Tomorrow morning, three members of the SOSJ team are to meet the Environment Regulator, Dr Tim du Feu with other members of his team. This follows a request made by our committee after recent concerns about pollution and excessive nitrates in St. Aubins Bay.
We reproduce below a list of questions that we have asked and the response from the Regulator, Dr Tim du Feu, which he would like us to share with our members.
We hope that after the proposed agenda which Dr du Feu has suggested there will be time for the questions to be addressed. (We have sent off Item 1 to save time) We will report back.
1: Re the discharge from the UV plant: Do you rely on the manufacturer’s specification for your results or do you test the discharge, if so how often
and what for? Are they in accordance with Water Framework Directive which says the water in St Aubin’s Bay is ‘bad to poor’
2: Are both outflows tested for bacteria and/or nitrates; the Bellozanne one, and the shorter one to the west (what watercourse does that serve?) If tested how frequently, on irregular basis? At the same times of day? Are additional measurements to be taken at other times (e.g. after heavy rainstorms?)
3: If so, what were the levels of both bacteria and nitrates from each outflow?
4: What is the ‘normal level for nitrates in the bay? Eg, what would you regard as an ‘acceptable baseline’ from the outflows? How have you set the baseline? Are they in accordance with the Water Framework Directive?
5: Have heavy metals been tested for from the Bellozanne outflow from the UV plant? (We understood that TTS transport leachate there from liquor pumped from the ash pits at La Collette and flush it out after letting the sludge settle and treatment with caustic soda.) Therefore we would presume that there would be testing for residual heavy metals?
6: We think that other sources may enter the flow and also that (if for instance) the flow heated up on the way down then could the bacteria load be altered in transit?
7: Do you test for nitrates when you test bathing water quality? If not, where and when do you test for nitrate levels?
8: When you test the UV outflow after periods of heavy rain and the bacteria level is high, do you issue a warning to the public? If ‘yes’, should the public be advised in advance?
9: We have video footage of a discharge under water from the Bellozanne outflow. A lot more activity that would happen just the steam running out- the sea was really disturbed – are there timed discharges when the tide is high? Do the measurements coincide with each discharge?
10: If ‘yes’, should the public be advised in advance of discharges (if indeed that was the cause of the disturbance?
11: If the outflow was longer and went into deep water. would this solve or partially solve the sea lettuce problem? If not, what would your preferred solution be to the nitrate overload?
12: The aquaculture farmers report that even when the bathing water tests are clear up the beach, often further down the beach to the east the tests are category B or C. Category B: Does this indicate that the bacteria level is worse in deeper water? If not what is the reason for this happening?
13: When the new sewage treatment plant is complete and the cavern work properly, do you anticipate a zero level of bacteria to be released 100% of the time from the Bellozanne plant?
14: As above, will there be a reduction on nitrates released into the sea or will this be the same?
15: You mentioned that you carried out a baseline study of water quality. Is this island wide or restricted to creation areas and would you define the tests that form the baseline parameters.
16: What tests do you do to check the sediment in the bay at Havre des Pas and La Collette with regards to heavy metals that may be leaching from the bottom of the older pits and built up in the sediment?
THE JEC Chimney:
We have communicated about this before and would like an update. In 2011 at the first Ramsar Management Authority meeting that was chaired by The Minister for Planning and the Environment, the Minister made a promise to us that the JEC flues would be regulated by the end of 2011. Can you tell us why that hasn’t happened and what the problem is?
The Ramsar Management Authority last met late last summer. Meetings were supposed to be held quarterly and the Minister promise that his Chairmanship would last 6 months and there would be elections as per the Ramsar ethos. We have not received minutes of the meeting nor had any meeting since.
We are concerned that the RMA has been allowed to deteriorate, and that the ethos that the Ramsar Bureau advise member countries to adopt has not been adhered to. We would appreciate your views on this. The Bureau have expressed their disquiet on more than one occasion.
The Regulators’ reply:
Thank you for the useful questions. Many of these are linked through our larger goals and programmes of work.
In order for us to move ahead quickly, I would suggest that we group these together and talk through them when we meet. The questions you ask can be covered under their respective headings and we can re-cap to ensure all areas have been covered. I would then be happy to write a short paragraph on each topic which may be helpful for you to forward to your members.
Can I suggest the following structure for our meeting:
1. Aims and objectives of SOS
2. Vision, mission and values of Environmental Protection
3. Current resources in Environmental Protection and use of consultancy input
4. Current regulation of the STW
5. The proposed replacement sewage treatment works and the phased approach
6. St Aubin’s Bay, the Water Framework Directive (WFD) approach and current sampling programme
7. The £200k funding, how this was targeted for differing work areas
8. Water quality testing for the aquaculture industry and bathing waters
9. Development of a WFD water catchment management plan for the island
10. Discussion on how best to work together
Re Ramsar Group and the JEC, I have forwarded your questions to Greg and to Peter Brown, Health Protection respectively, who will answer direct.