade waste to support the region’s largest industries.
“This visit from the VicWater Board allowed us to demonstrate this innovative thinking and share our learnings with the wider industry so that other Victorian water corporations might also benefit from adopting similar projects across the state.”
The multi-award winning Roof Water Harvesting project involves collecting rainwater from rooftops in new residential subdivisions then transporting and treating it so that it can become part of the drinking water supply. The demonstration site in Warrnambool has shown the roofs of new urban growth areas can generate enough water to meet the demand in those areas.
The aquaculture project uses goldfish to remove nutrients and sludge from sewage, reducing the need for costly de-sludging of sewage treatment lagoons and lowering the amount of energy used.
VicWater Chairman Doug Shirrefs said the Board welcomed the opportunity to visit the south-west and inspect some of the more recent innovations in the local water industry.
“Wannon Water is an industry leader in innovation and the Roof Water Harvesting and aquaculture projects are excellent examples of that,” Mr Shirrefs said.
“Wannon Water’s willingness to share the learnings from these innovative projects with the wider Victorian water industry is to be commended.”< PreviousNext >
Dam Safety Training
Southern Rural Water is ahead of the game when it comes to dam safety training – recently holding training sessions with dam experts from New South Wales.
The sessions were held in Willow Grove and Bacchus Marsh. They were aimed at storage operators, but were also attended by dam engineers.
“We organised the course after we realised our operators were looking for more detailed dam safety training, but there wasn’t anything suitable in Victoria,” said Manager Headworks Assets, Joe Matthews.
“The NSW Dam Safety Committee regularly runs training courses presented by Norm Himsley and Paul Heinrichs, who are both very well respected in the industry.”
Southern Rural Water approached the pair to put together a condensed version of their course, with specific focus on SRW dams and inspection programs.
In order to offset some of the cost, neighbouring dam owners were invited to attend.
“The lack of more detailed dam safety training in Victoria was obviously an issue for them too, as there was a great response,” said Joe.
“We had 26 Southern Rural Water staff joined by 30 others from Gippsland Water, GDF Suez, Melbourne Water, Coliban Water, Barwon Water and Central Highlands Water. “
The feedback from attendees was extremely positive, particularly from the storage operators.
“The training we received was excellent,” said one. “It was also very interesting to hear about the presenters’ experiences with overseas dams.”
The sessions also included presentations by Southern Rural Water staff, and a feature study of a dam followed by an inspection tour. The Willow Grove course focussed on Blue Rock Dam whilst the Bacchus Marsh course focussed on Merrimu Dam.
“It was a great event, thanks to the expertise by Norm and Paul, and the hard work of our organising committee at Southern Rural Water, particularly Mark Hore, our Manager Dam Safety Surveillance,” said Joe. “It was the first, but it definitely won’t be the last.”< PreviousNext >
Digital Water Meters: Innovation for the Future of the Water Industry
Victorian water retailer South East Water has seen strong early indications of benefits for the water industry and its customers through innovative digital water meter trials in Melbourne’s south east.
“We saw an opportunity to be more proactive in the identification of leaks for our customers and incorporating innovative and forward-thinking technology into our business is always at the forefront of our minds,” said South East Water Managing Director, Kevin Hutchings.
The advanced technology, initially tested in 2013, can read the volume of water that enters a property in 30 minute intervals and wirelessly transmit water consumption data to a central gateway. The data is then integrated into technology systems. Several trials are now investigating and evaluating differing technologies.
“This enhanced communication link used in the digital water meters can provide water readings in 30 minute intervals and all but eliminates the need for on-site meter readings. The greater frequency of reads generated by this new technology means that we can alert customers to any potential leaks much faster than ever before,” said Mr Hutchings.
Trialling the next generation of water meters will aid in the identification of the most efficient ways to inform customers of their water use. With over 13,000 kilometres of water pipes, it will also help to optimise the water network and focus future investment in water infrastructure where it’s needed most.
To complement the digital water meters’ functionality, some residents involved in the trials have access to an online self-service environment.
Through the site, customers are able to explore their daily water use, compare water consumption to other households participating in the trials within their suburb and set water use targets.
Mr Hutchings said the new technology is an exciting prospect not only for the potential savings available to customers, but also for the transformation of the water industry into a new and innovative space.
“The digital water meter trials have demonstrated the advancement of new technology in water retailing, which is delivering value for our customers. We are very excited about the future of our digital water meters,” said Mr Hutchings.
A number of customers involved in the trials have seen positive results from the possibility of early leak detection.
Seaford: A cracked galvanised pipe underneath a customer’s house was identified to be leaking 7,276 litres of water per day – this is equivalent to 61 bath tubs of water loss per day. The leak would have added several thousand dollars to the customer’s bill for the relevant quarter had it not been identified through the technology and subsequently fixed.
Belgrave South: A defective hot water service on a customer’s property was identified to be leaking 480 litres of water per day – this is equivalent to four bath tubs of water loss per day. The leak would have added several hundred dollars to the customer’s bill for the relevant quarter had it not been detected and fixed.< PreviousNext >
Cosgrove $6m Pipeline Provides Year-Round Supply
Stock and domestic water will flow year-round to 112 properties in the Cosgrove area, east of Shepparton, thanks to a $6 million pipeline announced by Minister for Water Peter Walsh in April.
Joined by Member for Shepparton Jeanette Powell at the Tungamah Pump Station, Mr Walsh said the Cosgrove Stock and Domestic Pipeline would provide landholders with a reliable water supply and improved water quality.
The Government is providing $5.4 million to the Cosgrove Stock and Domestic Pipeline, including $3.5 million made available for the project when the Water for Rivers program ended.
The 65 kilometre pipeline will service about 11,000 hectares of agricultural land, sourcing water from the Goulburn system through an extension of the existing Tungamah piped water district. It will replace the current Shepparton Stock and Domestic Community Water Supply Scheme channel system, which is more than 120 years old.
The Victorian Government is taking action to see this out-dated and inefficient system finally upgraded. The Water Supply Scheme sources water from the Broken River and was under major water restrictions from 2006 to 2010 during the worst of the drought.
While the community-operated system was a great initiative when established in the 1890s, it is well overdue for an upgrade. Goulburn-Murray Water has begun an early works program, with the project hoped to be complete by late 2014.
Funding of a further $650,000 will be raised through a tariff to Cosgrove customers. Mrs Powell said she and Minister Walsh had met with irrigators in the Cosgrove area a number of times and she was delighted with the announcement. “This is a significant investment to modernise the region’s irrigation infrastructure and support growth in the local farming and wider Shepparton communities,” Mrs Powell said.
Mr Walsh said the project would also benefit irrigators in the Broken system by saving 830 megalitres of water, which would be cancelled out of the Broken irrigation system. “This means improved reliability of supply for irrigators, as well as the potential for more unregulated flows to be passed through the system to benefit the environment in wet years,” Mr Walsh said.< PreviousNext >
WaterCare Hub Gives Helping Hand
Recently, Yarra Valley Water became the first utility provider in Australia to launch a resource for customers and the community sector, aimed at giving customers a helping hand in managing their water bills.
The WaterCare Hub, launched at the Financial Counselling Australia conference, has been developed to support community workers and agencies when working with financially vulnerable customers.
Tony Kelly, Managing Director Yarra Valley Water said the hub is part of our Watercare initiative, designed to support customers and ensure they understand the options available to them so they can better manage their water and sewerage bill.
“The WaterCare hub gives members access to information on assistance that is available to customers to help them manage their water and sewer bills, including links to useful websites, programs and services.
“While most utilities and some businesses now provide advice and payment options for customers, we wanted to take it one step further. It is no secret that our community sector has been stretched with the impact of changes in the economy both at home and abroad. The aim of the hub is to get help to the people that need it as quickly as possible. We have worked extremely closely with the community sector and financial counsellors to produce a resource which can help them provide the latest advice and information to the public.”
“We wanted to create a resource for those frontline people that we know are providing assistance to people in the community facing financial difficulty. The Hub can bridge the gap and get them the information they need to provide the best possible advice as soon as possible. Anyone can experience difficulty managing their finances, regardless of income or lifestyle.”
“Whether it is looking at how often you pay your bill, helping to set up a payment plan or looking at how to reduce your usage our understanding staff can talk you through the range of options available and we can offer tailored assistance to meet your needs.”
“We would hope that all water retailers and other utility companies as well as councils and banks will jump on board to provide a similar level of service creating a one stop shop for information” added Mr Kelly.
Visit www.watercare.com.au for more details.
WaterCare is a Yarra Valley Water initiative, established to provide a range of supporting programs to assist customers in managing their water and sewerage bills.
The objectives of the program are to identify customers that may be at risk of financial vulnerability early in the debt cycle and direct them to support programs so that preventative action can reduce the chance of them moving into financial hardship.
While hardship is a commonly understood term across the water industry and other utilities there is not an established vocabulary around vulnerability.
In turn there are established policies, frameworks and support services for those experiencing hardship but a general lack of suitable mechanisms for identifying and supporting vulnerable customers to help them avoid falling into serious difficulty. We understand that rising utility bills can have a big impact on households and at different times of life needs change, which can sometimes result in financial difficulty< PreviousNext >
Aquifer Storage Takes Next Crucial Step
A pilot project to use aquifers to store recycled water hundreds of metres underground in the Werribee area is set to take its next crucial step in the coming months.
Following successful results from the trial stage of the Aquifer Storage and Recovery (ASR) Project, the pilot will be expanded with five ‘production bores’ be drilled and test water pumped into aquifer in the coming months.
City West Water Managing Director, Anne Barker, said the $11.4 million ASR project offers a viable water storage solution for recycled water in Melbourne’s outer west.
“The ASR project represents a fantastic opportunity to maximise the use of recycled water in Melbourne’s west, and it is great to see the project take this vital step forward,” Ms Barker said.
“Recycled water already plays a large part in irrigating sporting and recreation facilities in the Werribee area and the ASR will see it play an even greater role, as well as ensuring that the right water is used for the right purpose.”
Aquifers are underground layers of rock or sand which can hold water in the spaces between sand particles, pores or fractures in the rock. Most aquifers already hold water in these spaces, and if the conditions are suitable, aquifers can be used to store additional water in large volumes.
To store water in an aquifer, bores are drilled to the aquifer and the bore sides sealed so that the only openings are at the surface of the aquifer.
In conjunction with Melbourne Water and Southern Rural Water, City West Water has undertaken extensive analysis and modelling to ensure that water being injected into the aquifer is monitored carefully to ensure bore water quality is not adversely affected.
The new production bores will enable City West Water to track water composition over the long term, ensuring that potential impacts on bore water are identified as quickly as possible.
The ASR project provides a cost effective water storage solution with minimal environmental impact – water can be stored below ground without having to build costly storage ponds and can store excess water during periods of lower demand.
“With the ASR, surplus water from the new recycled water plant we’re building at the Werribee Treatment Plant can be stored during the winter months in the aquifer for use during peak demand in summer and to meet future demands.”
“The West Werribee Dual Supply (Aquifer Storage and Recovery) Project was granted funding of $11.4 million under the Australian Government’s National Urban Water and Desalination Plan.
As part of the next phase of the project, City West Water’s ASR application has been advertised in the local newspapers by groundwater manager Southern Rural Water which has responsibility for administering the licences required.< PreviousNext >
Optimising Environmental Improvement Plan (EIP) Approvals
Last year, the VicWater Biosolids Task Group (BTG) put out a call to all Victorian water corporations asking them to describe their top five biosolids concerns. Industry feedback was then incorporated into the BTG’s strategic plan, which in turn focuses the efforts of the task group on seven strategic actions.
The third of these strategic actions is titled “Optimising EIP Approvals”. This reflects a relatively common concern amongst biosolids professionals over the process of obtaining regulatory approval for biosolids EIPs. In particular, comments relate to the protracted timeframes involved with obtaining approval and the lack of clarity in relation to the necessary EIP content.
While the BTG will also work toward longer term solutions, in the short term we have engaged with the EPA in attempt to better understand their current expectations and to identify how water business can navigate the EIP approval process more quickly and successfully.
We hope to pass on the key learnings to our biosolids peers via this article along with some practical tips that we hope will assist you to optimise your next EIP approval.
Not surprisingly, the timing and complexity of the approval process is directly influenced by the quality of your EIP.
A poorly written EIP with lots of gaps is likely to find its way back to you quickly, however you shouldn’t hold your breath for approval. And while an EIP with all the right detail is more likely to be approved, if it’s overly complex and wordy, the timeframe will suffer as a result.
Therefore, when developing an EIP, put yourself in the place of the assessor and set your sights on a document that follows the right EPA guidance, is concise, contains only the necessary detail, and is easy to read.
Here are a few tips to help develop a good EIP:
- The EPA will assess your EIP against the Guidelines for Environmental Management: Biosolids Land Application, Publication 943. Be sure to base your EIP on this publication. Part 8 of the guidelines provides specific guidance in relation to EIP requirements.
- The EPA is very supportive of water businesses developing a Regional EIP (REIP). An REIP will contain generic details related to a water businesses management of biosolids and can be approved just once. Details of individual reuse sites can then be submitted separately for approval on a case by case basis before being appended to the REIP. This minimises duplication and can be more efficient for both water businesses and the EPA.
- Speak to the EPA’s Development Assessments Unit when you begin developing your EIP. This simple conversation will help the EPA to plan their workload and any words of advice may also assist you in return.
- Try to stay within the bounds of the guidelines. Treatment methods or alternative approaches not included in guidelines are likely to demand more time (and money) to prove and approve.
- Avoid unnecessary information and highlight important details. The EPA will be particularly interested to know how the biosolids will be treated, how you have determined the quality, how they are to be reused and how risks will be managed. Help them find this information easily.
- Consider an independent internal review prior to submitting your draft to the EPA. A fresh set of eyes will provide good perspective on how clearly your EIP addresses key requirements. A helpful checklist is provided in Appendix E of the guidelines to ensure nothing is missed.
Draft for Comment
Having previously advised the EPA that you are developing an EIP, offer them an opportunity to provide comment on it prior to its submission for approval. This will increase your chances of a quick turn around once your EIP is submitted for approval.
Here are a few more tips:
- Be sure to address your draft EIP directly to the EPA’s Development Assessments Unit.
- Make sure the EPA understands that you are seeking feedback on the draft that will help it pass through the EPA’s approval process quickly and successfully.
- Respond as quickly as possible to any questions or requests that may come from the EPA. It’s important to capitalise on the opportunity while you have the EPA’s attention.
- Once feedback is received, provide the EPA with an estimated timeframe for submitting your final EIP. This will help the EPA to manage workloads and accommodate your submission.
Hopefully at this point all of your hard work, attention to detail and consultation with the EPA will help your EIP pass smoothly through the EPA’s internal processes.
Here are a few final tips in any case.
- Be sure to address all comments received earlier from the EPA and make all necessary changes before submitting your EIP for approval.
- Once again, address your submission to the EPA’s Development Assessments Unit but this time, make it clear that you are seeking final approval and be clear about your intended timeframe for biosolids application.
- If you do receive further questions or comments from the EPA, respond as quickly as possible to avoid holding up the assessment process.
While acknowledging that many of the factors that influence approval timeframes are out of our direct control, we also know that we are able to improve our chances of receiving timely approval by carefully controlling what we submit.
Refer to the guide below next time you develop a biosolids EIP to improve its passage through the EPA.
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