Proposed WAP

The Proposed Water Allocation Plan (WAP)

As at the end of October 2014, no one from the community has seen the proposed WAP. Criticism of it is based on two Consultative meetings with the NRM Board and contributors to the WAP, held in Port Lincoln (October 13,) and Elliston (October 14), and the recently released “Additional science support for the Eyre Peninsula Water Allocation Plan” DEWNR Technical Report 2013/19.

The intention of the proposed WAP can be summarized: The Government is going to extract as much water as needed to supply Eyre Peninsula each year for the next ten years, regardless of whether the basins can sustain it or not. It is important to them that as much water as possible be allocated to SA Water for the community so that the profits they make can go to the Government.

They are prepared to take this water without regard to protecting the native vegetation dependent on groundwater – for example the red gums at Polda, and wetlands in other places.

Draining our underground “rainwater tanks” is much cheaper than tackling the issue of maintaining our basins in an ecologically sustainable way for all future generations.

The proposed WAP needs to be seriously revised to take into account the views of the people on EP and not consist of what the Government and their advisors think is good for us.


Our WAP (the People’s WAP)

The Water Allocation Plan, in its present form, contains only the thoughts and intentions of various water managers, mainly in Adelaide. It has been starkly evident in the consultation that has occurred so far, that they either have no idea of past events or are deliberately ignoring them.

What the community needs to see is a proposed WAP that takes into account a combined view of what has been happening and what needs to be done now based on the best local experience available. More importantly it should be made clear what it is the people of EP want, not just the Government.

This will require much more consultation between the various parties, with the assistance of a facilitator, to ensure a fair and balanced outcome. Without this the outcome will be far less successful than it could be.


More Monitoring

Much of the failure of the present WAP can be put down to the lack of monitoring. It was legally required in the WAP but constantly pushed aside by the NRM Board as some sort of “wish list”. The presently proposed monitoring scheme suits those keeping track of the remaining water in selected places but makes no attempt to monitor those bores that have had water in them in the past. To allow this to go ahead unchanged will result in the future in having no measure of recovery (if any) and the community will be forced to rely on very restricted information.


Extraction? Or Extraction with Recovery?

The proposed WAP is only concerned with ensuring there is enough water to be extracted from the basins for projected community use for the next 10 years. In this context “sustainable” means that the basins can “sustain” the demand placed on them before they run out in the future.

It is possible to both extract groundwater AND achieve a measure of recovery over the life of the proposed WAP (ten years) but only by reducing what is taken and by supplementing the remainder with water from alternative sources. This is the essence of being “ecologically sustainable”.

Any suggestion that the community wait another 10 years before taking action to start restoring our basins is extremely short-sighted. The sooner we start, the longer we have to achieve our restoration, and the easier it will be over time.

The proposed WAP for example could refrain from taking any water from Uley-Wanilla Basin, and the Lincoln Basin area, for at least as long as it takes for them to supply an ecologically sustainable amount of water into the future. Polda of course should be officially closed to any future public water supply.


Accessing “brackish” Water.

This is an issue that needs far more careful scrutiny before it can be accepted by the community. It presently appears to be strategy for SA Water to access enough water over the next 10 years to ensure that projected demand will be met and their profits maintained. It will probably conform to WHO’s strict definition of “drinkable” but be regarded as “undrinkable” by many.

The question that needs to be answered by our water managers is: “is it necessary?” Probably it is from the point of view of SA Water, but is there an alternative more acceptable to the community?


Paying for the Monitoring

One of the reasons the monitoring proposed in the present WAP was not done was the Government refused to fund it. In fact this was contrary to the legal requirements of the WAP. To avoid establishing a comprehensive monitoring scheme acceptable to all but not funded, it is again necessary to put it into the WAP. Making it a legal requirement. Then the community, the NRM Board (if it still exists) and the Opposition can maintain the pressure, with legal backing, to ensure it gets done.


Extending the Prescribed Wells Area

This action has been discussed since 2006 by the EP NRM board and others, but nothing has ever come of it. The Government has persistently avoided it on the grounds of cost and effort.

The Southern Basins are contained within the Prescribed Wells Area (PWA) and strict conditions apply to water access, and is the reason for having a Water Allocation Plan (WAP) to ensure that it is managed carefully. The problem is that the PWA area was drawn up before the nature and extent of the Basin was properly understood.

For proper water management in the region, all areas of the basin AND their catchments need to be subject to careful control. In the absence of complete coverage of the total catchment landholders outside the PWA can create dams reducing basin recharge, access significant amounts of water without proper monitoring, and reduce water required for the maintenance of groundwater dependent ecosystems. Businesses can be started up along side the PWA that can extract vast quantities of water with little or no control of the long term effects on the basins.

It may well be that extending the PWA is all too difficult, but discussion of this issue for inclusion in the proposed WAP may come up with an acceptable alternative, and not just leave it unresolved.


Establishing a “Baseline”

It has been argued that to handle the allocations from the various basins, some sort of “baseline” level needed to be used. It has been said that it needs to be the same baseline for each basin. To that end, an examination of past water levels and rainfall resulted in 1993 being the “baseline” for future reference.

The problem with this is, that in many cases, if not all, the water levels in the basins were higher in previous years than in 1993. By focusing all future measurements on 1993, and using it as the “100% full level” the impression is given that all future allocations are measured against the time when the basin was really full. This is not true.

The only true indication of the state of the various basins is to make use of the water levels from past monitoring and using the highest levels recorded as “full”.

If that indicated, for example, that there were 5 metres of water in the basin, and in 1993 it was 3 metres in the basin, then it has already declined by 40% before the new “baseline” is used for the new allocations.

If, by 2015 the water level is 2 metres, this means that the basin has already declined (historically) by 60%, and not 33% if compared with 1993. These are significant differences and they should be reflected in the amount of water that can be extracted from a basin that has already declined by so much.

This position was recognized by the Parliamentary Inquiry and specifically referred to in their Final Report (pages 81, 82 and see picture page 83).


Reducing the Water for the Environment

In the present WAP, 60% of the recharge is set aside for the environment. The report “Additional science support for the Eyre Peninsula Water Allocation Planreduces this to 30% for all water sources in the Uley South Public Water Supply area. This is arrived by decided NON-scientific means and indicates the length the DEWNR is prepared to go to access enough water for the region. Its effect is to put in jeopardy the ecologically sustainable future of Uley South.

No attempt has been made since the initial decision to divide the recharge into 60/40 (60% for the environment and 40% for allocation) to in fact confirm whether this “fits” our basins. It is in fact likely that a better ratio would be 70/30 but no one wants to do the observations necessary to confirm this – just in case it turns out to be correct. That would really require a reduction in the amount of water that can be extracted.

Choosing a 30/70 ratio in the proposed WAP endangers the future of Uley South until more work has been done. In the meantime, the precautionary principle must be invoked and the ratio kept at 60/40 until there is much more scientific evidence to the contrary.


Maintaining Red Gums and Native Vegetation.

When EPWAG questioned what was happening to the red gums at Polda it was told that a study had been done and there decline was not due to lack of water, but climate change and attack from disease. It has recently been revealed that no such scientific study has been made. Our water managers have been keen to overlook the fact that the Natural Resources Management Act does not over-ride the Native Vegetation Act. Mature trees and other areas of native vegetation have been jeopardized by water managers taking too much water. This issue needs to be settled before the proposed WAP settles on how much and from where it will get water over the next 10 years.


Our Swamps – Wetlands or Not?

A study carried out by a WA ecologist on our wetlands (paid for by the EP NRM Board) is being ignored when it comes to classifying our swamps. Because they are inconveniently located on or close to Uley South Basin they are an impediment to accessing more water from the basin as well as of concern to any future mining.

The thinking behind the water managers’ refusal to include the Swamps as wetlands needs to be far more closely examined rather than just taking their say-so.

These then are additional concerns from EPWAG relating to the issues that need resolving before an incomplete and poorly scientifically based proposed WAP is put up for widespread community discussion. Anyone who thinks they can add materially to our understanding of these issues is invited to contact EPWAG at any time.


Restoring our Basins

The recent history of water management on EP has resulted in basins being depleted or becoming too saline. Here is a list:

Tod Reservoir                too saline, closed off in 2002/3

Robinson Basin             too saline

Uley Wanilla Basin        over-extracted

Lincoln A                       salinity issues

Lincoln B                              “           “

Lincoln C                              “           “

Uley East Basin             declined without extraction – where has the water gone?

Polda Basin                   depleted – closed off in 2008 – no real recovery


It was claimed at the Consultative Meeting (Port Lincoln Oct 13) that there was no ability for the WAP to restore the basins. Such an attitude needs to be challenged.

Graphs showing the amount of water extracted from Uley Wanilla clearly show that this basin could have produced a sustainable supply of water for decades if the amount extracted had been limited to (say) 500ML/a. The proposed WAP should close off extraction from this basin until it has recovered to the point where it can give a sizable ecologically sustainable amount.

Similar water level graphs also show that the Lincoln Basins have been reduced to the point where an increase in salinity threatens their long-term future. These basins, and their surroundings, should also be closed off to ensure their recovery.

Although no water has been extracted from Uley East Basin, it too needs to be monitored to ensure that it recovers to its full capacity as an indication that the Southern Basins are being restored.

The proposed WAP takes no account of the reduced state of our basins as a result of past mismanagement. This is both unacceptable and short-sighted and needs to be corrected.






Two Important Issues

1. The People’s WAP

The Parliamentary Inquiry in its Interim Report made it quite clear that the Water Allocation Plan should be a “people’s WAP”.

   “The Committee believes that greater involvement of dissenting community members and landholders needs to be encouraged. The Eyre Peninsula NRM Board/DEWNR should not fear a Water Allocation Plan (WAP) that does not accord with departmental views as the Minister (advised by their department) has the final say on WAPs anyway. It is more important that consultation be genuine. The Draft WAP should be a ‘people’s WAP’, as is intended under the Natural Resources Management Act.” (Natural resources Committee Sep 2012, pages iii-iv) Hon. Steph Key Presiding Member 18 September 2012

The proposed WAP as it is at present has NOT taken into account various stakeholders’ views in an attempt to make consultation genuine. It cannot be a “people’s WAP” until there is a resumption of the Consultative Committees created in 2010 and so ignominiously dismissed in April 2012 before the work of writing the WAP had really begun.

At the very least there are a dozen of more issues (many identified in the PLT Advert of November 4th) that need to be thrashed out before the WAP is presented to the wider community, and ultimately the Minister. Without the democratic involvement of the various stakeholders, those in particular who will be directly affected by the proposed WAP, then anything put up by a majority of people who do not even live in the region, needs to be opposed.


2. Ecologically Sustainable

The Natural Resources Management Act, which requires that an approved Water Allocation Plan must be drawn up, makes it abundantly clear (Chapter 2 7 – Objects)

  1. The objects of this Act include to assist in the achievement of ecologically sustainable development in the State by establishing an integrated scheme to promote the use development of natural resources.

This is then followed by a list of statements that even include “to support and encourage the restoration or rehabilitation of ecological systems and process that have been lost or degraded”.

Spin doctors who want a specific outcome to benefit the Minister (and not the environment let alone the region of EP) select and twist some of the things that are contained in the Act. In practice an Act must be read and interpreted in its entirety (which makes any detailed discussion of this issue extremely lengthy).

However, the nub of the issue can be put in a very few words: “Environmentally degrading actions are unsustainable actions”. The proposed WAP takes the presently degraded water environment of EP and intends to degrade it further, and certainly does not intend to undertake any thing like the amount of restoration that is needed to redress the over-extractions of the past.


Appendix 1

The “National Water Initiative” states in Actions (95).

     States and Territories agree ‘to ensure open and timely consultation with all stakeholders’ in relation to:

        i) pathways for returning overdrawn surface water and groundwater systems to environmentally sustainable extraction levels(paragraphs 41 to 45 refer);

Appendix 2

In Section 7.2 of an SKM Report states “that the EP NRM Board does not wish to return GDEs (Groundwater Dependent Ecosystems) to the condition they experienced 10 to 20 years ago, when climatic conditions were more favourable.