Steve Taylor, Head of Operations, The Water Services Authority – Taumata Arowai, responds to the article in the September magazine, ‘Regulator here to enforce not advise’ about a boil water advisory for Marlborough District Council’s Havelock supply.
Drinking water requires careful planning, active management and robust infrastructure to be (and remain) safe. Since our establishment in 2021, we have focused on improving drinking water safety.
In late 2023, the Authority wrote to council drinking water suppliers (including Marlborough District Council) whose supplies lacked protozoa, bacterial or residual disinfection treatment barriers, of our expectation that they create a plan and install these safety barriers by the end of 2025.
For some councils, this meant upgrading multiple supplies. Good progress has been made, and we expect most council supplies to have these barriers in place by the end of the year.
To be very clear, these barriers are not a new requirement – they have been required for decades.
The Havelock supply did not have a protozoa barrier. Protozoa barriers are critically important and stop single-cell parasites like cryptosporidium and giardia that can cause serious gastrointestinal problems and pose a threat to public health. In addition, the bacterial barrier (chlorination) was ineffective. This meant neither required treatment barrier was present nor working effectively and the community was being put at unnecessary risk.
Where barriers remain absent, we expect suppliers to take extra measures such as a boil water advisory to ensure consumers are safe. It is important that consumers know if their drinking water might make them sick, so they can take steps to protect their health. A boil water advisory is the only way to effectively manage the risk until an appropriate treatment barrier is put in place.
The council provided us with a funded plan in July 2024 for installing protozoa treatment at the Havelock supply. At that time, we were told the expected completion date for the installation of infrastructure was 2025/26.
Over the next few months, this timeframe continued to extend because of difficulties with land ownership and access, as well as design challenges. The ongoing extending timeframe gave us further concern that the community was continuing to drink water from a supply that had inadequate treatment.
The article states that the Authority “arbitrarily slapped a boil water notice on Havelock on July 9 with just two days’ notice and then stood back”. To suggest the council knew nothing about this until two days before the notice is incorrect.
The Authority expects councils to actively manage risks to drinking water and avoid making people sick. Where this isn’t happening, we escalate our response if there is a public health risk.
In this case, our regulatory approach was one of engagement and providing assistance to comply before we considered using our enforcement tools.
From the setting of expectations in 2023, right through to our increased communications with the council from May 2025, we consistently reminded the council of the obligation to install appropriate barriers against contamination in a timely manner and manage risks in the meantime.
We were not satisfied the council’s risk mitigation plan for Havelock went far enough to address the risks to the community before treatment for protozoa was put in place.
Authority staff met with council officers on 11 July to discuss risk mitigation. A boil water advisory was recommended as an appropriate risk mitigation measure, given the risk profile of the supply and the insufficiency of controls to protect public health.
It’s good news that the council has moved quickly to install a temporary ultraviolet (UV) treatment plant. This will not only result in safer drinking water for locals but will also allow the boil water advisory to be lifted.
Regarding comments that the Authority did not provide the council with alternative options, while we always seek to be helpful, councils are best placed to find treatment solutions suitable for their specific supply conditions.
A number of councils have needed to install treatment barriers and have put temporary solutions in place. Queenstown did this in 2023 to lift its boil water advisory after the cryptosporidium outbreak there. Options are widely known and readily available.
For Havelock, we provided council staff with options to consider regarding point-of-use treatment for businesses. We also provided feedback on the public communications to ensure messaging was clear and consistent.
To say that we are here to “enforce not advise” is incorrect. As a regulator, we do both. We regulate drinking water suppliers to ensure they meet the requirements and standards for delivering safe drinking water.
On 10 July, we published our Compliance, Monitoring and Enforcement Strategy 2025-28 that is a clear action plan for how we will regulate drinking water safety over the next three years and what we expect drinking water suppliers to do in that time.
Moving forward, drinking water suppliers and the public can expect to see us focused on real improvements. We will work to support suppliers as they progress including developing practical guidance and how-to information. We will continue to monitor critical safety issues and incidents on a case-by-case basis.