PUBLIC CONSULTATION: SEWERAGE WORKS APPROVAL TRANSFORMATION (SWAT) PHASE II

Transcription

1 PUBLIC CONSULTATION: SEWERAGE WORKS APPROVAL TRANSFORMATION (SWAT) PHASE II

2 INTENT THE NEED FOR PROPER SEWERAGE MANAGEMENT

3 EVOLUTION OF SANITATION IN MALAYSIA - INDIVIDUAL vs COMMUNITY Prior to 1950-s TECHNOLOGY BENEFIT TO COMMUNITY/ ENVIRONMENT DIRECT BENEFIT TO USER Pour Flush Septic Tank Imhoff Tank OP/AL Activated Sludge/ Biological Filters Fully Mechanised Plant Early Days in Malaya 1950-s 1960-s 1970-s 1980-s 1990-s 2000 YEAR Primitive / Primary Treatment Partial / Full Secondary Treatment Future Tertiary Treatment (Address Public Health) (Address River Pollution) (Address Environment)

4 CURRENT FINANCIAL INVESTMENT STRUCTURE SEWERAGE CAPITAL INVESTMENT GOVERNMENT FUNDED CONCESSIONAIRE FUNDED DEVELOPER FUNDED 5 years National Plans Sewerage Capital Contribution Soft Loan & Capital Markets Built into Tariff Structure Part of Land & Property Development Major Contributor of Sewerage Capex PUBLIC PLANTS O & M INVESTMENT GOVERNMENT FUNDED SERVICE LICENCEE FUNDED Soft loan/ subsidy to IWK Tariff Collection

5 STAKEHOLDERS ROLES Aspects Responsibility Activity Quality of sewerage assets construction Consultants, contractors and developers Registration of qualified person and issuance of permits Operations and maintenance of sewerage assets Services licensees Introduction and measurement based on KPIs Products and systems used in sewerage systems Manufacturers, suppliers and person whom installs the sewerage products/systems. Registration of suppliers

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7 LEGAL ENABLERS SECTION 45 Plans and specifications for the construction of sewerage systems and septic tanks require the approval of the Commission SECTION 129 Responsibility of manufacturers, suppliers and any person whom installs, suppliers and uses the sewerage products, systems and material SECTION 180(a)(i) Minimum standards and specifications which shall be used in the design, construction, installation, protection, operation and maintenance of any water supply system or sewerage system

8 LEGAL ENABLERS SECTION 49 SECTION 180 (iii) no part of the sewerage system can be worked, managed or operated except by persons possessing qualifications or necessary certificates. may make rules on minimum qualifications to be possessed by persons before they may be allowed to construct, install, test, commission, operate, maintain or manage any sewerage system SECTION 180(a)(vii) may make rules on standardization of equipment, materials or devices used in sewerage system for the purposes or providing sewerage services

9 SUBSIDIARY LAW PDC RULES Enforced since 1 July 2013 Impose responsibility, accountability and liability on the significant / relevant parties Ensure planning, design, installation and construction works are carried out by the appropriate / relevant parties Ensure quality works being carried out to minimize impact on public health, water resources and the environment Ensure enforcement action can be taken on non compliance with the Act and subsidiary legislations

10 PDC GUIDELINE Procedural guideline developed by SPAN in 2013 Sewerage Works Procedure (Volume II) Provide guidance to better understand conditions imposed in the Rules. Provide details on matters stipulated in the Rules such forms, supporting documents, processing time, payment procedure, bank guarantee amount and other relevance. Ease of amendment (flexible)

11 REGISTERED CERTIFYING AGENCIES Section 45 Relevant plans and specifications must be approved by the Commission before the works are commenced Registered Certifying Agency (CA) Sewerage APPOINTMENT : Since 1 st January 2008 STATE :All states except Kelantan, Sabah & Sarawak APPOINTMENT : Since 1 st June 2009 STATE : Kelantan Section 174 Registration of certifying agencies for the purpose of approving plans and specification on behalf of Commission

12 PLAN AND SPECIFICATION APPROVAL PROCESS FOR SEWERAGE SYSTEM STAGE 1 : PRE - CONSTRUCTION 14 days STAGE 2 : DURING CONSTRCUTION 1 day STAGE 3 : POST CONSTRCUTION 14 days Sewerage Planning Approval (PDC 1) Sewerage Design Approval (PDC 2) 21 days Notice to Start Work (PDC 6) Intermediate Inspection (PDC 7) 14 days Final Inspection (PDC 8) Handover to Service Licensee

13 REALITY OF APPROVAL MECHANISM M&E Specification Submission Comments of Site Inspections Planning Approval Design Approval C&S Specification Submission Site Inspections Handing over of System Planning Application Design Application Lodgment of Commencement of Works Submission of Intermediate Inspection Certificate of Compliance by QP Planning Design Commencement Intermdiate Inspection Final Inspection Handing Over (Public) Notice to pay SCC Submission of Final Inspections Submission of Documents Site Inspections Verification by CA Verification by SPAN Issuance of Receipts Issuance of LOC/ comments

14 THE S.W.A.T. INITIATIVE The Vision: sewerage services that are sustainable, reliable and affordable One of the ways: through sewerage works approval. ASPIRATION Sewerage works approval procedures which are transparent, uniform, practical and enforceable. YOU SPOKE Complaints by industry players on sewerage works approval procedures are increasing (largely due to bureaucracy) WE LISTENED To regulate efficiently and effectively does not require multi layer of procedures

15 2 February 2016 Punita Nook Naidu Director Technical Standard and Compliance Division Sewerage Regulatory Department Suruhanjaya Perkhidmatan Air Negara

16 SWAT - MILESTONE 4/12/12 SWAT Concept Paper approved by Commission 15/01/13 - Quick Scan on identifying problems & solutions 04/02/13 - SWAT Minilab I (new procedural mechanism & strategic plan) 22/04/13 - SWAT Minilab II (stakeholders engagement) 14/05/13 - SWAT Minilab III (document preparation) 18/06/13 - SWAT Phase I Public Consultation launched by SPAN CEO YBhg. Dato Teo Yen Hua 8/07/13 - Briefing on SWAT during the Enhancing Regulatory Quality Seminar officiated by KSN 13/12/13 - Public Consultation report analysis presented to SPAN Top Management 01/04/14 - SWAT Phase I (Low Risk) implemented on a trial basis 26/08/14 - Engagement with stakeholders (Developers) 22/09/14 - Engagement with REHDA Your life does not get better by chance, it gets better by CHANGE - Jim Rohn 15/06/15 - SWAT Phase II Workshop (new procedural mechanism for medium & high risk) 14/09/15 - Minilab I (document preparation) 02/02/16 - Public Consultation launching by SPAN CEO YBhg. Dato Mohd Ridhuan bin Ismail

17 TEAM FINDINGS #1 Findings from mini lab further indicates current practices are: Unfair to industry players whom perform responsibly and ethically; Not preventive for unscrupulous industry players; Based on input regulatory which cannot produce the desired outcome and quality (very procedural); and Not facilitating enforcement initiatives.

18 TEAM FINDINGS #2 SUMMARY OF CURRENT PROCEDURES Total numbers of procedures, documentations and numbers of processing days MULTIPLE PROCEDURES, NUMEROUS DOCUMENTATION & TIME CONSUMING!! Approval Process Required Below : Procedures (nos.) 25 Documentations (nos.) Processing Time (days)

19 TEAM FINDINGS #3 SAME PROCEDURE FOR ALL CREATES INEFFICIENCY PDC 1 PDC 2 PDC 6 PDC 7 PDC 8 Planning Design Notify to Start Work Inspection Work Completion PUBLIC PRIVATE SEWERAGE INFRASTRUCTURE LIST OF WORKS Connection Sewer Pumping stations Sewage Treatment Plant Small Sewage Treatment System Sludge Treatment Facility Inspection Chambers, Individual/ Common Piping, Connection Sewer Pumping stations Sewage Treatment Plant Small Sewage Treatment System Sludge Treatment Facility Pre-treatment Septic tanks Construction Alteration Disconnection Close up Current approval mechanism has the same procedure for ALL types of sewerage infrastructure and works irrespective of size or criticality!

20 MINI LAB OUTCOME #1 SEWERAGE INFRASTRUCTURE Collection Septic Tanks Conveyance Sewage Treatment Works Inspection Chambers Prefabricated Individual/ Common Piping Sewage Treatment Plant Manhole Conventional Connection Small Sewage Treatment System Sewer Pre-Treatment Pumping Station Sludge Treatment Facility

21 MINI LAB OUTCOME #2 IDENTIFICATION OF SEWERAGE WORKS 1. CONSTRUCTION - Construction of new sewerage infrastructure - Includes sewage treatment works, sewerage system, septic tanks, etc 2. DISCONNECTION - To stop or terminate the flow 3. CLOSE UP - Decommissioning of system - Demolishing of the structure and making it safe 4. MODIFY Refurbishment, rectification and sewer rehabilitation including : - Replacement of equipment, component or structure for same or similar function and specification to achieve its original capacity and treatment compliance; - Change of material used for sewer system; Works not directly related to the process of the system such as fencing, road, resurfacing etc; Upgrading works including : 5. ALTERATION - Increasing treatment and capacity of system and/or; - Improving effluent compliance - Increasing sewer conveyance capacity Rerouting sewage flow (sewer diversion) Change of functions or purpose of the system

22 MINI LAB OUTCOME #3 IDENTIFICATION OF SYSTEM OWNERSHIP Land not reserved for sewerage use and/or privately owned Single ownership serving a single development PRIVATE SYSTEM PUBLIC SYSTEM System located in public utility corridor (i.e sewer) System serving more than one (1) premise and reserved for sewerage use and/or surrendered to Federal Land Commission (FLC) Any system declared or determined by the Commission as public sewerage system

23 MINI LAB OUTCOME #4 RISK MATRIX ASSOCIATED WITH WORKS & PROCEDURES PUBLIC SEWERAGE INFRASTRUCTURE PRIVATE LIST OF WORKS Connection Sewer Pumping stations Sewage Treatment Plant Small Sewage Treatment System Sludge treatment Inspection chambers, Individual/ common piping, Connection Sewer Pumping station Sewage Treatment Plant Small Sewage Treatment System Sludge treatment Pre-treatment Septic tanks Construction Alteration Disconnection N/A N/A 2 1 Close up Note : Risk Scoring (at scale of 1 to 5 ) Least risk Slight risk : Very low impact, confined and localized harm/threat : Low impact, limited spread of harm/threat Moderate risk : Reasonably impactful, harm/threat extended beyond localize limit High risk : High impact, wide spread harm/threat Very high risk : Very high impact, wide spread harm/threat and difficult to manage

24 RISK CATEGORIZATION SCORING 1 Least Risk RISK CATEGORY LOW PROPOSED IMPLEMENTATION PHASE 1 2 Slight Risk Phase 2 METHODOLOGY emphasize self regulation concept fewer procedures, faster processing time and cheaper 3 Moderate Risk MEDIUM Phase 3 4 High Risk 5 Very High HIGH Phase 4 Risk Phase 5 greater regulator s involvement in checking/ inspection processes stricter evaluation prior to issuance clearance

25 SCOPE & GUIDELINE LOW RISK (PHASE I) Procedural guideline developed by SPAN in 2013 Sewerage Works Procedure (Volume II) Low Risk

26 IMPLEMENTATION LOW RISK (PHASE I) CURRENT APPROVAL PROCEDURES NEW APPROVAL PROCEDURES SWAT 14 days 21 days Planning PDC 1 Design PDC 2 Sewerage Works Application SWA 14 days 1 day 14 days 14 days Notice Start Works PDC 6 Intermediate Inspection PDC 7 Final Inspection PDC 8 Sewerage Works Completion SWC 7 days

27 OUTCOME OF TRANSFORMED PROCEDURE PARAMETERS PDC PROCESS SWAT PROCESS REDUCTION / SAVING % Nos of Procedures % Certifying Agency Processing Time No of Documents in Certifying Agency No of Documents by Applicants Certifying Agency Operating Cost Consultant s Operating Cost 94 days 21 days 78% 9 no 3 no 66% 32 no 13 no 59% RM RM 1, RM % RM 1, %

28 BENEFITS IN SUMMARY: SWAT PHASE 1 For a total of 25,695 low risk category applications annually, it is estimated involving 10,448 projects.

29 AVERAGE RESULTS SWAT PHASE I IMPLEMENTATION Average: September 2015 November Certifying Agency Maajari (Kelantan) - 100% & a few states under IWK (CA) - > 80% SWAT Phase 2 should be implemented PDC (%) SWAT (%) PDC (%) SWAT (%) PDC (%) SWAT (%) Source: IWK (2015) IST SC SSTS

30 SEWERAGE WORKS APPROVAL PART 2 HOW S.W.A.T. PHASE II

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32 SWAT - MILESTONE 4/12/12 SWAT Concept Paper approved by Commission 15/01/13 - Quick Scan on identifying problems & solutions 04/02/13 - SWAT Minilab I (new procedural mechanism & strategic plan) 22/04/13 - SWAT Minilab II (stakeholders engagement) 14/05/13 - SWAT Minilab III (document preparation) 18/06/13 - SWAT Phase I Public Consultation launched by SPAN CEO YBhg. Dato Teo Yen Hua 8/07/13 - Briefing on SWAT during the Enhancing Regulatory Quality Seminar officiated by KSN 13/12/13 - Public Consultation report analysis presented to SPAN Top Management 01/04/14 - SWAT Phase I (Low Risk) implemented on a trial basis 26/08/14 - Engagement with stakeholders (Developers) 22/09/14 - Engagement with REHDA Your life does not get better by chance, it gets better by CHANGE - Jim Rohn 15/06/15 - SWAT Phase II Workshop (new procedural mechanism for medium & high risk) 14/09/15 - Minilab I (document preparation) 02/02/16 - Public Consultation launching by SPAN CEO YBhg. Dato Mohd Ridhuan bin Ismail

33 RISK CATEGORIZATION SCORING RISK CATEGORY PROPOSED IMPLEMENTATION STATUS 1 Least Risk LOW PHASE 1 2 Slight Risk PHASE 2 3 Moderate Risk MEDIUM PHASE 3 4 High Risk 5 Very High HIGH PHASE 4 Risk PHASE 5 Implemented in April 2014 and currently on going on voluntary basis Phase 2 to phase 5 proposed to be implemented concurrently engaging through public consultation

34 IMPLEMENTATION MEDIUM & HIGH RISK (PHASE II) CURRENT APPROVAL PROCEDURES NEW APPROVAL PROCEDURES SWAT 14 days 21 days 1 day 14 days 14 days Planning PDC 1 Design PDC 2 Notice Start Works PDC 6 Intermediate Inspection PDC 7 Final Inspection PDC 8 Sewerage Works Application SWA Sewerage Works Inspection SWI Sewerage Works Completion SWC 14 days 1 day 14 days

35 SWAT PHASE II: APPROVAL PROCEDURES SPECIFICATIONS SWA Consists of planning and design components; Planning and design components can be submitted independently by choice. SWI CP to submit inspection report and declaration to CA as specified; CA can conduct spot inspections as determined by Commission. SWC T&C for public sewerage assets will be witnessed by CA and Operator for the purposes of final inspection and taking over; For private sewerage assets, only declaration by CP is required

36 SWAT Phase II (Procedure) STP Sewerage Infrastructure Status < 10k PE Public NPS > 10k PE < 400 mm dia. NWS > 400 mm dia. Private STP NPS NWS Planning checked by CA SWA Design Checked by CA Declared by CP SWI Inspected & declared by CP SWC T&C by CA & OPS T&C declared by CP Notes: a) For public STP in compliance with TS approved and endorsed by the Commission, design declaration by CP for SWA is sufficient; b) The Commission or any person authorized by the Commission may inspect the sewerage works at any time deemed necessary by the Commission.

37 FEEDBACK VIA ONLINE OR SURVEY FORM IN YOUR REGISTRATION PACK SPAN VALUES YOUR OPINION SURVEY swatphase2@span.gov.my PUBLIC CONSULTATION 2 February March 2016

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39 Sewerage Industry - Issues Of Concern Safety System & Product Effluent noncompliance Structural quality & integrity Abondonment of STP / not handed over WHAT? Take over CAPEX Operator O&M works Consultant Design Responsibility Site supervision Quality Control Product Efficiency Standard Lack of skills & knowledge Design not following specification Sub-Standard product High O&M cost Lack of enforcement action Lack of competency in system handling Frequent system breakdown Highly sophisticated system not economical Obsolete system HOW? SEWERAGE INDUSTRY WHO? Regulator Changes Enforcement / Legal action Developer Contractor Supplier Cost Saving (design / choice of product) Quality / Site Supervision Lack of awareness & understanding Lackadaisical attitude towards enhancing knowledge & skills Insufficient CAPEX Inavailability of standards & specifications Sub-standard system constructed and took over by SL WHY? SOLUTION? Public Policy set up / Implementation Training / Capacity Building Enforcement / Legal action Standard & Specification Registration (control mechanism) Generation of Fund (SCC, Rolling Fund, etc) Sewerage Development Plan Sewerage Strategic Direction Public Nuisance Tariff / Bill

40 SPIN OFF ACTIVITIES FROM SWAT INITIATIVE Development And Implementation Of Technical Specifications And Standards Modernization of SCC Collection Mechanism Development Of Sewerage Infrastructure Selection Criteria Restructuring Of Competency And Skills Landscape For Water Services Sector

41 TECHNICAL SPECIFICATION & STANDARD STP Lacking of competency skills Why?? HOW?? Problem Statement Proliferation of small scale STP Poor workmanship and installation Insufficient standards and specification Errors during planning/design/ inspection stage Multiple suppliers Multiple substandard products and systems Structural integrity and quality Multiple products and systems Lack of enforcement High O&M cost STANDARDISATION 1. Benchmark sewerage products Equipment Systems 2. Benchmark sewage treatment processes Extended Aeration (EA) Sequencing Batch Reactor (SBR) etc 3. Uniform Sewerage System Standardised Sewage Treatment Plant (STP) Standardised Network Pump Station (NPS) Standardised Sewer Network (SN) Resolution Documents Marketing

42 STANDARD STP TECHNICAL FRAMEWORK Documents Marketing Technical Specification for Standard STP SWAT Model TS Standard STP Part 1 : EA User guide Requirements for Planning & Design Requirements for Construction & Installation Requirements for Testing & Commissioning Standardized Sewage Treatment Plant (STP) Public Access SPAN Sewerage Portal Stakeholder engagement report Process calculation program Engineering drawing Declaration and disclaimer Targeted for Public Comment on 14 December 2015 Internal progress meeting MoM TS Standard STP Part 1: EA Development Process Engineering drawings Construction cost estimation Statistics

43 MODERNIZATION OF SCC COLLECTION MECHANISM ISSUES Problem Statement Different intrepetation and understanding on regulatory requirement Different practices and unconsistent requirement Stakeholder confuse IMPACT Redundant scope of work Too much regulatory input Approval process delayed Receipt must be produced before final inspection can be given clearance

44 HOW IT CAME ABOUT To facilitate the stakeholders in complying the requirements 3 Utilize IT App Establish uniform practice and clear understanding among stakeholder especially to the processing officer 2 Provide Guidance Note 1 Strengthening Self Regulation Approach Simplyfying the process by shifting the mechanism from input to output regulatory process

45 NEW vs OLD MECHANISM New Mechanism Old Mechanism 1 d 30 d

46 WHAT S NEW: SCC CALCULATOR To facilitate stakeholder fill up the Form K by minimizing the simple mistake. Can be access at SPAN website It is not submission online. The complete form need to be print out and submit to CA together with the payment. Info will be use for the verification process (regulatory audit).

47 THE CHALLENGES Acceptance by the processing officer Changing the mindset to approve now and check it later concept Difficulty on using the SCC Calculator Non compliance issue

48 WAY FORWARD Long Term All interaction of SCC payment thru electronic medium via online system Short Term Enhancement of SCC Calculator to become more user friendly Immediate Publicity initiative to stakeholders continue

49 SEWERAGE INFRASTRUCTURE SELECTION CRITERIA SISCA Score from Sewerage Strategy Matrix (SSM) criteria 1 to 4 : Public Health & Safety Overriding Criteria criteria 5 to 7 : Environment & Water Resource

50 SEWERAGE STRATEGY MATRIX Urbanisation Population Density Population Growth Rate Strategic Importance River/Dam/Groundwater Use River Water Quality Assimilative Capacity (% of effluent distribution at DWF)

51 Feasible operating cost i.e. 'cut off' capacity SEWERAGE INFRASTRUCTURE OVERIDING CRITERIA a OVERRIDING CRITERIA b CONNECT if have existing sewerage facili c Determined from Type of Infrastructure If connection cost exceeds above 20% re yardstick cost, then refer to c. ECONOMIC FEASIBILITY (everything in excep Septic Tank (ST) or STP

52 a CONNECT if have existing facility nearby OVERRIDING CRITERIA b c If connection cost exceeds above 20% JPP's yardstick cost, then to refer to c. ECONOMIC FEASIBILITY (everything in exception to a) - ST or STP Feasible Operating Cost (i.e. cut-off capacity X PE) Operating Cost consists of : a) Regulatory cost - monitoring operators - Monitoring users b) Environmental cost - Failure on compliance X > 20% JPP yardstick cost RM/PE Feasible operating cost RM/PE CAPEX (Including Land) Y OPEX (ST vs STP) X Distance (km) ST STP PE

53 STAKEHOLDERS KNOWLEDGE AREA Public Policy maker Regulator Inspection / Certification Body Supplier Water Sector Stakeholders Project Implementer Certifying Agency Permit Holder Developer Qualified Person / Competent Person Service Licensee / Operator

54 ULTIMATE GOAL ON QUALITY OF PERSONS What we want? QUALIFIED and COMPETENT persons in water services sector How to establish that? Get them assessed and trained Who must be competent? Who must be assessed and trained? Who needs what? How to assess and train? How to compel them to comply?

55 CHALLENGES IN CAPACITY BUILDING At present human related capacity building in the industry are largely informal and based on the followings: Lack of stakeholders involvement in the aspect of human capital development Training costs are too expensive Training modules not impressive and effective Training providers and trainers are not appropriately regulated Competency program by regulators are not structured and holistic Competency requirement made mandatory intuitively due to specific issues The actual needs of the industry, its objectives and impacts were not sufficiently identified, verified and addressed.

56 STAKEHOLDER KNOWLEDGE MATRIX

57 PRIORITIZATION OF CRITICAL KNOWLEDGE COMPONENT From the knowledge prioritization matrix, the top 3 knowledge in ranking has been identified and shall be put into focus for strategic implementation;- 1. Operation & Maintenance, Treatment (sewage & sludge) 2. Operation & Maintenance, Desludging & Disposal 3. Operation & Maintenance, Conveyance (sewer & NPS)

58 COLLABORATIVE EFFORTS Accreditation process NOSS development process BP / SLDN Submission of application by the training provider (TP) PPT Submission from the applicant Request of NOSS development from industry Verification visits & presentation Approval committee Submission of experience log / achievement (evidence of competency) as per NOSS requirement Interview session Appointment of NOSS Development Committee (WG) Evaluation committee SPAN (DD/SE/E) SPAN (DD/D) Issuance of accreditation certificate Approval committee Approval committee SPAN (D) SPAN to joint JPK during annual audit Recognition and issuance of SKM Publication of NOSS

59 THANK YOU No country can really develop unless its citizens are educated