A copy of this letter and attachments were sent to every Member of Parliament in the South Australian Government
10/5/2014
Dear Name,
I am writing to you on behalf of the Eyre Peninsula Water Action Group regarding the response from the Minster of Water, Hon Ian Hunter, to the recommendations authored by the Natural Resources Committee’s Final Report of the Parliamentary Inquiry of the water on the Eyre Peninsula. EPWAG formed in late 2012 following community concerns that the agencies in place to manage the groundwater resources on the Eyre Peninsula were not only ignoring community concern, but actively covering up their own mismanagement and sending our water resources to a permanent demise.
We understand that soon, the NRC’s Final Report and the Minister’s responses will be debated in Parliament. As such, our group felt that we needed to provide each member of Parliament with additional information that is not contained in either the Final Report or that in the Minister’s response. Attached are two documents that contain our collective thoughts/concerns for the future of our ground water resources should the Minister and his agencies/Departments not be held accountable for “ecological sustainability” and the abhorrent way that landholders and members of the community have been ignored when raising their concerns.
EPWAG would also like to acknowledge and congratulate the NRC on their commitment to this process. Their Members have been professional and understanding and EPWAG supports each and every recommendation they have put forward and are keen to be the frontrunners in being involved in any way to enact these recommendations.
Should you have any questions or would like to seek clarification, please do not hesitate to contact us.
Kind regards
Nicole Linsell
Chairperson
Eyre Peninsula Water Action Group
ATTACHMENT 1
Analysing the Minister’s Response to the Inquiry.
Introduction
Following the tabling of the Final Report and its 12 Recommendations on the Eyre Peninsula Water Supply by the Natural Resources Committee, the relevant Minister has to respond in writing within 4 months. This Response is to be tabled in Parliament as soon as practicable for debate. What follows is an analysis of the Response by the Minister, in which he rejects 6 of the recommendations of the Committee, partially accepts three and fully accepts the remaining three.
The comments are presented in the order in which they are prompted by the Minister’s document. In the document being followed the first three pages are the ‘covering letter’ addressed to the NRC, followed by 11 pages detailing the argument for each of the recommendations. They are individually numbered 1-14. The text in quotes is taken from the Response.
Page 1
The Minister claims “the report also highlights a level of misunderstanding about current science, management arrangements and respective roles and responsibilities across government agencies”. This is not the Minister talking, rather it is the Government advisors putting forward a partial truth and claiming that it is in fact the full truth. While some presenters to the NRC may not be familiar with many government arrangements, this should not be allowed to hide the essential truth underlying any confusion of this type.
An examination of the submissions made by the EP community to the Inquiry will find a significant number that show no misunderstanding about present arrangements for water management. These submissions are also the ones that present specific arguments backed by references and detail, arousing significant doubt as to how the water management agencies have fulfilled their responsibilities. It is these that are being denigrated by the comment about misunderstanding, and it is quite false.
Page 2.
(i) To claim that the EP NRM Board “is currently investigating how [to improve information sharing with the community] might be achieved and improved in 2014” is in fact a strong condemnation of the working of the Board since 2005. If it has been unable to properly share information with the community by now, it should be replaced with Board members who can. It might come as a surprise to the Minister to learn, that the Board has spent at least $30,000 on producing a draft Community Engagement Handbook (undated but about 2008) that was never completed and never released. The Board’s incompetence in sorting out their priorities and keeping the community adequately informed is staggering.
(ii) The Minister makes reference to the fact that “the Natural Resources Committee appears to have placed equal weight on anecdotal evidence as that from peer-reviewed and robust scientific analysis. . . . Consequently, a number of conclusions and recommendations that have been made are not supported by scientific evidence.”
It is just NOT possible for the water management situation on EP to be supported entirely and only by scientific evidence. To claim otherwise is insulting to years of land management by farmers and the like. While there is much scientific evidence relating to the water situation on EP, there is also a huge amount that has NOT been scientifically proven, which including the absence of detailed monitoring information on the WAP was meant to be based, if it was to function properly. In the absence of reliable scientific evidence, inferences and conjectures have to be made to ‘fill the gaps’ if decisions are to be made – even if only temporarily until more becomes available. However, there is scientific evidence that CANNOT ever be obtained. This is the information based on observations carried out by observers in the past. Their observations and inferences are of extreme value today, especially when the relevant information is needed but not yet available.
What we have in the Minister’s response is the reaction of those in charge of water management, that have reams of information but lack that which is relevant to today’s problems. Their only defence when challenged by people with experience is to claim that their evidence is superior, and to denigrate anything that does not support their view. In fact, there are many instances when “the locals” have been proved to know better that the “managers” using all their scientific evidence – and the most obvious example is demonstrated with the history of Polda.
Management is not a ‘science’ although it must be based on as much science and ‘experience’ as possible. It is an ‘art’ that the present water management agencies do not seem to possess.
(iii). The Minister claims: “the Committee’s conclusion that ‘the cause of the decline in water quantity and quality in the limestone basins cannot be clearly attributed to either natural causes or over extraction by SA Water – it is most likely a combination of both’ is not supported by existing scientific analysis, nor the CSIRO technical report.”
This statement is a gross distortion of what the CSIRO technical report actually said. On page 95 of the Final Report the NRC stated (6.1.1):
“The consultants concluded that there was sufficient evidence available to make a determination as to whether climate change/reduced rainfall or extraction was the most significant cause of declining water quantity and quality, but that such an exercise was beyond the scope of their brief:
‘There are various methods to separate impacts of climate change and extraction on water levels. For Uley Basin, a groundwater model provides the best approach. For other areas, it would make sense to use a statistical approach.’ (CSIRO 2013, p19)”
The data is available but no-one has bothered to do the calculations? On such an issue as important as this it makes sense to afford this process priority and attention.
The NRC has heard the presentations, has seen the situation at first hand, has listened to the voices of experience, read the scientific conclusions and unanimously came to the most reasonable view that water decline in the quaternary basins was most likely to be a combination of both natural causes AND extraction. This situation is not going to be resolved by words in a Ministerial letter, but by carrying out the work identified by CSIRO. Until that is done the position of the NRC is perfectly reasonable. The implacable opposition by the water management agencies smacks of something to hide.
(iv) “The implication that all or most of the extraction by SA Water is ‘over extraction’ is not accurate and disregards the clear evidence in those basins where SA Water does not draw water and water levels have still occurred.”
Easy to read, but difficult to analyse. Where to start? The key is “over extraction”. Any extraction can only be “over” when compared with something else. The writer of this sentence has in mind the view that water that has been extracted from the basins on EP have never, or rarely, been “over-extracted”. No way could that happen. The amount of water allowed had been calculated (dubiously as it turns out), apportioned, and taken. The idea that any Parliamentary Committee could possibly think that the water had been over extracted is impossible to conceive. The water extracted had been calculated to supply the necessary demand of the community – but it was done regardless of the environmental impact.
The NRC sees the water extracted as being over extracted, especially having come to the conclusion that the impact on water level was MORE than variation in rainfall and climate change – it had to include the effect of extraction. But more than that, ecological sustainability demands that any extraction must be limited to some fraction of the (effective) recharge. Not calculated recharge but effective recharge as can only be measured by changes in water level. This was not being done by the water managers, and hence the various water levels in the basins were declining – a fact ignored by those to wedded to the calculations.
Water management must be based not on community demand but on basin sustainability, otherwise the region soon ends up with nothing but empty basins like Polda.
The effective recharge in any year depends on natural rainfall variation, effects of climate change, the amount coming in from contributing interconnections, and the amount of ground that is dry between the surface and the lowered water table. The amount that can be allocated for extraction depends on the amount taken the previous year, and the amount of ‘leakage’ that is constantly occurring. Either all these things are factored in OR the storage volume of water is assessed and compared with the same assessment the following year.
The biggest blunder in the explanation given in the response is the lack of detail as to exactly what happened to the water in Uley East Basin. The Dept claimed it was there in 2000, but had diminished to almost nothing by the time of the Inquiry (2012). In the absence of any extraction, where has it gone? The disappearance of the water can only be explained as an unforeseen consequence of extraction from Uley Wanilla, Uley South, and the lack of recharge from Big Swamp. But the water managers could never own up to this even being a possibility.
(v) “the commentary in the report . . . . does not acknowledge that SA Water supply water from these areas for critical human needs.” Of course it doesn’t!! Everyone already knows the importance of water. That is NOT up for debate. What is the crux of the issue is how to supply water “for critical human needs” in an ecologically sustainable way. Invoking the idea that the NRC does not care about “critical human needs” is deliberately designed to undermine the Committee’s standing in the eyes of the Minister. It seeks to take the debate away from the real issue and focus it solely on water supply, and not sustainability.
Page 4. (Under Recommendation 1)
(i) “The Eyre Peninsula community will have an opportunity to comment on a draft of the new [WAP] Plan as part of the community consultation process required under the Natural Resources Management Act 2004.”
This statement is repeated throughout the Minister’s Response. It seems to be some sort of escape clause: don’t worry if you disagree with anything in this Response, you will have your chance to voice your view when the draft WAP is up for community consultation.
This is of no comfort at all to anyone genuinely concerned about the long-term sustainable future of our groundwater basins. The reasons are as follows:
By the time the draft WAP is available the position of the water managers will be cemented into place and under no circumstances will any input that undermines their view be considered;
Under no circumstances will community input be discussed by the writers of the WAP and passed back to the presenter for wider discussion before the draft WAP is returned to the Minister for approval;
Far too little time will be made available for the community to actually digest the implications of the new WAP before submissions must be in;
At no time will the EP NRM Board and representatives of the water managing agencies actually enter into a dialogue/discussion with the community with a willingness to incorporate anything of substance into the draft.
As the NRC has already commented (in their Interim Report) the WAP is meant to be a community document, not one produced by managers to please the Minister. After all he can change it if he wants.
Unless the foundation of an ecologically sustainable groundwater basin management scheme is firmly in the WAP it won’t be incorporated through community input – there are far too many barriers to allow it to have any impact no matter the rightness of their views.
(ii) Under Recommendation 2
“The NRM Board and its Water Resources Advisory Committee has in place a strategic approach to the sustainable management of water resources across the whole of its region under the Natural Resources Management Act 2004.”
This assertion can only be called a false claim. There is no legitimate strategic approach to the sustainable management of water resources – because the demise of Polda could never have happened if it was managed in an ecologically sustainable fashion as required by the Act. There has certainly been NO change in strategic direction since 2008 or the community would have noticed it! The underlying reason in calling for a Parliamentary Inquiry was that the groundwater basins were NOT being managed sustainably – they were declining. And this has been amply demonstrated, even proven, by the results of the Inquiry.
(iii) Under Recommendation 2
“The assessment of future water supply opportunities is not part of the Board’s legislative functions.”
This may be so, however, the Board cannot sit back and watch the groundwater resources decline without intervening. Unless the Board can question what it is being told by the various water management agencies to confirm that any strategic approach to the sustainable management of water is actually occurring, then it’s an impotent rubberstamp and not any sort of watchdog at all. Maybe that is why Polda was over-extracted.
Page 5 (Under Recommendation 3)
(i) “SA Water will continue to undertake long-term planning that addresses water security for its customers in the region”
Here is the nub of the underlying malaise of water management on EP. The future security of water is not the sole responsibility of SA Water. It involves the community, landholders, Local Governments and Councils, DEWNR and the Minister’s department as well as the NRM Board. A strategic approach to regional water management would require regular input from all parties at some sort of forum each year.
SA Water cannot resolve a problem unless the solution suits SA Water. The latest project for them to spend $3.9 million on a pipeline connecting Coffin Bay to the Southern Basins is an excellent example of this. The basic concern is said to be that SA Water believes that there is insufficient water in the Coffin Bay lens to supply the township into the future – their solution – a new pipeline that only strains the Southern Basins even further. Taking an approach broader than just SA Water, would recognize that many dwellings in Coffin Bay either have no rainwater tanks or the ones they have are pretty small. If the District Council of Lower Eyre Peninsula were to require all dwellings in Coffin Bay to install rainwater tanks commensurate in size with the roof catchment of the dwellings, there would be no need for a new pipeline. Many dwellings in Coffin Bay are vacant for much of the year. In the extremely unlikely event that there is a dire water shortage emergency, potable water can be easily transported in at a fraction of the cost of a pipeline and the running costs of a pump.
(ii) Page 5 Under Recommendation 3
“SA Water has been working with the Ceduna Council on the proposed desalination plant at Denial Bay since the late 2000’s.”
A more accurate summary would be: SA Water has been intransigent in engaging in any cooperative endeavours with the Ceduna Council. Discussion on this issue has only resumed with any hint of progress since the Parliamentary Inquiry. Recently there is news that SA Water is demanding a higher standard of water be carried in its leased pipeline than the water they supply. This is an issue yet to run its course, but the Minister’s partial support is disingenuous to say the least (if not premature).
Page 6. Recommendation 4
“It is recognized that there may be some community confusion about these administrative arrangements.” See above Page 1.
Page 7. Recommendation 4
“Prescription is undertaken where a water resource is stressed or likely to be stressed in the near future and requires intensive and ongoing management through the imposition of a licensing regime on water users through the water allocation plan.”
It is the view of many that the Southern Basins, are stressed, and that stress will increase unless there is a change in management. Management in the area is confused with different authorities having differing responsibilities with the Prescribed Wells Area, the Water Protection Area and the Water Protection Zone. The result is that what should be managed as one comprehensive water catchment is splintered between various departments, the local government and the EPA.
Managing groundwater systems where water movement is unseen is very different from managing above-ground systems with creeks, rivers and lakes. This is the differing jurisdictions that need to be reviewed. Reference to Robinson Basin, although well-intentioned, has served as a distraction from the real issue surrounding the Southern Basins.
The most significant source of water in the region is now the Southern Basins, and it is this location that demands a review of management responsibilities.
Page 8 Recommendation 6
The issue of dams would not have arisen had the total catchment of the Southern Basins been placed under prescription. Even now, the solution proposed is at the best partial, and at worse, of no real sustainable value.
“The Board has recommended that landholders that have medium to large on-stream dams voluntarily install low-flow bypasses and that those who extract water from the watercourse also voluntarily measure their extractions and limit these periods above the threshold flow rate determined for that particular location.” (emphasis added).
The situation has been known locally since it was raised by John Hyde in the 1990’s. At no time since has there been any sign of action, voluntary or otherwise, that will resolve the issue. The claim in the Minister’s Response that a number of voluntary responses will settle the matter is just an example of wishful thinking rather than the taking of decisive action.
The idea that “native fish surveys, stream-flow monitoring, photo point monitoring and ongoing management of water affecting activities through relevant permits and compliance will continue” is just papering over the cracks. There is no indication here that any attempt will be made at any sort of restoration that will go a long way to repairing the damage incurred in the past, yet real ecological sustainability requires this to happen.
Page 9 Recommendation 7
(i)The argument against any relocation of staff from Adelaide to Eyre Peninsula is easily recognizable as a policy position being upheld regardless of the on-ground situation. Eyre Peninsula does have the need for inspection and/or monitoring staff to be on the spot – the evidence for that is the list of occasions when monitoring has not been done by the Board, when information from monitoring has not been made available relating to trigger points, the cacophony of outbursts from Landholders trying to get a fair go from mining companies as they carry out exploration which is seen as disruptive.
If the Government does not want to listen to reason on a policy matter, it won’t. Hence this recommendation is not supported. Any belief that the NRM Board “will continue” to work with relevant Government agencies and be effective, need only look at the mess we are presently in to hold out little hope that it will occur.
Page 10. Recommendation 8
(i) The Minister’s Response to this is prefaced by the deflection that “this recommendation relates mainly to the Polda Basin”. In fact, the problems on Eyre Peninsula can be traced back to the fact that Section 8 Monitoring in the WAP (2000) has been deliberately ignored, to the point that when challenged on the legality of the WAP requiring this monitoring to occur, the Board has steadfastly refused to resolve this issue. It opted (against strong community opposition) to ensure that it was in fact NOT carried out. This position of the Board has been dismissed by the NRC with its unequivocal finding that the WAP is a legal document.
There is something radically wrong in taking the next sentence at face value. The claim is made that for Polda “the annual recharge rate is estimated using changes in groundwater levels, not changes in rainfall”. This can’t possibly be the full story.
Much of the discussion in front of Dean Brown at Lock (2010) was based on the claim that false rainfall records were being used in determining the amount of water that could be extracted from Polda. In practice, if the management agencies (including SA Water) had in reality been monitoring the changes in groundwater levels in Polda it could never have been driven down to the point that it was empty. In fact it has continued to remain empty such that Notices of Prohibition for its use are still in force SIX years later (and it is a widely held belief that the Prohibition should remain for many years to come!)
(ii) The response to Recommendation 8 continues: “In 2009, four pluviographs were installed on Polda Basin, three on Uley South Basin and one at Coffin Bay. These rainfall stations take hourly measurements of rainfall with the results available on the website.” No explanation is given for this action, but it occurs at a time when we are told that ‘the annual recharge is estimated using changes in groundwater levels, not changes in rainfall.’ They can’t both be right in the form argued in the response.
This explanation can only be understood if it seen as a post-event cover-up.
Page 11 Recommendation 9
The Minister’s refusal to support Recommendation 9 is a blockage to information. What this recommendation from the Inquiry seeks is for basic information relevant to determining extraction be made available to all those making and affected by the decision. The due diligence of the agencies will be kept in check through thorough community consultation and accountability. Only in this way can a proper watch be kept so that allocations are not exceeded.
It is not enough for SA Water to inform DEWNR. The Board and the community must also be involved to ensure that SA Water does not exceed their water allocations. The claim that “it will not always be appropriate to require extractions to immediately cease where unforeseen circumstances have dictated that SA Water have reached their allocation limit” is to avoid exactly that from ever happening. The more widely known the allowed extraction, the more people will see if in fact they are approaching their limit and warn them well in advance.
The claim that an increase in monitoring and publishing of data would be difficult and costly is laughable. The information has to be collected and collated to be useful, and putting it on the internet is what is already done with this sort of information. This is an attempt to shield the sharing of this information of the very sort that needs to widely available. The way around it is of course through the Freedom Of Information.
Page 13 Recommendation 11
This Minister’s Response to this issue cannot be dealt with adequately with a brief analysis of the three paragraphs in the document. A more complete discussion of this vital issue is contained in: “The 1993 Argument: A new “year zero’? (Final Report page 81).”
Page 14 Recommendation 12
The purpose of this Recommendation is to close off Polda permanently from commercial extraction (“SA Water to permanently decommission it’s pumps and limit future extraction…) and leave it for the local landholders (stock and domestic) and for emergencies (human need and fire fighting), it does not say local landowners decommission their pumps which is implied in the Minister’s response (“and four landowners no longer being able to access water for licensed purposes”). It is suspected the real reason SA Water does not want this basin closed off is because they have spent many tens of thousands of dollars (may be more) on equipment in anticipation of accessing Polda water in the very near future. They refuse to acknowledge that their management has resulted in such a monumental disaster and as former MP Liz Penfold stated it was “environmental vandalism”. So their stance is: there is water in there (or there will be in the future) and we will continue to exercise our rights to extract it.
Anyone, like the NRC, who has taken the time to see the impact of the poor management of Polda to date, has no hesitation in wanting it closed off. The photograph on page 83 of the Final Report should be persuasive enough to leave Polda alone. The amount of water coming on to Eyre from the River Murray is more than enough to compensate for closing off Polda.
ATTACHMENT 2
The 1993 Argument: A new “year zero’? (Final Report page 81).
Introduction
In the Final Report of the NRC, the basic argument concerning 1993 as a new year zero is put by Stewart (2013). DEWNR “needs to be able to compare that level of storage to some kind of baseline, so some 100 per cent full status… The climate on Eyre Peninsula has changed significantly over the last 50 years, and we need to start considering that when we’re allocating water there.” And further on: “Every year we model the level of storage within the different consumptive pools and determine what the level of storage is and then that will help guide how allocations will be varied.”
Putting aside for the moment the specific year of 1993, what is Stewart really arguing for? Water managers are looking to have a water storage level baseline which can be used to “guide how allocations will be varied.” The reason for this need is because “the climate on Eyre Peninsula has changed significantly over the last 50 years.” (For the full argument see the NRC’s Final Report page 81).
This position refers to “significant” changes in climate on EP over the last 50years. In fact, there have been no significant changes during that time – even the Final Report makes mention of only a less than 10% change in rainfall over 100 years, and even that varies year to year. More to the point Stewart’s argument fails to make mention that one of the greatest changes impacting on any water storage level storage on EP during the last 50 years is the amount of water being extracted.
A Better Interpretation
A more honest presentation of the position would go like this:
“The water storage level in the lenses on EP is the result of a number of factors, both input factors and output factors. The main input factor is rainfall (which varies according to normal annual changes in rainfall, and any effect of climate change). The best measure of “rainfall” as a factor in the water storage level is not rainfall itself, but the “effective recharge”, ie the amount of rainfall that actually enters the storage lens or basin.
The main output factors are ‘leakage’ (from the bottom of the lens or basin or from the sides and top as a result of overflow from the lens or basin) and water extraction.
If the water storage level is measured in exactly the same way at the end of each year (April 30 has been suggested) and compared to the same measurements the previous year, then the difference in storage water volume can be attributed to: rainfall (more or less), climate change (more or less), ‘leakage’ (presumably little changed over the years, except for the impact of extraction) and extraction itself.
For ecologically sustainable management of the basins, it does not matter if it is not possible to measure the rainfall, climate change, or ‘leakage’ because it is not possible to manage any of them! These factors are independent, ie beyond the control of water management.
The only factor that can be measured is water extraction. The storage water level can only be maintained by manipulating water extraction. It does NOT matter how much or how little this is, if the other three independent factors + water extraction produce a reduced storage water level then the future sustainability of the basin is in jeopardy. If the three independent factors + water extraction produces an increase in storage water level then the future sustainability of the basin is assured.”
Discussion
This view (or model) of reality is never put by the Department because it does not suit them. They want a reliable (even increasing?) quantity of water to be available for sale each year to maintain income. The prospect of a diminishing quantity of water available from the basins over time only makes their job of supply more difficult and challenging. An even worse prospect is the closing off of the groundwater basins altogether as a saleable source of water.
This explains DEWNR’s position and that of its predecessor DfW, of ignoring the management principle for groundwater – that is, limiting the amount of water for allocation to a percentage of effective recharge. By NOT measuring effective recharge but pointing to rainfall, ground porosity, climate change, area of the basin, the impact of native vegetation among other things, it is possible to juggle the calculations for allowable water extraction to suit their needs and not that of the environment.
Measuring effective recharge allows the intrusion of such factors as variation in rainfall, the impact of climate change (no matter how slight) and the extent of interconnectivity between basins, etc to be part of the argument. By not focusing on the only measure that matters, the storage water level (along with the amount of water actually extracted) and using that as the guide to management, a “recharge” figure is calculated and adhered to regardless of the change in storage water level. All the factors, ‘other than extraction’, are then used to “explain” why the water levels in the monitoring bores are following a downward trend.
The clash between the Department and the NRM Act and its requirement for ecologically sustainable management is now seen for what it really is. The Act requires the long-term ecological sustainability of the basins to be paramount, whereas the Department insists that the water demand of the region be met at every turn, no matter what the environmental consequences. They would even insist, if confronted with the issue put in these terms that the basins must decline if the water demands of the region are to be met.
These two opposing positions can only be reconciled when they are acknowledged, and their differences defined. This is not happening at the moment.
[An Aside: There is already strong community opposition on EP towards the “new year zero” 1993. Their view has been best expressed in the Final Report by the NRC. They feared that the new year zero is an attempt to ‘rewrite history’ by disguising the impact of extraction for public water supply on the basins compared to the situation prior to 1962. They went on to recommend that “the full basin level should be the maximum level recorded historically based on the best available scientific records; eg pre-1962 (higher) water levels could be considered for use as the baseline”. This position was adopted after the NRC viewed the situation at Polda, where the 1993 “new year zero” would be barely 30 cm above the present “rock” bottom of landholder basins.
Implications of Accepting the 1993 Baseline
The need for some sort of baseline from which to measure the impact of the input and output factors is real. The year 1993 is as good a baseline ‘full year’ is as good as any, but the danger still exists that by itself it will be used to support the ongoing depletion of the groundwater basins on EP.
The acceptance of 1993 as a baseline year cannot be done in isolation. This guideline for water management must be accompanied by two others if EP’s groundwater system is to be maintained ecologically sustainably. It is necessary for the complete package of the three guidelines to be implemented – each depends on the others for sustainable long-term management.
However, for the new administratively useful guideline to be both effective and widely adopted, it cannot be referred to as the baseline defining the “100% full status” of the basins. It is simply not true. It can be called the 1993 baseline, but it can never be acknowledged that the basins or lenses were “full” at that time.
The first additional guideline is that a second baseline needs to be selected, somewhere between 1993 and the last time the basins can be accepted as full, say 1900. While no-one presently seeks a return of storage water levels to what they were before extraction on a large scale started, it is essential that the basins be managed so as to achieve some degree of recovery from the present position. This will not happen just by monitoring water levels around the 1993 baseline level. Future storage water levels must rise above those of 1993, even if takes many years to reach this second baseline level. The proposed second baseline is really a compromise between the present depleted levels and that of the naturally full state of the past. A possible date for a second baseline could be 1970.
The second additional guideline is that a minimum, unchanging set of bore-holes must be monitored. Over recent decades there has been a constant change to the specific bores that are monitored. There has been a move away from bores that have been monitored for decades to those only recently drilled. This change inevitably distorts any picture being developed of how the water levels of the basins change over the years. While new bores can be added to the list of those being monitored, older ones must remain on the list to complete the picture. This is necessary so as be able to properly gauge any recovery in the whole basin.
Measuring Recharge and Determining Amount to be Extracted.
All that remains to complete the process of sustaining the basins ecologically is to agree on how recharge is to be measured, and then calculating an acceptable level of extraction.
(1) Measuring Recharge.
In recent years, work done by the DEWNR, has produced a modeling of the basins by which it is possible to calculate the volume of water contained in each lens or basin at a given time. This modeling does not take into account the various porosity of the soil structure at different depths which vary greatly. While it is probably possible to improve this modeling in time, it may well be possible to use it now. The approach would be to take the necessary measurements on or as close to a given date (probably April 30) each year, and compare the results with the preceding year. The difference gives the change in water storage volume over the previous 12 months.
The beauty of this approach is that it does not need rainfall gauges, calculations of climate change, effect of native vegetation, estimates of leakage, etc. It is a direct measure of effective recharge. As the only variable that can be managed is the amount extracted in that year, then the change in water storage volume towards an environmentally desirable sustainable level can only be achieved by changing the amount to be extracted in the following year.
For administrative reasons, it does not matter whether the calculations of the allowable extraction volume applies in the 12 month period immediately following the April measurements or in the year following that (ie 14 months later), as long as they are applied and adhered to.
(2) Determining the Amount to be Extracted.
Once the difference in water storage volume over the year has been calculated, a decision has to be made as to how much can be extracted for use by the community. The first decision is what will be the intended level of water volume in the following April. This must take into account the 1993 Baseline, and the second Baseline (eg 1970). A commitment to long-term ecological sustainability means that the intended water volume when next measured must not only be between these two baselines, but must show a gradual increase towards the earlier Baseline over time.
In practice the water volume stored in the basins can be manipulated over time not just through determining the amount of water to be extracted in any one year, but also by varying the amount of water coming onto EP through the Iron Knob-Kimba pipeline as well as encouraging the community to adopt every possible water conservation measure thereby reducing their demand on the groundwater basins.
If sufficient community water conservation measures are widely adopted, then hopefully effective recharge of the lenses and basins will far exceed those of leakage and extraction, to the point where they will recover more quickly than planned.