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Guidance for Source Water Risk Management Planning

This guide covers the importance of protecting drinking water at its source and describes what a drinking water supplier should consider when carrying out risk management planning for source water. It should be read with the Drinking Water Safety Planning guidance.

This guide describes good practice for source water risk management. We recognise that some suppliers, particularly those who operate very small drinking water supplies, won’t have previous experience of source water risk management, so will need time to fully implement this guidance. Taumata Arowai will provide templates to support people who operate very small (serving less than 50 people) and small (serving 50 – 500 people) drinking water supplies to complete plans in a way that is proportionate to the scale, complexity and risks associated with their supply.

A supplier doesn’t have to complete a source water risk management plan if:

  • They have implemented an Acceptable Solution that specifies that a drinking water safety plan isn’t required.
  • They don’t have a source from which they are abstracting water. For example a Water Carrier who takes water from another supply.

If you're a drinking water supplier who wasn’t registered with the Ministry of Health before 15 November 2021, you won’t need to prepare a source water risk management plan until after your supply is registered. You have up to November 2025 to register your supply, and up to November 2028 to prepare and provide a drinking water safety plan or comply with an Acceptable Solution.

Overview

The Water Services Act 2021 (the Act) defines a ‘source’ as the water body from which water is abstracted for use in a drinking water supply. Examples of sources include rivers, streams, lakes, aquifers and rainwater.

As part of drinking water safety planning, drinking water suppliers must prepare and implement a source water risk management plan outlining the hazards and risks associated with the water that they abstract to use as drinking water and how these will be managed. The source water risk management plan becomes part of the supplier’s drinking water safety plan.

Source water risk management carried out under the Act, together with measures set out in the Resource Management Act 1991, the National Policy Statement for Freshwater Management 2020 (NPS-FW) and the National Environment Standards for Sources of human drinking water (NES-DW), provide a framework that ensures:

  • the risks and hazards to source water are identified, assessed, managed and monitored by drinking water suppliers and local authorities, and
  • information on source water, and measures to manage risks and hazards to source water, are published on a regular basis by regional councils.

The importance of protecting source water

There are three types of source water:

  1. surface water (from a lake or river);
  2. ground water (from a bore or spring); and
  3. roof water (rainwater collected from impervious surfaces).

Hazards that affect source water can contaminate the entire drinking water supply and cause illness to those who consume it. Drinking water suppliers need to understand these hazards and the associated risks these hazards pose to the drinking water supply and manage these risks well.

The Water Services Act 2021 recognises that source water may be affected by activities carried out by people other than drinking water suppliers and which are regulated under other statutory regimes. The Act merges with the Resource Management Act 1991, regulations made under it (including regulations creating national environmental standards), and the NPS-FW. In particular, suppliers must have regard to values identified by local authorities under the NPS-FW that relate to the freshwater body that the supplier uses as a source. These values provide information about significant characteristics of the source water and the risks they may present.

Interaction between local authorities and drinking water suppliers is essential for effective management of freshwater. The Act therefore provides that local authorities must contribute to the development and implementation of source water risk management plans by providing information about:

  • Land-use activities, potential sources of contamination, and other water users that could affect the quality or quantity of the source of a drinking water supply;
  • Water quality monitoring of the source of a drinking water supply conducted by a regional council; and
  • Known risks or hazards that could affect the source of a drinking water supply.

Local authorities also have a role to address risks or hazards to the source of a drinking water supply that can’t reasonably be controlled directly by the drinking water supplier. It’s important that actions a local authority has agreed to undertake are recorded as a part of the source water risk management plan. 

Regional councils have the additional role of assessing the effectiveness of interventions to manage risks and hazards to source water in their regions. This must be done at least once every three years and the resulting information must be made available to the public through regional council websites. Regional councils must also publish information annually about the quality and quantity of source water in their regions.

Te Mana o te Wai

A principle of the Act is that a drinking water supplier in carrying out their duties must give effect to Te Mana o te Wai. It recognises the importance of water (wai) and how by protecting the health of water, you also protect the health and wellbeing of people and the wider environment. This whole system approach, embodied in Te Mana o te Wai, from maunga (mountain) to moana (sea) or ki uta ki tai, is unique to Aotearoa New Zealand. Te Mana o te Wai is defined in the National Policy Statement for Freshwater Management 2020.

Source water risk management planning

Effective drinking water safety planning is about identifying all potential hazards and hazardous events that could affect drinking water, assessing the likelihood and consequences of these, and implementing suitable controls to reduce the risk of the hazard/event causing harm.

You need to carry out separate risk management planning for your source water, as well as the risk management planning for your treatment and distribution processes. Both risk assessments are documented and form part of your overall drinking water safety plan.

The Drinking Water Safety Planning guidance outlines several approaches you can use for your source water risk management planning. Choose a risk management approach that is proportionate to the scale (including the number of people your supply serves) and the complexity of your infrastructure.

Plan-Do-Check-Act Cycle process

Here are points to consider about your source water at each stage of the planning process using the Plan-Do-Check-Act Cycle.

PLAN

The steps in this section include:

  • Understanding your drinking water source
  • Identify the hazards
  • Identify how the hazards can create a risk
  • Manage the risks by setting controls
  • Identify how you will respond.

 

Understand your drinking water source

Describe relevant characteristics of the source water used for your drinking water supply

This information helps to identify potential hazards and risks that may affect your drinking water supply.

You can do this by considering:

  • the type of source water (surface, ground or roof source water)
  • what you know about activities in the catchment area for your water source and how they may affect your drinking water supply. (Draw a map or get an aerial picture of the catchment)
  • what activity occurs on your land and what hazards and risks, to the source water, you can directly control
  • the complexity of the infrastructure that protects it (e.g. borehead structure, water intake arrangements, mechanisms for removing debris) and that supports the water to be delivered
  • the population your drinking water supply services and changes that may affect demand on your supply
  • the amount of water that you are extracting from your source
  • what treatment systems you currently have operating.

It’s also useful to take a walk around the area directly surrounding the source water abstraction point and observe the water supply yourself, noting its characteristics, as well as land use activities on neighbouring properties.

Talk to the people in your community who may use the land around your drinking water supply and whether their use impacts on your drinking water supply

It's important to have a complete picture of the land use activities and potential sources of contamination that could affect your source water. Although you can get some of this information from your local authority, talking to the people in your community will help you to establish relationships that will assist you with your source water risk management planning.

Obtain information about the values that relate to your source water under the National Policy Statement for Freshwater Management

You need to find out from your local authority if there are any values identified under the NPS-FW relating to your water source and how these might affect your drinking water supply.

Increase your knowledge of mātauranga Māori and seek to involve mana whenua meaningfully in the management of risks to your drinking water supply

Talk to mana whenua to see how they would like to be involved in your source and drinking water safety planning and how you can work together to manage the risks to your drinking water supply.

Draw on mana whenua knowledge of the water and learn from them to recognise, grow and enable the mātauranga Māori capability across your water supply system.

Understand the mana whenua protocols when a rāhui (temporary prohibition) is placed over source water. This will enable you to ensure that there are measures in place to consider other options in ensuring the provision of safe water to tangata whenua whilst respecting tikanga.

Increase your knowledge of Te Mana o te Wai and consider how you will maintain the wellbeing of your source water

Consider how you will integrate the principles of Te Mana o te Wai into the management of your drinking water source to ensure the health and wellbeing of the water, people and the environment is protected.

Think about the impact your water supply operation has on the environment and how you can change your practices to minimise the impact – for example, minimising unnecessary water take from your source, reviewing how you manage leaks in your supply, and how you can avoid contaminants from pumping equipment or backflow entering the water body.

 

 

Identify the hazards

Identify the hazards associated with your source water(s)

You need to understand the hazards or hazardous events that may impact on the safety or sufficiency of your source water.

Think about the things that could cause your water source to become contaminated.

Connect with other drinking water suppliers who draw water from the same source (for example, the same river or aquifer) to share information and work together to identify the hazards associated with your source water.

Use your own knowledge of what activities are happening around your water source. Consider seasonal variations and temporary events which may occur in the catchments (for example, gatherings or festivals, tree felling, crop spraying) and the potential for foreseeable but unplanned incidents such as chemical spills or landslips.

Seek information from local authorities (territorial authorities and regional councils in your area) on land use activities, potential sources of contamination, other water users and any known risks or hazards that may affect the quality or quantity of your sources of drinking water.

Get information from the regional council regarding the quality of the water source and the available quantity of water to abstract.

Refer to the Drinking Water Quality Assurance Rules to determine what source water monitoring rules you must undertake for your type of source water.

Also carry out testing of your water source to determine if there are any additional contaminants (not covered in the Rules) that may be in your source water and that you will need to monitor to ensure the water is safe.

 

Identify how the hazards can create a risk

Assess how each of the hazards you have identified can create a risk to your water source

For every hazard or hazardous event you have identified, assess the likelihood of it occurring and the severity of its consequences.

Share your findings of known risks and hazards with your local authority

If testing and monitoring of your source water identifies risks and hazards to your drinking water source or related infrastructure that could affect the provision of safe drinking water, you must inform your local authority as soon as you can. This includes any known risks and hazards, as well as those identified as part of your source water risk assessment.

Local authorities must also inform you as soon as they can of any risks or hazards they identify that could affect a source of a drinking water supply or related infrastructure.

This is important to protect the health and wellbeing of your consumers and the wider environment.

Talk to your local authority to address your concerns about the risks and hazards to your drinking water supply that you have no control over

Talk to your local authority about new resource consents that could impact on your drinking water supply, including consents that have been granted but not yet implemented.

You may have identified risks and hazards in your assessment that you have no influence over but that the local authority may be able to resolve. For example:

  • If existing discharges into the catchment exceed resource consent limits, then the local authority could commit to putting additional effort into requiring consent holders to comply with their consent limits.
  • Where a consent is due for renewal, there may be an opportunity for existing consent conditions to be modified or tightened. If the matter is brought to the attention of the local authority, they may be able to take action.

Although the onus is on your local authority to address the risks and hazards to the source water, you should follow up with them on the progress of any agreed work and document this as part of your source water risk assessment. Remember to always ensure that the water extracted from the source for your water supply is treated appropriately for the hazards and risks associated with it.

 

Manage the risks by setting controls

Identify how you will control the risks you have identified

You need to consider what you can do to keep contaminants out of your source water or to manage, control, or eliminate them if their presence can’t be prevented entirely.

What measures (controls) will you put in place to prevent the risk of hazards entering the source water (preventative controls) that may cause contamination and what measures will you take to lessen the affect if a hazard does enter your water source (mitigation controls).

Identify how you will respond

Consider whether your water supply has a sufficient quantity of water to support the drinking water needs of your consumers

How will you supply drinking water to your consumers if:

  • contamination of your source occurs and public health is at risk?
  • if an event occurs restricting the availability of water?
  • a rāhui has been placed on a water body?

In these situations you may need to arrange an alternative source for drinking water.

Identify how you will respond if there is a failure in your controls

You need to have a plan in place for how you will respond if, despite your controls, an incident or emergency occurs that contaminates your source water and impacts on the treatment and distribution components of your water supply.

Think about who will need to advise if there is a failure, who you will call on to assist you and what alternative source of drinking water you will use to provide drinking water to your consumers.

Know who you should communicate with

It's important that you are able to communicate quickly with other people who use the same water source and with neighbouring land users including mana whenua. This will enable you to tell each other if something happens that may affect a drinking water supply.

It will also be helpful to have contact information for Fire and Emergency New Zealand, your regional council and your territorial authority at hand if needed.

You should know what matters to notify Taumata Arowai about and have our contact information available.

 

DO

Implement the measures to control the hazards

Put in place controls for every hazard you have identified

Source water protection is the first barrier against drinking water contamination – but it should not be your only barrier. You need to have multiple barriers (controls) in place across your drinking water supply system to ensure the safety and sufficiency of the drinking water provided to consumers.

CHECK

Monitor your processes and report your results

Identify how you will monitor your source water.

It’s important that you monitor any changes in your source water regularly and over time.

Conduct regular water testing based on the Drinking Water Quality Assurance Rules and what you have found out from your local authority about your water.

Conduct additional monitoring where you have identified additional risks that may affect your source water.

 

ACT

Review the effectiveness of your plan

Demonstrate how you know your controls are working and are effective

You need to conduct a regular review of your source water risk management plan and implement improvements as necessary. A review should consider:

  • have you identified all of the hazards and risks or is there new information about hazards and risks in your source water catchment?
  • are the controls you have in place still appropriate and are they effective? For example is your water treatment working as intended?
  • will your monitoring of water quality, and of your controls, enable you to remedy issues in a timely way? For example, is your continuous monitoring equipment, if used, calibrated and reading correctly?