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THE WATER POLLUTION RULES, 2019 Presentation by the Environmental Management Authority (EMA) 1 Intent of the Revision Overview Overview of Revision Water Pollution Rules 2019 Discharge Fee Calculation Next Steps 2 2 Why were the Rules and


  1. THE WATER POLLUTION RULES, 2019 Presentation by the Environmental Management Authority (EMA) 1

  2. Intent of the Revision Overview Overview of Revision Water Pollution Rules 2019 Discharge Fee Calculation Next Steps 2 2

  3. Why were the Rules and Fees revised? • To support the revision of the Water Pollution (Fees) Regulations, in keeping with the tenets of the Polluter Pays Principle (PPP). • Incorporate lessons learnt from 12 years of implementation • To provide an integrated approach to watershed management which aligns with National Policies and International Convention obligations. 3

  4. WPR 2019 – Integrated Approach ● Inclusion of ambient water quality standards ● Implementation ● Pollutant loading ● Align the WPR of Watershed (concentration with the Polluter Improvement Plan limits with Pays Principle discharge volume) Policy & International Convention 4 obligations

  5. Overview of Water Pollution Rules Revision PROPOSED CURRENT PREVIOUS 2 application 1 application process Tiered based on Fixed application fee discharge volume Fixed discharge fee Calculated annually Point and Non Point sources (Watershed Point source Approach) 5

  6. Amendments to Schedules I & II Other Solid waste removed (28 Parameters) Revisions Ambient Water Quality Standards included as Schedule III -applicable to surface water quality with relationship to coastal near shore environment -does not apply to ground water nor the offshore environment -will guide the Watershed Improvement Plan PROPOSED Post compliance monitoring compliance included after meeting the required pollutant levels of Schedule II Effluent monitoring requirements in issued permit updated (e.g. specify daily average, flow monitoring device) Encourage wastewater reuse Beneficial Use discount in annual discharge fee calculation 6

  7. Quality Assurance Project Plan, Pollution Control Plan, Best Management Practices UNCHANGED Plan, etc. REQUIREMENTS PROPOSED Monitor/report ONLY on parameters specific to the facility discharge Monthly/Annual Reporting 7

  8. All Source Registration applications WPR and Certificates under those rules are PROPOSED 2001 was no longer valid revoked All permits issued under those rules are no longer valid. The EMA will advise facilities on the way forward 8

  9. PREVIOUS WPR 2001 CURRENT WPR 2019 ALL FACILITIES with point-source discharge submit Application for Source Permit Application to the EMA Registration EMA reviews application and effluent data SRC Issued Renew every 3 years Data within Data outside Data outside Schedule I Schedules I & II Schedules I & II and within Schedule II Application for Permit Permit issued Facility required to meet Schedule II ≤ 5 years Permit issued Maybe required to implement for ≤ 5 years Watershed Improvement Plan (Schedule III – 9 Ambient Water Quality Standards)

  10. Permit Application – WPR 2019 45 working days from commencement of the Rules All facilities with point-source discharge submit application or otherwise guided by the EMA One hard copy and a soft copy (in PDF format) EMA reviews application 20 working days Exempt Acknowledges application/ Requests further information • Operational releases from motor where necessary vehicles • Releases from households except EMA issues notice of 30 working days where such households contain determination industrial or commercial facilities • Releases authorised by a competent Permit is Required governmental entity into sewerage EMA Develops & Issues facilities owned or operated by such competent governmental entity EMA Monitors Compliance 10 10

  11. FEES PREVIOUS CURRENT ● Fixed application fee ● Tiered application ($2500, $5000) fee based on discharge volume ● Annual fee ● Fixed annual fee calculated based on ($10000, $15000) pollutant load, Monitoring and Inspection Fee & Beneficial Use 11 11

  12. Application Fees Effluent Initial Renewal Facility Discharge Application Application Type Volume Fee (TT$) Fee (TT$) (m 3 /day) micro-/mini <10 14,000 5,800 small 10-100 15,000 5,900 medium 100-500 18,000 6,400 large >500 20,000 6,600 12 12

  13. Discharge Fee Calculation Jurisdictional review of seven (7) existing fee infrastructures conducted. Analysis recommended assessment of Wisconsin, Jamaican and Malaysian models to determine best fit for T&T. Guidance sought from Economics Department of UWI. Recommendation - adaptation of discharge fee calculation in Jamaican Natural Resources Conservation (wastewater & sludge) Regulations, 2013. 13

  14. Discharge Fee Calculation  M.I. = Monitoring & Inspection  B= Net Pollution Load  U = Discount for Beneficial use of Effluent DF = M.I. + B – U 14

  15. Monitoring & Inspection Fee (M.I.) DF = M.I. + B – U Effluent Discharge M.I. Fee Facility Volume (m 3 /day) per annum Type per facility (TT$) micro-/mini <10 5,000 small 10-100 15,000 medium 100-500 50,000 large >500 100,000 15 15

  16. Net Pollution Load (B) ($) DF = M.I. + B – U For each pollutant, the annual load ( NL p ) is multiplied by the per- B p = ∑ NL p R p ….. tonne discharge fee rate ( R p ) and summed to give the base discharge fee, B p 16 16

  17. Net Pollution Load cont’d - Annual Pollutant Load (NL p ) DF = M.I. + B – U Convert m 3 /day to L/day 99m 3 /day x 1000 = 99000 L/day Calculate Pollutant Load (mg/L/day) 99000 L/day x 305mg/L (average daily flow x average =30195000 mg/day concentration) Convert mg/day to mg/year 30195000 mg/day x 365 = 11021175000mg/year Pollutant Load in tonnes/year 11021175000mg per year ÷ 10 9 = 11 tonnes/year Calculation for one parameter From the monitoring reports:  TSS average concentration for the year = 305mg/L  Average discharge volume at that point = 99m 3 /day 17 17

  18. Per-Tonne Discharge Fee Rate (R p ) ($/Tonne) Fee Parameters $TT/Tonne Five Day Biological Oxygen Demand (BOD 5 at 150 20 o C) Dissolved Hexavalent Chromium (Cr 6+ ) 3500 Total Suspended Solids (TSS) 75 Total Petroleum Hydrocarbons (TPH) 250 Total Cadmium (Cd) 150 Total Mercury (Hg) 3500 Total Cyanide (CN - ) 10,000 Faecal Coliform ( fee rate is in $/1,000,000 litres ) 400 – 5000 Organisms per 100 ml 250 5000 – 20000 Organisms per 100 ml 500 More than 20000 Organisms per 100 ml 750 18 18

  19. Exemptions- Toxicity, Radioactivity, Dissolved Oxygen • The EMA did not include Toxicity, Radioactivity and Dissolved Oxygen in the discharge fee calculation. • All three parameters cannot be calculated by pollutant load and are not included in the Rate Fee. 19 19

  20. Net Pollution Load (B) ($) B = ∑𝑶𝑴 𝒒 R p DF = M.I. + B – U Parameter Annual Discharge Fee Rate (R) Net Pollution Pollutant Load (NL) $TT/tonne* Load (Faecal Coliform in (B) $/1,000,000 litres TSS 11 tonne/year 75 825 TO&G 2 tonne/year 250 500 BOD 5 17 tonne/year 150 2550 NH 3 -N 0.14 tonne/year 250 35 36.14 litres Faecal 500 9,035 Coliform TOTAL NET POLLUTION LOAD FOR THIS DISCHARGE POINT TT$12,945 20 20

  21. Beneficial use of the Discharge (U) DF = M.I. + B – U DISCOUNTING THE BENEFICIAL USE OF THE DISCHARGE • T he effluent characteristics meet an established criteria for irrigation or some other approved use. • O nly applied in instances where it has been demonstrated and verified that use of the effluent is having the desired effect. *for this example, application of ‘U’ was not applicable 21

  22. Discharge Fee Calculation - Example 5 Discharging Medium MI + B - U = 1 discharge parameters into size 50000+12945 point of concern municipal - 0 facility in 2017 drain 𝑬𝒋𝒕𝒅𝒊𝒃𝒔𝒉𝒇 𝑮𝒇𝒇 = 𝑵. 𝑱 + 𝑪 − 𝑽 = 50000 + 12,945 – 0 = TT$62,945 22 22

  23. WHAT ABOUT…… • Relationship with the Certificate of Environmental Clearance Rules? • Storm water discharge? • Input water could be already polluted from the source? • Normally Unmanned facilities 23 23

  24. NEXT STEPS • The EMA will inform each facility when to submit a permit application • Subsequent to the issuance of a permit, the EMA will advise of the calculated annual discharge fee 24 24

  25. Any Questions? For further clarification please contact the EMA at 226-4362 For further information please visit our website at www.ema.co.tt 25 25 25

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