Submission by EPWAG
It is the view of the EP Water Action Group that the Draft WAP needs to be reworked and then presented again to the community of EP. This is based on all the following reasons that collectively make up our submission to the EP NRM Board.
- The Draft WAP was presented in two separate documents, the Draft WAP and the MERI Plan. These need to be incorporated into one document that can be read as a continuous, comprehensive and integrated Plan.
- The completed single document must be reworked so as to be readable and comprehended by most people without extra explanations being necessary. Alternatively, a separate new document produced of shorter length be produced that can be read by all, with specific references to the various sections of the reworked, larger, single WAP.
- The reworked single WAP must include specific reference to the National Water Initiative (NWI) acknowledging that the WAP:
- ——–intends to “complete the return of all currently overallocated or overused systems to environmentally sustainable levels of extraction” (page 4);
- ——recognizes the “the connectivity between surface and groundwater resources and connected systems managed as a single resource” (page 4);
- —— requires that water is to be made available for environmental needs within relevant water plans, and 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); and
- —— any impact on water availability resulting from climate change will be carried by the licensees (page 8, section 48).
- The text of the reworked should acknowledge the NRM Act by referring consistently to “ecological sustainability” and not just ‘sustainability’. The term sustainability already has too many definitions attached to it, and in this context it is proper to refer to “ecological sustainability”.
- The new WAP needs to acknowledge that the Native Vegetation Act requires water extraction activities not to interfere with native vegetation.
- If the reworked WAP is to have any community credibility, it will need to acknowledge that Polda Basin has been, or will shortly be, taken off line and no longer available for the reticulated supply system.
- The reworked WAP should contain an Introduction the WAP that places it in context, especially the period from 2000 to the present, during which the present WAP has been operating. This should refer to changes in basin levels and the change in condition of various GDEs.
- In the section dealing with GDEs, there needs to be a diagram with native vegetation growing on a relatively flat surface accompanied by three different water levels: one just above the surface showing the vegetation in a ‘swamp’ situation; the second level below the surface but still within reach of the roots of the native vegetation; and the third level below the reach of the roots. This should be used to explain the actual and possible effects of over-extraction on these types of GDEs.
Various parts of the present Draft WAP need to be expanded to explain what they mean including:
- the designation of the consumptive pools into fresh and ‘brackish’ and how that was done;
- the location of the tipping points in relation to the 1993 (sustainable) reference level, the present water storage level, and the historic water level ie the best estimate of the water level at the time extraction for the public supply commenced;
- what the 129mm recharge for Uley South means in terms of changes in water levels, and how this level was selected compared with the average recharge rates for Uley South of 47-129mm/yr.
- The section dealing with the proposed change of the environment/consumptive ratio from its present 60/40 level be deleted. Until there is scientific information to the contrary, the ratio to remain at 60/40 for the Uley South basin.
- A pipeline was recently constructed from Coffin Bay to Uley Wanilla basin costing approx. $4 million. Its purpose, impact on potable supply and constraints imposed on its use needs to be presented.
- Details as to how the groundwater dependent ecosystems (GDEs) will be selected and monitored to be included, along with identifying who will be responsible for it being done.
- At some point one or two graphs showing the relation between “effective rainfall and changes in water level”, especially in the period 2000-2014 need to be included in the reworked WAP.
- The new WAP will need to contain details as to all the minimum number of bores that will be monitored during its lives, along with their listing, location on a map, frequency of monitoring and data to be collected. It will be necessary for the selected bores to cover the whole of the basins, including those that held water in the past for it to be regarded as being appropriately comprehensive. Responsibility for this being done will need to be identified in the WAP.
- The present Draft WAP contains references to mining. A separate section should be written discussing present controls on mining, how much potable water has been made available for mining exploration, details as to where the water is coming from for the graphite mine near Sleaford, and some indication of the limits that should be placed on mining in a Prescribed Wells Area.
The inclusion of these deficiencies and their implications into the present Draft WAP will have the effect of creating a vastly different (single) document. “This necessitates a second round of community consultation based on the reworked WAP so that proper, comprehensible and wide community comment can be made to ensure the ecologically sustainable management of our groundwater systems”.
D. John Hunwick
D. John Hunwick
Secretary of EP Water Action Group.