Questions to Minister


 

 

 

 

 

 

“THE DRAFT WAP MUST BE CHANGED”

 

Minister (Ian Hunter), our group has sought a meeting with you in order to ask you to defer implementing the revised draft Water Allocation Plan for EP. We strongly believe that it needs to be rewritten for the all reasons we are about to present to you.

 

The presentation will (in order) refer to:

            1. The WAP (2000)

            2. The Uley Wanilla case study (John Hyde)

            3. Three pieces of legislation, and policy

                        The National Water Initiative

                        The NRM Act (2004)

                        The NRM State Plan (2006)

            4. The Consultative Process           

            5. The Draft WAP – Two Other Problems

           

 

 (1) The Water Allocation Plan (2000) and the Draft WAP (2015)

 

The starting point of any groundwater allocation plan should be the amount of water that is available for allocation. Because the draft WAP is the latest (second) such plan for use on Eyre Peninsula it provides an unparalleled opportunity to compare the capacity of the various lenses to provide water when the first WAP(s) was initiated in 2000/1 with the present draft WAP 2015.

 

Data from the WAP (2000) Table 2 (page 13) is in the second column, while data from the draft WAP (2015) Tables 17 and 18 (pages 76,77) is in the third column – all units are ML/yr: (A fourth column has been added to show the percentage change over the period 2000-2015).

 

 

 

            Lenses                                   2000                          2015                          %age change

 

                                            RArea  x  RRate  = AAR   RA  x  RR = RCap.

                                

Coffin Bay A                          11  x  34   =  375           13.8  x  29  =  401            +6.93   

Uley Wanilla PWS                 37  x  54  =  2000          14.3  x  13  =  186            -90.7

Uley South PWS                   129 x 155  =  20,000     65.4  x  129 =  8439        -57.8       

                                                                                         

Lincoln A,B,C                         45  x  56  =  2520          1.2  x  35  =  42                – 81.12 – ABC

Lincoln B                                                                   3.95  x  35  =  137.25

Lincoln C                                                                   7.92  x  35  =  277.2

                                                                                  TOTAL  =  456.45

 

Uley East                                19  x  69  =  1310          5.48  x  22  = 120 (A)

                                                                                    2.42  x  22  = 53    (B)

                                                                                    TOTAL  =  173                86.8 !

 

As you can see, most of the changes are not trivial – they are alarming!

 

The situation is made even more alarming when we consider Uley East. This lens has NOT been subject to any large-scale extraction for the reticulated system. Where has its water gone? Up to now it has existed for many decades if not longer.

 

1. Where in the draft WAP is there a summary of the “state of the lenses” comparing the water allocation plan process started in 2000 with the present?

 

 One explanation for the change in water storage that is favoured by a number of water managers, is the lack of rainfall. While variation in rainfall may be part of the explanation, it is not enough to explain the dramatic changes. Some other factor must also be in operation.

 

Put it simply, the amount of groundwater stored in a lens is the result of rainfall, leakage and extraction. Over time, in the past, rainfall must have exceeded leakage for the lens to actually form by accumulating water. Management cannot alter the amount of rain or the amount of water lost through leakage. As the Minister has said in Parliament (18/6/13) there is not much we can do about degraded aquifers except controlling the extraction process”. Management can only control the amount of water that can be extracted.

 

2. Where in the draft WAP are there explanations for the change in area of the lenses, as well as the changes in recharge as presented in the Table?

 

Let us turn to the WAP (2000) for a closer examination of how water has to be managed.

 

The WAP refers to the principle of groundwater management as follows:

 

Page 11: 4.2 CAPACITY OF THE RESOURCE

 

As the primary consideration in the management of these underground water resources is to ensure that demands on the resource do not exceed supply, the general principle of management is that usage must be apportioned from the recharge component of the water budget leaving the storage component intact to ensure the integrity of each resource.

 

The NRM Board has never insisted on this principle of water management being adhered to. The writers of the first WAP recognised the nature of the problem of groundwater extraction. The temptation is to take the stored water ignoring the fact that, if we don’t want an empty lens then we must limit our extraction to a portion of the ongoing recharge.

 

3. Why has this “general principle of management” as presented within the WAP never been followed?

 

Page 3: “2. Assessment of Needs of Dependent Ecosystems

In order to meet the needs of underground water dependent ecosystems it is necessary to maintain the natural discharge processes that make the water available to these ecosystems. If the storage component is allowed to diminish then these discharge processes will be affected, therefore the storage component must also be maintained.

 

4. Why has this instruction never been followed?

 

The storage component of all lenses used for the reticulated supply has been allowed to decline alarmingly. As predicted, this has significantly decreased the number of locations in the region where natural discharges are no longer occurring.

 

5. Why have these discharges (past and present) not been recorded and mapped before now, so as to monitor the effect of extraction?

 

The WAP also refers to climate change: (page 3)

 

Maintaining sufficient water for discharge processes will also assist to buffer variations in storage due to climate induced fluctuating recharge.  

 

 The WAP writers acknowledged the reality of climate change and knew the best response was to maintain storage levels as high as possible. Instead of doing this, the Board and Departmental staff have been known to blame decreases in storage levels on climate change, rather than allowing for it.

 

6. What steps are being taken in the draft WAP to reduce any climate change impact in the future?

 

The WAP (2000) also sets out a series of criteria that limit the amount of water available for allocation:

 

Pages 18-19: 5.3 CRITERIA FOR ALLOCATION

 

General

            13. Water shall not be allocated if the rate of underground water extraction will

            cause, or will likely to cause, the salinity of the water measured at the proposed

            point of extraction to exceed the baseline salinity by more than 100mg/L.

            15. Water shall not be allocated if the rate of underground water extraction will      reduce, or will likely reduce, the saturated thickness of the aquifer at the         proposed point of extraction by 10% or more within any 12 month period.

            16. Water shall not be allocated if the taking of water will reduce, or will be

            likely to reduce, the saturated thickness of the aquifer within a 500 metre radius   of the proposed point of extraction by 5 percent or more within any 12 month

            period.

            18. For the purpose of this Plan, the depth to water and base of the relevant

            aquifer is measured as a distance from the natural surface of the land at a time

            when extraction pump is not operating.

 

            20. that the water to be taken from each point of extraction will not

            (iv) adversely impact upon an ecosystem”.

 

They spell out a series of criteria relating to the amount of water that could be allocated. They were accompanied by a series of on-ground measurements that could be used to ensure over-allocation was not happening. This list of the specific restraints were to be applied before the amount of water available for allocation is actually calculated. Even applying the “rolling ten-year average” for measuring recharge can only be applied after the Criteria for Allocation have been taken into account.

 

 

7. Why has every single one of the sections quoted above been ignored or breeched by the Board?

 

We know these conditions imposed by the WAP have not been met. Among other things, if they had been met, Polda lens would still be functioning. The real tragedy of Polda is that this basin, managed in accord with the directions and guidelines in the WAP, would even now be providing an uninterrupted supply of reasonable quantity and quality of water well into the future, instead sitting there unused.

 

As the table presented earlier shows, failing to implement the conditions in the WAP has affected other lenses as well.

 

The Government is well aware that a WAP must be monitored. The requirements for this are in the WAP too:

 

Pages 29-30 MONITORING

 

This section of the plan outlines a system providing for the regular monitoring of the capacity of the prescribed water resources to meet the demands for water on a continuing basis:

 

Some 22 statements are made outlining the intended actions for monitoring and reporting.

 

Staff working for the NRM Board consistently denied that the WAP was a legal document and claimed that they regarded the Monitoring requirements as a “wish list”. Any one who took the time to read the NRM Act would know that.

 

We have known all along that the WAP was a legal document and its conditions were to be carried out.

 

This issue was clarified by the Parliamentary Inquiry:

 

Committee Comment:

“The Committee was advised that a water allocation plan is a legal document and required under the NRM Act in any prescribed water resources area. If monitoring provisions in that document are unable to be implemented the State Government must either provide more funding to the Board, require changes to priorities of the applicable agencies, or require that the provisions are modified under the amended WAP. The Committee also noted that water licence holders have responsibilities under the WAP for monitoring and these responsibilities may not have been carried out”.

 

Adequate monitoring has not been done, nor the other strictures in the WAP applied, and the lenses have therefore declined in quantity and/or quality. The record of the Board and staff in relation to water management so far gives them no credibility.

 

8. Why has it taken so long for our water managers to accept and implement a legally binding plan? As this WAP is still in operation, presumably it is being carefully followed now.

 

 

 

 

(2) ULEY-WANILLA CASE STUDY  JOHN HYDE

 

The history of Uley-Wanilla illustrates three things:

 

1. In the past, the various lenses held significantly more water than at present.

 

9. Why is this historical context not shown in the draft WAP?

 

2. The water storage in the lenses of the PWA has been maintained historically because of a range of interconnections some above ground, the rest below ground. All of the more obvious interconnections of the past have long since vanished or occur now very rarely. However, their absence does not mean they are not important in maintaining the lenses. Rather it means, in their absence, the lenses are being depleted and the draft WAP is ensuring that they remain that way.

 

We believe the ability of the Uley South lens to remain the major source of groundwater for the reticulated system, is under serious threat because it is no longer being fully buffered by the other lenses , especially Uley East, and the Big Swamp catchment. Continued over-extraction runs the real risk of depletion beyond recovery and sea-water intrusion.

 

10. Why is the possibility of significant interconnections between the lenses in the PWA, based on historic documents, maps and people’s experience, and the need to reinstate them, being ignored in the draft WAP?

 

3. Finally, the presently proposed level of extraction from Uley Wanilla (186 ML) is way below what could have been maintained in an ecologically sustainable manner if the lens had been managed properly in the first place. [44 years above 500ML/yr; 29 years above 1000M/yr; 17 years above 1500MG/yr; 6 years above 2500ML/yr]

 

11. Why isn’t Uley Wanilla being closed down for a period until its resource capacity has recovered sufficiently to provide a much larger ecologically sustainable supply?

 

By any standard, the first WAP(s) are excellent documents for groundwater management. Being difficult to implement does not mean that water managers can ignore this legal document for their own convenience. Since the NRM Act (2004) the ongoing provision of groundwater can no longer occur at the expense of a deteriorating environment. Even more so if the part of the environment deteriorating the most is the volume of water available for consumption.

 

 

 

(3) The Legislative and Policy Requirements.

 

The conditions governing the extraction of groundwater have been changed over the years in response to experience and new circumstances. This has occurred during the 2000-15 period as much as any other time.

 

The most significant changes relating to EP are:

 

The signing of the National Water Initiative (2004)

The passing of the NRM Act (2004)

The publication of the State’s first NRM Plan (2006)

 

12. Where in the draft WAP have these changes been acknowledged and implemented?

 

 (A) Federal Requirements – National Water Initiative

 

It was signed by Premier Rann on behalf of South Australia.  This document underpins decisions important to South Australia when dealing with issues relating to the River Murray and the EP NRM Business Plan– it should be just as important when dealing with water management on Eyre Peninsula.

 

13. Why is the NWI and its requirements not part of the draft WAP?

 

Returning all systems to environmentally sustainable levels:

 

“The Parties agree to implement this National Water Initiative (NWI) in recognition of the continuing national imperative to increase the productivity and efficiency of Australia’s water use, the need to service rural and urban communities, and to ensure the health of river and groundwater systems by establishing clear pathways to return all systems to environmentally sustainable levels of extraction” (page 1) – emphasis added.

 

South Australia is therefore committed to clearly state, in the new Draft Water Allocation Plan  for EP, how our basins will be returned to environmentally sustainable levels of extraction and what those levels are. This has not been clearly explained and presented to the community. As a result they have not been widely discussed and agreed upon.

 

Returning all over-allocated systems to environmentally sustainable levels of extraction:

 

The NWI continues (page 2): The Parties will make substantial progress towards implementation of this Agreement by 2010”. The Objectives of the NWI also make it clear that the Parties (ie the states and territories and the Federal Government) will: “complete the return of all currently over-allocated or overused systems to environmentally sustainable levels of extraction” (page 4).

 

There is no doubt in the minds of the region’s informed population that our groundwater basins have been “over-allocated” in the past, and must now be returned to a much more “environmentally sustainable levels of extraction”.

 

14. Where in the draft WAP is there mention of a commencement to start some degree of restoration of the depleted lenses?

 

Recognising interconnectivity

 

One other objective of significance in the NWI commits the parties to the: “recognition of the connectivity between surface and groundwater resources and connected systems managed as a single resource” (page 4).

 

Ecologically sustainable management as now understood would never try to manage a water resource by dividing groundwater from its surface water. This is clearly stated in the NWI. It commits the signatories to the: “recognition of the connectivity between surface and groundwater resources and connected systems [to be] managed as a single resource” (paragraph B). This was felt so strongly by the National Water Commission that it recommended connectivity be immediately accepted (15/10/2009) and the onus of proof of connections be reversed.

 

15. Why does the draft WAP actually divide the groundwater of southern EP from its surface water?

 

One of the reasons given for this separation is that the surface water is outside the Prescribed Wells Area (PWA). This is referring in particular to Big Swamp and its catchment. This separation is administratively convenient but is not ecologically based management. More than that, any evidence from EP “proving” that they are no longer interconnected is in fact limited to indicating that they are presently not connected to the extent they used to be.

 

Based on past documents, evidence and people’s experience, a precautionary response would be directed towards increasing storage so that any past interconnectivity could be re-established. This is what the legal requirement for recognizing interconnectivity is seeking to achieve: connecting water both above and below-ground to restore and maintain those connections that must exist. Few bodies of water, above or below ground, are maintained by rainfall alone, especially those that have shown interconnections in the past. Systems that are, or were, interconnected must be managed ecologically, ie as a single resource, otherwise no re-connection is ever going to happen.

 

16. Why do our water managers think they can manage our groundwater lenses without the same degree of management applying to the swamps and catchments that are needed to supply them?

 

Securing environmental water.

 

The NWI also states that water is to be made available for environmental needs within relevant water plans. In addition such water is “to be given statutory recognition and have at least the same degree of security as water access entitlements for consumptive use and be fully accounted for” (page 7).

 

This means that in any proposed change in the balance between the environment, society and the economy, the supply of water for the environment must be as secure as water for consumption.

 

The draft WAP appears to take the view that what water is left for the environment after applying the 60/40 ratio can be extracted later, at any time in the future, to keep supply “sustainable”. Water in storage is not automatically available for use in a management approach that is meant to be ecologically sustainable. After all, why make available more water to sustain consumption if the amount left to maintain the environment ecologically is not enough to do so? .

 

17. How does the draft WAP secure the water for the environment?

 

 (B) State Legislation – Natural Resources Management Act 2004

 

The Objects of the Act provides the shortest and clearest possible insight into the purpose of the NRM Act and therefore the context within which any WAP is to be produced and put into operation.

 

The starting point for any WAP in South Australia is the NRM Act (2004). The over-riding purpose of the WAP is dealt with in Chapter 2 – Objects of Act and general statutory duties, Part 1 – Objects, sections 7 and 8.

 

“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 and management of natural resources management in a manner that –


 

 

a)                recognises and protects the intrinsic values of natural resources; and


 

 

b)                seeks to protect biological diversity and, insofar as is reasonably practicable, to support and encourage the restoration or rehabilitation of ecological systems and processes that have been lost or degraded; and


 

 

c)                 provides for the protection and management of catchments and the sustainable use of land and water resources and insofar as is reasonably  practicable, seeks to enhance and restore or rehabilitate land and water resources that have been degraded; and


 

 

d)                seeks to support sustainable primary and other economic production systems with particular reference to the value of agriculture and mining activities to the economy of the State; and


 

 

e)                (deals with pest species); and


 

 

f)                  promotes educational initiatives and provides support mechanisms to increase the capacity of people to be involved in the management of natural resources.”

 

7 – Objects (1) is then followed by two more statements, (2) and (3), both of which specifically and at length refer to ecologically sustainable development.

 

(2) “For the purposes of subsection (1), ecologically sustainable development comprises the use, conservation, development and enhancement of natural resources in a way, and at a rate, that will enable people and communities to provide for their economic, social and physical well-being while –

 


 

 

a)                sustaining the potential of natural resources to meet the reasonably foreseeable needs of future generations; and


 

 

b)                safeguarding the life-supporting capacities of natural resources; and avoiding, remedying or mitigating any adverse activities on natural resources; and


 

 

c)                 avoiding, remedying or mitigating any adverse effects of activities on natural resources.

 

(3) “The following principles should be taken into account in connection with achieving ecologically sustainable development for the purposes of this Act:

 


 

 

a)                decision-making processes should effectively integrate both long term and short term economic, environmental, social and equity considerations;


 

 

b)                if there are threats of serious or irreversible damage to natural resources, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation;


 

 

c)                 decision-making processes should be guided by the need to evaluate carefully the risks of any situation or proposal that may adversely affect the environment and to avoid, wherever practicable, causing any serious or irreversible damage to the environment;


 

 

d)                 the present generation should ensure that the health, diversity and productivity of the natural environment is maintained or enhanced for the benefit of future generations;


 

 

e)                a consideration should be the conservation of biological diversity and ecological integrity;


 

 

f)                  environmental factors should be taken into account when valuing or assessing assets or services, costs associated with protecting or restoring the natural environment should be allocated or shared equitably and in a manner that encourages the responsible use of natural resources, and people who obtain benefits from the natural environment, or who adversely affect or consume natural resources, should bear an appropriate share of the costs that flow from their activities;


 

 

g)                 if the management of natural resources requires the taking of remedial action, the first step should, insofar as is reasonably practicable and appropriate, be to encourage those responsible to take such action before resorting to more formal processes and procedures;


 

 

h)                consideration should be given to Aboriginal heritage, and to the interests of the traditional owners of any land or other natural resources;


 

 

i)                  consideration should be given to other heritage issues, and to the interests of the community in relation to conserving heritage items and places;


 

 

j)                  the involvement of the public in providing information and contributing to processes that improve decision-making should be encouraged;


 

 

k)                the responsibility to achieve ecologically sustainable development should be seen as a shared responsibility between the public sector, the private sector, and the community more generally;


 

 

l)                  the local government sector is to be recognized as a key participant in natural resources management, especially on account of its close connections to the community and its role in regional and local planning.”

 

18. Where does the draft WAP explain the meaning of the term “ecologically sustainable development” and commit to it – the over-riding intent of the Act? There is nothing ecologically sustainable about continuing to deplete groundwater lenses.

 

In general, the Objects seek to enshrine more than the use of natural resources, and sets out to include their protection, restoration, and management in a holistic way. This perspective is to be the ‘lens’ through which their future management is to be conducted.

 

19. Why is the draft WAP not showing how it is responding to “protecting, restoration, and management in a holistic way”?


 

 

 

 (C) The State Natural Resources Management Plan 2006

 

Although not part of the legislative requirements, this document is a requirement of the NRM Act and therefore sets out to “explain” it. People concerned about water management on EP should be able to assess the draft WAP according to its conformity with this State Plan. If nothing else it is an easy to read and be understand by many people. It contains a series of Guiding Principles (page 5) that the regional WAP needs to exemplify both in content, and the processes by which it is developed and finally approved.

 

The first five Guiding Principles are as follows:

           

Our natural resources must be managed for long term social, economic and environmental outcomes by landscape improvements to the ecosystems which we depend upon.


 

 

1.                  Win, win, winEcologically sustainable development of natural resources underpins a sound economy while delivering positive social and environmental outcomes.


 

 

2.                  Work within limits – The use of our natural resources in response to social and economic pressures must work within ecologically sustainable limits to maintain their life-supporting capacity.


 

 

3.                  Look after the future – Ecologically sustainable development of natural resources will protect their capacity to provide ecosystem services upon which the well-being of future as well as current generations depends.


 

 

4.                  Use without losing – Natural resources management must embrace the fundamental interdependence of economic productivity and ecologically sustainable use.


 

 

5.                  The whole is greater than the sum of the parts – Natural resources management will be most effective when using an ecosystem approach that recognizes and integrates all the components and processes of ecosystems and their use; and manages these at the appropriate temporal and spatial scales.

 

This section of the Plan emphasizes yet again the need for any development of water resources to be ecologically sustainable. It specifically identifies that management is to occur within ecological limits, and requires an ecosystem approach.

 

20. Where in the draft WAP is there any reference to ecological limits and the need to maintain ecological services on EP?

 

(4) The Consultative Process for the Draft WAP

 

My Experience of Consultation with the NRM Board         Ken Meyers.

 

Here is a list of events experienced by members of EPWAG and others when it came to Consultation about the draft WAP

 

 (1) Two Community Consultative Committees were established in 2010 to assist in the preparation of the draft WAP (at that time, one committee for Uley South and one for Musgrave). In each case members experienced the following:

(a) Being brushed aside when discussing matters in the meeting,

(b) Items being left off the Agenda,

(c) Items promised to be put back on the Agenda being consistently omitted,

(d) Questioning of experts from Adelaide was always cut short,

(e) In many cases their digital notes were not made available for ongoing discussion,

(f) Being placed under unrealistic timetables and time constraints,

(g) Summarily dismissed (20/4/12) for reasons that were never presented at a meeting thereby allowing for discussion (and apologies if necessary) to allow the process to continue,

 (h) Submitting written comments and passing them on to the chairperson, but no follow up discussion between the contributor and the Board (or staff),

(i) Never given the chance in the meetings to discuss with each other what they had written,

(j) Both sets of meetings were initially chaired by an NRM staff member and then a member of the WRAC but meetings were not conducted impartially.

 

Other Issues with the Consultation Process

 

(1) The Parliamentary Inquiry recommended the appointment of a facilitator to be present at further meetings between the Board and the community. This was an excellent move and initially seemed to be working well. As community consultation continued on the draft WAP however, it became obvious in later sessions that the facilitator was not acting impartially, but was very much being held to account by the NRM Board. Time and again community-based discussion was cut short, with promises of ongoing discussions to be continued ‘later’ that never eventuated.

 

 (2) The final meeting, the “Feedback Session”, was a typical exercise in which the specially invited audience was subject to a “shut –up and listen to us” session by the Board and staff. This was so demeaning to the gathered expertise that they got up and left without bothering to make comment – because they knew no-one would listen let alone record their responses. This is was the final straw that prompted our move to meet with the Minister.

 

(3) The Consultation process also brought to light an unusual anomaly. We are told that some 70-80 changes have been made to the draft WAP as presented to the community for comment. THE COMMUNITY HAS NO IDEA WHAT THEY ARE! We have yet to see (let alone respond to) the revised draft WAP that has been changed following consultation.

 

We agree with you Minister when you said in Parliament: (22/7/2015)

`”The new WAP will include a comprehensive monitoring, evaluation, reporting and improvement (MERI) framework to ensure that the new WAP is achieving its set objectives”.

Yet in the final “feedback session” it was stated by the EP Manager:

The MERI Plan will be separate to the WAP”. This is indicative of the many problems we have had in communicating with the Board.

 

We are firmly of the view that the MERI Plan must be in the WAP so that its requirements are legally binding. The Board’s decision in this matter has not been discussed with the

community.

 

21. Has the Board discussed this issue at length with you following your statement in Parliament? Why does the EP draft WAP not include the monitoring as has been done in other WAPs?

 

The Board fails to realize that the most important resource, even more than water, is community participation in natural resource management. Verbal comments, written submissions, historic documents and the building of cordial relations are ALL priceless when it comes to involving the community and making them feel that their views are important and valued. The NWI (in Schedule E which sets out the Guidelines for Water Plans and Planning Processes) states that for community consultation: adequate opportunity for consumptive use, environmental, cultural, and other public benefit issues to be identified and considered in an open and transparent way” must occur (page 36) – emphasis added. None of the most dedicated stakeholders believe that this describes what happened on EP. The State NRM Plan urges genuine community involvement, declaring that “people are the key” – capable, connected and committed people are critical to effective natural resources management (p4,5).

 

22. Why does this not happen with the Board on EP? It seems to always be restraining contributions from the community.

 

Any future consultation process can follow the same steps as required by the legislation but they must be handled quite differently if a more appropriate outcome is to be achieved.

 

 

 

 

 

(5) The draft WAP presents us with two other major concerns.

 

1.The use of the environment/consumption ratio.

 

The foundation for water allocation presently being used on EP, the 60/40 ratio of environment/consumption, has never been questioned or verified. This is actually a failure to safeguard the life-supporting capacities of natural resources; and avoiding, remedying or mitigating any adverse activities on natural resources (paragraph E b))

 

The draft WAP uses the 60/40 environment/consumption ratio for determining the amount of water available for consumption. At no stage during the last 15 years has this ratio been called into question and compared with what is actually happening in the lenses. One possible reason for the many aquifers being overdrawn is that the ratio underestimates the amount of water needed to maintain storage volumes. The draft WAP not only continues to use this ratio but intends to change it in relation to Uley North and most notably in relation to the Uley South lens.

 

The proposed new ratio of environment/consumption for Uley South is to be set at 48.5/51.5. This was only changed following the vigorous opposition of local stakeholders to the proposed change in the draft WAP to 30/70! It was originally proposed to change it to 30/70 which would have effectively doubled the amount of water that could be extracted from this lens. Refusal to assess the validity of the ratio against real changes in water storage shows that our water managers are not committed to achieving ecologically sustainable use in order to ensure ongoing economic productivity. (paragraph G 4).

 

The real problem with the use of the ratio in the draft WAP is that its use is repeating the problem that is in the first WAP (2000). It is being applied untested to the resource capacity without regard to the state of the lens at the end of each water year.

 

23. Where in the draft WAP is the ratio actually compared with the storage levels in the lenses over the years 2000 – 2015?

 

2. Accessing more water in other parts of the PWA.

 

Let us return to Question 15: How does the draft WAP secure the water for the environment? INTRODUCING TIPPING POINTS DO NOT DO THIS! Saving water for the environment is by-passed by the tipping points as the draft WAP intends to access even more water from more lenses.

 

This is to be done without making any research as to where that water comes from, how long it has been there, how it is kept topped up, or what ecosystems or ecosystem services presently depend on them. This is not a management approach that remotely resembles ecological sustainability. It is plunder first and ask questions later. The problem of some lenses becoming depleted is not solved by opening up more sources of groundwater. Considering the state of the lenses given earlier, EP must face up to the fact whatever water remains in the Prescribed Wells Area needs to be protected for the environment AND the ongoing supply of water for consumption! If EP has to extract even more water from the PWA then it will soon have to get water from other sources before increasing extraction compromises what we can get now.

 

 

24. Why is the draft WAP proposing to access additional sources of lower quality groundwater? Nowhere in the WAP does it concede that water for the reticulated system and the regional community might soon have to come from sources other than groundwater?

 

 

 

 

(6) Finally:

 

At the heart of being ecologically sustainable is how we manage that resource. At present we are treating EP’s groundwater as a non-renewable resource – extract and move on! We live there are there is no moving on. We must manage better what we have. The draft WAP as it is at present does not do that.

 

If you were to send the revised draft WAP back to the Board to be rewritten, we believe a much better draft WAP can be produced in accord with legislation and policy, given the chance for meaningful collaboration between all parties represented here today.

 

 

 

 

 

 

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