draft eastern mount lofty ranges water allocation plan public

South Australian Murray-Darling Basin Regional Management Board

DRAFT EASTERN MOUNT LOFTY RANGES

WATER ALLOCATION PLAN

PUBLIC MEETING

QUESTIONS COMMENTS AND RESPONSES

AUGUST 2011

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Questions, comments and responses from the public consultation meetings for the draft Eastern Mount Lofty Ranges water allocation plan This document outlines questions and comments made at the public meetings on the draft water allocation plan and licensing process for the Eastern Mount Lofty Ranges. The responses have been supplemented with information gathered since the meetings as appropriate. Responses will continue to be developed as the South Australian Murray-Darling Basin Natural Resources Management Board (SAMDB NRM Board) and the Department for Water work through responses received during the consultation process. Questions and comments have been grouped by topic, and in some cases similar questions have been grouped with a single answer. The meeting location and date that a question or comment was made is shown in italics.

Table of contents Prescription........................................................................................................... 2

Water availability and limits ................................................................................. 8

Surface water and watercourses ........................................................................ 11

Dam construction and works .............................................................................. 14

Roof runoff ......................................................................................................... 18

Groundwater ...................................................................................................... 18

Environment ....................................................................................................... 20

Transfer............................................................................................................... 21

Rollover ............................................................................................................... 25

Other policy areas in the draft plan .................................................................... 26

General water affecting activities ....................................................................... 27

Monitoring .......................................................................................................... 27

Returning low flows ............................................................................................ 28

Dam size .............................................................................................................. 38

Licensed and non-licensed purposes .................................................................. 40

General allocation issues..................................................................................... 41

Existing user allocations ...................................................................................... 42

Metering .............................................................................................................. 47

Costs .................................................................................................................... 49

Consultation process ........................................................................................... 54

Water issues outside scope of Eastern Mount Lofty Ranges prescription .......... 56

Other NRM issues................................................................................................ 58

Acronyms and abbreviations AMLR Adelaide and Mount Lofty Ranges ML Megalitre (1,00,000 litres) EMLR Eastern Mount Lofty Ranges NRM Natural resources management GL Gigalitre (1,000,000,000 litres) NRM Act Natural Resources Management Act 2004 ha Hectare SAMDB South Australian Murray-Darling Basin kL Kilolitre (1,000 litres) WAP Water allocation plan

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Question or comment Response

Prescription

1. Who owns the rain? (Mt Compass - 23 May, Langhorne Creek - 25 May)

2. Whose water is it? People will be charged to use their own water. (Mt Compass - 30 May)

No-one owns the rain.

However, the community, through the government, regulates the right of people to take prescribed water resources for the benefit of all water users. This is because water is a valuable resource that must be managed sustainably. The Natural Resources Management Act 2004 (the NRM Act) provides for the management of the State’s water resources for the benefit of the community and environment. The water allocation plan and licensing process sets out how that communal resource is to be shared between users, including the environment.

3. I can see where the NRM Board is coming from, but care needs to be taken to protect the landowner of his / her rights to farm. (Mt Barker - 31 May)

4. I think the concept of the plan is aimed at restricting the irrigators from doing their job of producing food of all kinds. (Mt Barker - 31 May)

5. What happens to irrigators growing food in the long term? (Strathalbyn - 26 May)

6. On watching the TV news of an unknown food poisoning in overseas vegetables and with water difficulties being forced on our food producers, there may be no alternative but to import this inferior food to eat. Have a good think about it. (Mt Barker - 31 May)

The prescription process is intended to protect the water resources for all users in the long term, including irrigators, stock and domestic users and the environment. It will help to protect the investment of water-using businesses from the impacts of unregulated water taking.

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7. There has to be an environmental economic impact statement done for what it will do to food producers. (Mt Barker - 31 May)

8. An economic impact statement needs to be done. (Mt Compass - 30 May)

9. Has an economic assessment been made to see what the effect is going to be on farmers? (Strathalbyn - 26 May)

10. What are the details of the economic impact on farmers and landowners? (Strathalbyn - 26 May) Note: information on costs is given in the “Costs” section

The SAMDB NRM Board has considered and balanced social, economic and environmental factors when developing the draft Eastern Mount Lofty Ranges water allocation plan (EMLR WAP). Consultation with the community advisory committees during the development of the draft plan provided a good indicator of likely economic issues at the local scale. The committee members either reside in the area or own property in the area. This means that as each policy was debated, the debate was conducted by people who had a direct economic and social interest in the outcome.

The prescription process aims to keep water use within sustainable limits, and many of the policies in the draft plan are aimed at protecting current users and the environment from the impact of new water taking and use in their area. This means we should have a healthy, working resource to support users and the environment into the future, and better security and protection from unregulated water taking for existing water users.

Existing users are expected to receive an allocation that meets their reasonable requirements in the majority of management zones.

There was an economic assessment of the effect of prescribing the water resources of the Eastern Mount Lofty Ranges done in 2004 as part of the investigations undertaken to help decide whether to prescribe the region. The results of this assessment were that prescription would have a positive effect in the longer term. The full report is available on the Board’s website at: http://www.samdbnrm.sa.gov.au/Portals/9/PDF's/Water/EMLR%20Prescription_Final%20 Report.pdf

In addition there was a formal regulatory impact assessment in 2005 prior to the decision to prescribe the water resources. This assessment included an assessment on the impacts on businesses. It stated in part that:

“the alternative of not introducing the regulation may have long-term negative impacts. There is limited ability to prevent extraction by one water user impacting negatively on another, or to protect the resource from long-term over-exploitation. In the long-term this would be unsustainable and detrimental to businesses that have made investments but can no longer support their business due to the lack of water.”

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11. Why do we need it, as it will not add to the environmental flows. The science is flawed. (Mt Compass - 23 May)

12. The database, facts and science is flawed. All the information is wrong and will affect social and economic outcomes. It does not represent the best available science and application. (Mt Compass - 30 May)

13. We need the scientific proof. We need to be careful about what scientists we listen to and who is paying them. (Langhorne Creek - 25 May)

14. Where is the scientific evidence? (Mt Barker - 31 May)

15. Show us the science to prove the decline in water resources. (Mt Compass - 23 May)

16. The science is wrong and hasn’t been thought through well. It needs to be done on an individual basis not on the catchment. (Mt Compass - 23 May)

17. Where is the scientific proof? When will you provide it at one of these meetings? (Mt Pleasant - 24 May)

18. Where is the science? We would like exact figures. (Strathalbyn - 26 May)

The SAMDB NRM Board believes that the data used in developing the draft EMLR WAP is sound, and is interested to receive any specific concerns with the science or evidence of flaws.

Monitoring data, modelling and analysis shows existing long-term declines in water resources and the environment, such as decreasing groundwater levels and increasing salinity in some areas, decreasing flow and declining native fish populations.

The Board and the Department for Water have used the available reliable data that has been collected to appropriate standards in relation to water resource supply and ecosystem condition (such as rainfall, flow, groundwater level and salinity, and fish and macroinvertebrate condition).

Analysis and modelling of that data is described in peer-reviewed, published technical reports. These reports describe the data and modelling used (including assumptions) and the outcomes of the analysis.

The reports outlining these impacts and resource assessment are available from the Board and Department for Water (e.g. on our websites at www.samdbnrm.sa.gov.au, and www.waterconnect.sa.gov.au). These reports were made available at the public meetings, and technical staff were available at the public meetings to discuss the work and answer questions.

The draft EMLR WAP itself also provides an overview of key components of the science underpinning the plan, and sets out the proposed figures for sustainable limits and water-taking rules. The draft EMLR WAP is available from the Board's website, at Board offices or on request (tel. (08) 8532 9100).

The proposed limits and water taking rules that underpin the draft EMLR WAP and the existing user allocation process have been set to meet environmental objectives while considering social and economic needs for water.

It is also important to note that prescription is not only about addressing existing impacts and declining water resources. Prescription also provides a management framework to ensure long-term sustainability and to protect current users, including the environment, from the impacts of unregulated future water resource development.

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19. I have heard many facts and figures. Hopefully they are realistic and not just conclusions that have arisen. Who actually looks at the practical issues where the rubber hits the road? I’m not sure I’ve heard about this tonight. (Mt Pleasant - 24 May)

The SAMDB NRM Board believes the figures in the draft plan are realistic, and are underpinned by the available reliable data.

The draft EMLR WAP has been developed in close consultation with community advisory committees made up of local water-users representing a range of areas and industries. The committee members have provided great feedback on the practicalities of different options. The current consultation on the draft plan provides another chance for water users to give feedback on the practicality of the policies.

In addition, water allocation plans are reviewed at least every five years, giving the opportunity for assessment of whether the policies in the plan have been effective and practical.

There is more work to do on developing an implementation program for the proposal to return low flows. Part of this program will involve working with landholders to identify and address practical issues around how low flows can best be returned to the environment.

20. Instead of having the recommendations on a five year trial period (which could well be an absolute failure), it would be better to place a five year freeze on development to check the results of any situations. This is to avoid any big expenses to property owners which could be proven to be not warranted. (Mt Barker - 31 May)

21. What has happened to all of the information on the permits that we already have? Why hasn’t that worked? You don’t think that we have been managing it ourselves? (Mt Pleasant - 24 May)

The current system of authorisations provides a temporary freeze on further water use development (for purposes such as irrigation), while longer-term measures are developed in the form of the water allocation plan and licensing. This moratorium (Notice of Prohibition) was placed in October 2003. The condition of water resources and the environment has continued to be negatively affected since then. The water allocation plan and licensing process provide a long-term management approach which will allow businesses to continue within sustainable limits.

22. In the high rainfall areas of the Eastern Mount Lofty Ranges, which is the top 1% of the wettest part of the state, there are now less dairy farmers, less potato growers and more hobby farmers who don’t irrigate. Why is it necessary for the Mount Compass, Yundi area etc to be proclaimed as all? As it is, this area is under only 1% land mass under irrigation. (Mt Compass - 23 May)

Prescription provides a mechanism for current users to be protected from the impact of future unregulated water resource development, and to have better security of access to water. Experience in other areas has been that, when a water resource is prescribed, then new development may shift to neighbouring unregulated areas and can lead to overdevelopment and water-sharing issues there.

Analysis of monitoring data has shown that environmental impacts are occurring in the high rainfall areas of the Eastern Mount Lofty Ranges, particularly during drier years, and in downstream areas that depend on flow from the wetter areas.

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23. This is all directed at farmers. Why hasn’t the implication of population growth been looked at as impact on water resources? (Mt Barker - 31 May)

24. Look at the impact of 30,000 – 50,000 new population on water resources as well as the people on whom they rely for food supply. (Mt Barker - 31 May)

25. Have you looked at the proximity of the intense growing population? (Mt Barker - 31 May)

26. When it comes to water allocation – major residential and housing development seems exempt from principles relating to water allocation. Yet rural activity can be put through excessive rules, principles and regulations. Why? The facts are I need fresh fruits and vegetables to stay alive. I don’t need more and more bricks and cement. Do something about this double standard! (Mt Barker - 31 May)

Water used for domestic purposes has been excluded from the prescription process in the Eastern Mount Lofty Ranges, following community consultation on the issue when prescription was first proposed for the region in 2003.

The volume of current domestic use from the prescribed water resources in the Eastern Mount Lofty Ranges (surface water, watercourses and groundwater) has been estimated and included in the water balance calculations, but future domestic demand has not.

Any new dams and bores require a water affecting activity permit, including those used for domestic purposes. The draft plan includes policies aimed at minimising the impact of these new structures on current users and the environment. These policies include dam capacity limits at a range of scales (property scale to catchment scale) and well buffer zones.

The draft plan includes policies on allocation of the additional runoff generated by the increase in impervious areas created by new urban development.

27. As a matter of equity, do these restrictions apply to SA Water use (such as the TWS in Mt Compass), which appears to allow for development expansions, while surrounding food producers are restricted and being potentially impacted upon by SA Water use? (Mt Compass - 30 May)

28. How can SA Water increase use, while everyone else is restricted? (Mt Compass - 30 May)

The NRM Act applies to SA Water. When the EMLR WAP is adopted, it will also apply to any SA Water activities in the region.

SA Water is subject to the same rules as everyone else. If they wish to use water that is covered by the Eastern Mount Lofty Ranges prescription as an existing user, they need to demonstrate that use was either existing during the relevant period, or they had made a significant legal or financial commitment to that use prior to October 2003.

If there is a possibility that reductions in water use may be required in a particular management zone, there is consultation with the water users and community in the area. In some cases in the past, the community has supported not reducing allocations for some uses, such as critical human needs or irrigation of sports grounds.

29. How does this licensing process integrate with the Murray-Darling Basin Plan? (Mt Compass - 30 May)

The Basin Plan will set sustainable diversion limits and a range of other requirements that will be implemented via the state mechanisms such as the water allocation plans and existing South Australian licensing system.

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30. I put an application in for a dam two years ago for stock and domestic use and the answer was no. But they said I can get a meter to take water from the Murray. They didn’t give me a reason for saying no to my dam. It is just a money grab. (Mt Pleasant - 24 May)

The prescription process is about long-term, sustainable water resource management. This means that new water capture may be prevented in areas that are already fully developed, to protect the ability of current users and the environment to access enough water.

31. This is unconstitutional. (Mt Barker - 31 May) The draft water allocation plan and licensing process are carried out in accordance with the state NRM Act. We are not aware of any challenges to the validity of this legislation.

32. Why do you think that people will take notice of this plan? (Mt Pleasant - 24 May)

Water allocation plans (or similar) are in place across the state and country as a key tool in managing water resources. Once adopted, the EMLR WAP will be a statutory plan that governs water taking and use for licensed purposes in the region, together with the NRM Act.

33. I have not heard of the Department for Water until tonight. (Mt Pleasant - 24 May)

The Department for Water was previously part of the Department for Water, Land and Biodiversity Conservation. The Department for Water was formed in July 2010.

34. I bought a property in an area that has 15 dams. I have now been told that no new dams are allowed to be built in that area. There was no encumbrance on my Form 1 that said that I couldn’t build a new dam. This should be on the Form 1. (Mt Compass - 23 May)

35. I have not had any positive feedback about this plan. (Strathalbyn - 26 May)

36. I receive phone calls from women worried about their husbands committing suicide because of this lunacy. (Mt Compass - 23 May)

37. I want my faith restored in bureaucracy. Our livelihoods are going. We won’t have anything left. I’m very upset. (Mt Compass - 23 May)

38. The WAP needs to be completely overhauled and the NRM Act burnt. (Mt Compass - 23 May)

39. Feasibility study at the moment being conducted for me not to grow food anymore (on my 300 acres). Leave the land idle. Work with 20 Chinese farmers in Chyngu Province who water and fertilise with human waste. Import and sell as a wholesaler or retailer. Make more money. Less headaches. But I don’t think South Australia would rather me do this would they! Help us NRM, don’t be against us. At the moment it’s not good. (Mt Barker - 31 May)

40. Look after our farmers (food producers). I don’t want to eat overseas [food]. (Mt Barker - 31 May)

41. I am frustrated with the complexity of all of this. (Langhorne Creek - 25 May)

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Water availability and limits

42. You need to make policies based on long term averages. (Langhorne Creek - 25 May)

43. How did you go about measuring the long term average? (Mt Barker - 31 May)

44. There are 27 groundwater management zones and each zone is assigned a consumptive use limit. You said that the long term average was used to reach the consumptive limit. How long is that long term? (Mt Barker - 31 May)

45. When were these reports done? There have been suggestions that the demand maps is based on data collected during the drought period and is not representative of actual conditions and therefore need another 10 years of monitoring (assuming average rainfall over this period). (Mt Compass - 30 May)

46. We need dates for the science. What are the dates? (Mt Pleasant - 24 May)

Proposals in the draft EMLR WAP are based on analysis of long-term behaviour of the water resources.

For example, groundwater replenishment or recharge has been estimated using a number of chemical techniques that determine long-term average recharge rates over a period of approximately 30-40 years. Groundwater monitoring data (level and salinity) has been collected from a range of sites over the Eastern Mount Lofty Ranges. The period of data varies between sites, within the period of 1969 to present.

The surface water modelling has been done for the period of 1971-2006, underpinned by rainfall data and flow monitoring data collected over that period from stations throughout the Eastern Mount Lofty Ranges (period of flow data varies between flow gauging stations, within the period of 1969 to present).

The methodology for determining the capacity of the water resources is summarised in the draft EMLR WAP (section 1.4) and technical reports which are available on the websites of the SAMDB NRM Board and the Department for Water (www.samdbnrm.sa.gov.au and www.waterconnect.sa.gov.au), or on request (telephone the Board on (08) 8532 9100).

Another important element of the draft plan is monitoring and evaluation of water resources, water use and the environment, with an adaptive management approach to allow responses to changing conditions if necessary.

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47. How have you worked out what water is the amount of water available? (Strathalbyn - 26 May)

48. How are you working out how much water we are allowed to have? (Mt Compass - 30 May)

The long-term average annual volume of runoff was determined using a combination of measured flow data and surface water modelling based on that flow data and rainfall data. The amount of that runoff available for taking within sustainable limits was determined by setting environmental targets (based on environmental needs balanced against social and economic needs), and then using the surface water models to determine what combination of water taking limits and rules would achieve those targets, when modelled over 1974-2006.

The long-term average annual volume of recharge to groundwater was determined using a range of chemical techniques, taking measurements in the different types of groundwater systems in the Eastern Mount Lofty Ranges. The amount of that recharge available for taking within sustainable limits was determined by subtracting the volume of throughflow (water moving between groundwater systems) and the volume of baseflow (water moving from groundwater into creeks) from the total recharge.

The methodologies for determining the consumptive use limits are outlined in the draft EMLR WAP (sections 2 and 4.2).

49. What are the percentages of water available? (Mt Compass - 30 May)

The proposed maximum consumptive use limit for surface water + watercourses is 29% of long-term average annual adjusted runoff, when calculated at the scale of the whole Eastern Mount Lofty Ranges (where adjusted means adjusted to account for the impact of dams, watercourse diversions, forestry and some urban areas on flow). This includes a base limit of 15%, as well as additional water available for watercourse diversions.

The proposed maximum consumptive use limit for groundwater is 56% of long-term average annual recharge, when calculated at the scale of the whole Eastern Mount Lofty Ranges.

50. According to the pie chart that you showed us, 50% of the water is being allocated to the system and environment. Where did that percentage come from? (Mt Pleasant - 24 May)

The pie chart in that presentation was only intended to illustrate the concept that the total water available has been divided into a number of components, being system and environment, licensed use and non-licensed use. It was not intended to show the actual split between those components.

The consumptive use limits as a percentage of total available water, and an outline of the process used to determine the limits and total available water, are given above.

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51. Does the community have access to monitoring reports to support the consumptive use limits and high demand zones? (Mt Compass - 30 May)

Technical reports underpinning the draft EMLR WAP and the existing user allocation process are available on the websites of the SAMDB NRM Board and the Department for Water (www.samdbnrm.sa.gov.au and www.waterconnect.sa.gov.au), or on request (telephone the Board on (08) 8532 9100).

There are some management zones of ‘high demand’ where the combined reasonable requirements of existing users exceed the capacity of the resource. In these zones, the Minister may not allocate these users their full reasonable requirements.

Currently no reports are available specific to ‘high demand zones’ however the Department for Water will be working with users in high demand zones to balance reasonable requirements with consumptive use limits.

52. Some scientists are saying that we should catch all of the water for drought periods. You need to consider the whole process. (Mt Barker - 31 May)

It is difficult to respond to that comment without more detail on why all the water should be caught for drought periods. The current level of water capture and extraction is leading to problems in some areas in terms of water quality declines, inadequate sharing of water between users, and environmental degradation. Capturing more water will exacerbate these problems.

53. All planning has to be set on reports and data. Out of the reports that you showed us that are available on your website, the latest was from 2007. There have been significant changes in this area since 2007. Previously the most saline water was the first flows, and that has now changed. The first flows are now the best and the later flows are more saline. You need to guarantee that we have new data to review in the next five years. Can we have a guarantee that during this five year period we will have new data and reports? (Langhorne Creek - 25 May)

The latest report is from 2010.

The SAMDB NRM Board agrees that it is very important to continue to collect data to assess the responses of the water resources, environment and water users, and to assess the effectiveness of policies in the water allocation plan. The draft EMLR WAP includes a monitoring chapter that sets out the minimum monitoring requirements, including roles and responsibilities. Data will continue to be collected which will inform future reviews of the plan.

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Surface water and watercourses

54. What is the definition of surface water? How do you ascertain what it is? (Langhorne Creek - 25 May)

Surface water is generally water on the land surface, unless it is in a watercourse (in which case it is watercourse water). Surface water is commonly captured in dams. Surface water and watercourse water are very closely linked, and the draft EMLR WAP generally treats them as a single resource.

The definition of surface water from the NRM Act is given below:

(a) water flowing over land (except in a watercourse)—

(i) after having fallen as rain or hail or having precipitated in any other manner; or

(ii) after rising to the surface naturally from underground;

(b) water of the kind referred to in paragraph (a) that has been collected in a dam or reservoir;

(c) water of the kind referred to in paragraph (a) that is contained in any stormwater infrastructure.

Note that the NRM Act defines a watercourse as a river, creek or other natural watercourse (whether modified or not) in which water is contained or flows whether permanently or from time to time and includes—

(a) a dam or reservoir that collects water flowing in a watercourse;

(b) a lake through which water flows;

(c) a channel (but not a channel declared by regulation to be excluded from the ambit of this definition) into which the water of a watercourse has been diverted;

(d) part of a watercourse;

(e) an estuary through which water flows;

(f) any other natural resource, or class of natural resource, designated as a watercourse for the purposes of this Act by an NRM plan.

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55. When you talk about the surface water limit being 15%, is that for the whole Eastern Mount Lofty Ranges? It seems very low. (Mt Compass - 30 May)

56. What do you mean when you say 15% runoff? Is that all we are allowed to catch? (Mt Pleasant - 24 May)

The 15% consumptive use limit for surface water + watercourses sets the limit to the total volume of water that can be taken at the catchment scale (e.g. Tookayerta or Bremer catchment), and also at the management zone scale (where surface water management zones are shown in the draft EMLR WAP on page 90-91) – that will achieve the areas environmental targets. This limit does not apply at the property scale. The draft EMLR WAP also proposes that additional water is available for watercourse diversions in some circumstances.

Analysis of current information on demand compared with the consumptive use limit shows that this limit is sufficient to meet the reasonable requirements of existing users in 172 out of the 194 surface water management zones.

57. How does it affect me as an Angas/Bremer river diverter? (Langhorne Creek - 25 May)

The proposal to provide for low flows means that river diverters will not be able to extract water from the river when the flow rate is at or below the threshold flow rate, and that taking water must not cause the flow rate to drop below the threshold flow rate.

There is also an additional amount of water available for allocation to existing users in the lower Angas and Bremer Rivers that can only be taken under additional water-taking rules. These additional rules are that water can only be taken in a flow event once flow has reached a nominated first flush flow rate at the Ballandown Road flow gauging station for at least 24 hours, and that in-stream weirs (that block the watercourse) can only be operated for a cumulative total of 48 hours within a flow event.

58. What are low flows? (Langhorne Creek - 25 May) Low flows are flows at or below the threshold flow rate. Low flows make up around 10-15% of the total flow over the long term. In the lower Angas River, the threshold flow rate is 0.2 cubic metres/second, or 17.3 ML/day. In the lower Bremer River, the threshold flow rate is 0.5 cubic metres/second, or 43.2 ML/day. These flow rates have been calculated on the basis of environmental water requirements such as the water depth required for fish movement.

Note that further information on low flows is given in the “Returning low flows” section.

59. The 7.5% evaporation figure is not correct. We lose half the water from our dam in summer due to evaporation. (Mt Pleasant - 24 May)

The 7.5% evaporation figure represents the total volume of evaporation as a percentage of the total average annual runoff. It is agreed that evaporation as a percentage of dam capacity is more than 7.5%.

60. If I have 30% seepage from my dam that ends up underground, isn’t that a benefit? (Mt Barker - 31 May)

The 30% loss figure from dams is largely due to evaporation, rather than seepage to groundwater.

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61. How do you find out how much water I have coming off my property? (Langhorne Creek - 25 May)

Runoff has been measured using flow gauging stations throughout the Eastern Mount Lofty Ranges. Surface water models have been developed using this flow data and local rainfall data. The models have been used to develop rainfall-runoff relationships that have been used to estimate runoff at different scales (e.g. management zone).

62. If the flows have declined in the last 10 years, then why are my dams responsible if they are 30 to 40 years old? (Mt Barker - 31 May)

Capture or extraction of water means that downstream flow will be reduced by that amount of water taken, so reductions in flow would have been occurring since dam building or other water capture began. Dams built 30 or 40 years ago are playing a part in the current reduction in flow.

63. How much water is being held in the state compared to average rainfall and runoff? (Mt Compass - 23 May, Mt Pleasant – 24 May, Mt Compass – 30 May)

This consultation period relates to the Eastern Mount Lofty Ranges only. The total dam capacity in the Eastern Mount Lofty Ranges represents 17% of the long-term average annual adjusted runoff for the area (for 1971-2006). Adjusted runoff means the runoff adjusted to account for the impact of dams, watercourse diversions, forestry and some urban areas on flow.

64. What water would flow into streams etc if the land had not been cleaned? Lots more plants, leaf litter, mulch soaking/using water and holding it back, slowing it down, and less run off than cleared land. (Mt Compass - 23 May)

Land clearance would have changed runoff patterns and volumes. More rainfall is likely to run off a paddock or urban area compared with native vegetation. However, runoff has also been reduced by capture of water in dams and by watercourse diversions. As you have identified, water would have been held back by leaf litter and deeper soils around drainage lines and creeks under natural conditions, allowing for a slower, longer release of water and probably a longer flowing season. Extraction of groundwater may have also affected flow in creeks in some areas by reducing input of baseflow via springs and seeps.

65. The base rate (consumptive use limit) of 15% should stay with the land it falls on (i.e. each hectare keeps 15% of the water). Then no matter what land is bought or sold it retains its base rate. This to be put in submission to include or change the current draft. (Mt Compass - 30 May)

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Dam construction and works

66. Am I allowed to put a plastic liner in my dam and reduce my dam to under 5 ML? (Mt Barker - 19 May)

67. Do I need a permit to reduce my dam size? (Mt Barker - 19 May)

68. Do you need a permit to repair a dam wall? (Mt Compass - 23 May)

Yes, it is likely. A water affecting activity permit is required for modification of a dam, as is likely to occur if the dam capacity is reduced, and potentially if a dam is repaired depending on the nature of the work.

It is suggested that landholders considering works on dams in the Eastern Mount Lofty Ranges contact the Water Resources Assessment Officer at the SAMDB NRM Board on 8391 7500 to discuss whether a permit is required for their situation.

69. Will water affecting activity permits affect existing dams? Can you put it in writing that repairing a dam will not require a permit? (Strathalbyn - 26 May)

Permits only affect existing dams when those dams are modified, enlarged or removed. A permit may be required for repairing a dam, depending on the nature of the work.

70. If I want to do work on my silted, leaking dam, do I need a permit? (Mt Barker - 19 May)

71. Do you need a permit for cleaning out and maintaining old dams? (Mt Compass - 23 May)

72. Do I need a permit to clean out my dam? Where do I put the soil that I clean out? (Strathalbyn - 26 May)

73. When you take two or three feet of silt out of a dam for cleaning, I thought you had to get a permit for that? (Strathalbyn - 26 May)

A permit is not required for desilting a dam in the Eastern Mount Lofty Ranges, provided that the dam capacity is not increased (i.e. only remove accumulated silt), the dam wall height is not increased, and the excavated material is not placed in or near a watercourse, floodplain or lake.

Repairing a dam may require a permit depending on the nature of the work.

It is suggested that landholders considering works on dams in the Eastern Mount Lofty Ranges contact the Water Resources Assessment Officer at the SAMDB NRM Board on 8391 7500 to discuss whether a permit is required for their situation.

Note that the rules for desilting dams are different in the Adelaide and Mount Lofty Ranges (AMLR) NRM region. It is suggested that landholders in that area contact the AMLR NRM Board on 8273 9100 for information.

74. What is the rule at present regarding cleaning of dams in the Victor Harbor region? (Mt Compass - 23 May)

Victor Harbor lies within the Adelaide and Mount Lofty Ranges (AMLR) NRM Board region, and dam cleaning there is managed under the AMLR Regional NRM Plan. It is understood that a permit is required for cleaning an on-stream dam under this plan. It is suggested that you contact the AMLR NRM Board on 8273 9100 to discuss your situation.

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75. What criteria are used to assess applications to build new dams? (Mt Compass - 23 May)

76. Suppose that someone had a property with a large dam and then split that property into two. Then one property would have the dam and the other property, which relied on this dam, would have no dam. What are the chances of the people who have the property without a dam to get a permit for a new dam? (Mt Barker - 19 May)

77. How much water can I capture at my place? (Strathalbyn - 26 May)

78. Can I capture 15% of the water that runs off my property? (Strathalbyn - 26 May)

Approval for new dam construction, and the size of new dams, would depend on the amount of dam development and water use already in the area.

The dam construction permit policies in the draft EMLR WAP include dam capacity limits at the catchment scale, management zone scale and property scale, as well as limits aimed at protecting access by downstream users and the environment. Likely usage from proposed dams is also assessed against the consumptive use limits. All of these rules would be applied to a permit for new dam construction, and the allowable new dam capacity would be the smallest volume determined by these rules.

In the case of sub-division example, the landholders could consider entering into a water supply arrangement to provide water from the dam to the property that has been split off.

Note that the dam capacity limit is set at 30% of average annual adjusted runoff. The 15% limit sets the cap on the total volume that can be taken from dams and watercourses and applies at the scale of the whole catchment (e.g. Angas River catchment) and the management zone. The 15% limit does not apply at the property scale.

79. Because every property varies in size, there was a policy where there was a certain ratio of how much water you were allowed to store as a proportion of the catchment on your property. Is this policy still in place and will you be able to apply for a permit and be granted one in regards to whatever your run off will be? (Mt Barker - 19 May)

Dam construction in the Eastern Mount Lofty Ranges is currently managed under the rules in the SAMDB Regional NRM Plan. The Regional Plan includes property-scale dam capacity limits based on 30% of the average winter runoff from a property. The Regional NRM Plan also includes sub-catchment limits based on 30% of the average winter runoff from the sub-catchment. Both of these limits apply. This means that if the total dam capacity in a sub-catchment is already at or over the sub-catchment limit, then new or enlarged dams would not be allowed on a property in that sub-catchment, even if the dam capacity on that property was under the property-scale limit.

The draft EMLR WAP includes similar limits on dam capacity at the property scale and management zone scale. The draft plan also includes additional limits at the scale of the catchment as well as limits designed to protect downstream users and the environment. These limits all apply, so the allowable new or enlarged dam capacity will be the smallest volume permitted by all of these limits (which may be zero, in which case the permit application would be refused). So once again, this means that if one of the other types of limits is exceeded, then a permit for a new or enlarged dam would be refused, even if the total dam capacity on the property that is under the property-scale dam capacity limit.

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80. I have a concern that if your property is under-developed, you will miss out on your rights to water storage because of the permit process. I can understand going through this process if your property is over-developed. (Mt Barker - 19 May)

81. If I have a couple of dams and I am only using 9% of my runoff and want to put a new dam in, but you allowed for a new dam to go in downstream, then I might not be able to put my new dam in because of the new dam downstream. So I can’t catch the rest of my water. Who is going to compensate me for the loss of my water down the river? (Mt Compass - 30 May)

It is important to manage water capture at the larger catchment scale as well as at the property scale, because all parts of a catchment are connected by the flow of water through the system. An area of a catchment may be over-developed, causing problems for downstream users and the environment. Any further dam development on a property within that area, even if that particular property is under-developed, will make the problems worse.

82. Some people have more storage than required. Are you requesting these people to reduce the number of dams they have? (Mt Barker - 19 May)

No, the draft EMLR WAP does not propose or require removal of dams or reduction of dam capacity.

83. I have a property that has 4 titles and I want to supply water to all of those titles by putting a big dam at the top of the hill. How much water am I allowed to supply to those titles? What size dam would I need to supply 4 domestic uses? (Langhorne Creek - 25 May)

It is up to the applicant to decide what size of dam they would like to apply for. The water affecting activity permit policies are used to assess whether a dam of that size may be constructed.

The dam construction permit policies in the draft EMLR WAP include dam capacity limits at the catchment scale, management zone scale and property scale, as well as limits aimed at protecting access by downstream users and the environment. Likely usage from proposed dams is also assessed against the consumptive use limits.

The property scale policies in the draft plan limit total dam capacity to twice the volume of the reasonable water requirements of the property from dams. This includes evaporation, licensed use and non-licensed use, with a nominal figure of 1 ML included for domestic requirements.

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84. If I put a dam in a gully or a dam in a creek, what is the difference? (Langhorne Creek - 25 May)

The permit policies in the draft EMLR WAP set out that a water affecting activity must not have adverse impacts on water-dependent ecosystems, including migration of aquatic biota. Building a dam in a creek is more likely to affect movement of aquatic biota such as fish, compared with building a dam in a gully.

The draft plan also sets out that new or enlarged dams must not be on-stream dams, unless there is no suitable location on the property for it to be constructed as an off-stream dam. An on-stream dam is built across a watercourse or flow path for the purpose of holding back and storing the flow of that watercourse or flow path. A new dam in a creek would be an on-stream dam, and so would generally not be permitted unless there is no other option on the property.

An off-stream dam is not constructed across a watercourse, and is primarily designed to hold water diverted from another source (e.g. a watercourse, another drainage path, or an aquifer). It may capture a limited volume of surface water from the upstream catchment (up to 5% of its total capacity). A gully dam may be an on-stream dam or an off-stream dam, depending on its location, size and construction (e.g. may have a contour bank upstream that directs flow around the dam). If a new gully dam is an off-stream dam, it is more likely to be approved, provided it meets the other policies in the plan.

85. Some people have a dam every 100 meters. They are over storing water and they don’t use it all. They should have to bypass 100% in some instances. (Mt Barker - 19 May)

86. If someone collects 60% of the water instead of 30%, then their dam should be knocked down. (Strathalbyn - 26 May)

87. Most people want to build a dam for sub divisions. (Mt Pleasant - 24 May)

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Roof runoff

88. Are you saying that people won’t be allowed to collect water from their roof? (Langhorne Creek - 25 May)

No. In a small number of cases, a licence will be required to use roof runoff for licensed purposes but it is not intended that this will stop people using roof runoff. The draft EMLR WAP generally allows new allocations to be made from roof runoff in the cases where a licence is required.

A licence is only required for using roof runoff when that water is used for licensed purposes and more than 500 kilolitres (kL) is deemed to be collected, or when any volume is collected and used for irrigation.

Roof runoff used for stock and domestic purposes is not licensed or metered, and is not affected by the prescription process or the water allocation plan.

89. Do we have to pay for rain water? (Langhorne Creek - 25 May) In cases where a licence is required for using roof runoff (as described above), then the same water levy is payable for this allocation as is payable for other allocations (see “Costs” section).

90. In the plan it says that roof runoff will be available as long as environmental flows are available. How are you determining that? (Langhorne Creek - 25 May)

The draft EMLR WAP says that if a licence is required for using roof runoff and more than 1,000 kL is deemed to be collected, then the runoff from a nominated percentage of the roof area needs to be returned to the environment. The nominated percentage is given for each management zone in Table 4.4 (starting page 93) in the draft plan. These percentages have been calculated based on the percentage of rainfall that would be expected to run off the land and also recharge the groundwater aquifers in the absence of water resource development in the current landscape.

91. Any restriction / specification on returning capture runoff? For example, from roofing to recharge water bore? (Mt Barker - 31 May)

The draft EMLR WAP says that returned roof runoff should be returned to the environment as close as reasonably practical to the natural path. This will need to be assessed on a case-by-case basis and potentially could occur via a recharge bore (provided that water is not re-extracted).

Groundwater

92. How big are the well buffer zones? (Mt Compass - 30 May) It depends on the underground water management zone and the purpose of water use from the well. The proposed sizes of the well buffer zones are given in Table 5.3 on page 139 of the draft EMLR WAP, and have a radius of 50-200 metres.

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93. There are thousands of bore sites in SA that aren’t equipped. What restrictions are there to equip an existing well or bore for stock and domestic use? (Mt Compass - 30 May)

There are no restrictions in the draft EMLR WAP on equipping an existing well for non-licensed stock and domestic use, as use for stock and domestic purposes is exempt from the prescription process.

94. Has the effect of low river level been considered in relation to groundwater levels? (Langhorne Creek - 25 May)

The consumptive use limits for groundwater have been set based on long-term recharge rates or behaviour, rather than based on recent responses to drought and low river level. Some aquifers (such as the confined limestone aquifer) are not directly connected to the rivers, and so will not be affected by low river levels.

95. How much water has gone into the aquifers from the Queensland, New South Wales and Victorian floods, and from Papua New Guinea? (Mt Barker - 31 May)

The only connection between the aquifers of the Eastern Mount Lofty Ranges and the River Murray waterways carrying flood water from Queensland, New South Wales and Victoria occurs in close proximity to the River Murray and Lake Alexandrina. The amount of flood water going into these aquifers has not been estimated but is likely to be small.

There is no demonstrated connection between groundwater systems in Papua New Guinea and the Eastern Mount Lofty Ranges. Groundwater from both systems would ultimately discharge to the ocean as it is the lowest point in the hydrological cycle.

Groundwater in the Eastern Mount Lofty Ranges comes from infiltration of local rainfall.

96. When you talk about salinity impacts, are you talking about salinity in the water itself or salinity seeping up? (Mt Barker - 19 May)

We are talking about salinity in the groundwater.

97. Anyone who has a bore in this area will tell you that the water level hasn’t dropped at all in the last 30 years. (Mt Compass - 30 May)

The Department for Water monitors 24 groundwater bores in the Mt Compass area. Twenty one of these have shown a declining groundwater level trend over 1999-2010, with 10 of these declining at an average rate of 0.2 metres per year or more. This groundwater monitoring data is available at https://obswell.pir.sa.gov.au

Monitoring by the Mt Compass Area School also shows declining groundwater level trends in some bores.

98. You could measure a bore today and at the same time next week, and it would be different. (Mt Compass - 30 May)

Analysis of groundwater level trends has been done over the long term, using data from a consistent time of year (in September, after recharge over winter but before significant irrigation extraction).

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99. Have you located free flowing bores which should be capped? Although this could affect downstream users and the environment. (Mt Barker - 31 May)

No. Any decommissioning of bores is the responsibility of the owner.

Environment

100. How can the environment use underground water? (Mt Pleasant - 24 May)

The environment can use underground water in a number of ways:

underground water can be discharged to the surface into wetlands and creeks via seeps and springs

some animals, known as "stygofauna", live under the ground in aquifers

some plants have roots that tap into the water table

101. How will the environment benefit? Bremer River health is now the best it has ever been – as compared to previous condition due to impacts by the Mount Barker Woollen Mills and Kanmantoo mine. (Langhorne Creek - 25 May)

The health of the Bremer River will have improved as a result of management or cessation of water quality impacts from industrial activities. However, water extraction is also believed to have had negative effects on water resources and the environment, such as declines in native fish populations and increases in salinity in some areas. Better sharing of water resources between all users is expected to have benefits for the environment as well as other water users.

102. You have missed the whole point of prescription in regard to the environment. (Mt Compass - 23 May)

The NRM Act requires a water allocation plan to provide for taking and use of water that achieves an equitable balance between environmental, social and economic needs for water. The SAMDB NRM Board believes that the proposals in the draft EMLR WAP achieve an equitable balance.

103. Why aren’t you protecting the sea? There is too much fresh water going out to the sea. (Strathalbyn - 26 May)

The catchments of the Eastern Mount Lofty Ranges flow into the River Murray or Lake Alexandrina before flowing out to sea. The amount of water flowing through the Murray Mouth to the sea has been inadequate, with dredging required to keep the Murray Mouth open for eight years until the recent floods.

104. Dam sizes should be increased to provide for environmental flows, for example, increase a 5 ML dam to 7 ML. The landowner then is only allowed to use 5 ML and there will always be 2 ML for the environment. (Mt Compass - 23 May)

It is more environmentally sound to allow water to remain within the flow system, rather than building additional dam capacity to capture flow that will be subject to evaporation before it may be released for the environment. A key issue is that dams interrupt the natural flow pattern that the environment relies on, and building more dam capacity will exacerbate this issue.

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105. When are you going to publish the environmental impact statement? (Mt Compass - 30 May)

A report outlining the impact of current development on environmental flows is available on the SAMDB NRM Board's website at: http://samdbnrm.sa.gov.au/Portals/9/PDF%27s/Water/Environmental%20Water%20 requirements%20of%20the%20EMLR.pdf

106. If we only use 50% of our allocation then we should be given an incentive for helping the environment. (Mt Compass - 23 May)

Transfer

107. Can you give a more practical example of how transfers work? (Strathalbyn - 26 May)

A hypothetical example of the steps in a groundwater transfer is given below:

Person A has a groundwater allocation that they want to sell. Person A’s bore is located on their property. Person B wants to expand the area they irrigate and wants to buy some additional allocation. Person A and Person B both take water from the same aquifer.

Person A agrees to sell their allocation to Person B.

Person A and B both sign a transfer application and submit it to Department for Water.

The detail of any payment between Person B and Person A is an agreement between the parties and is not administered by the Department.

The Department assesses the transfer application against the relevant policies in the water allocation plan, which include management zone limits and buffer zones.

If the transfer is approved, Person A no longer takes water for licensed purposes from their bore, but they may still take water for stock and domestic purposes). Person B may now pump the transferred allocation from the bore on their property.

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108. How do you transfer water from one place to another? (Strathalbyn - 26 May)

109. How do I get the water that I buy? (Mt Compass - 23 May)

110. If I need more water and my neighbour sells me their allocation, how do I get the water from his dam to mine? (Strathalbyn - 26 May)

It is the right to take water that is being transferred, not the water itself. Basically it means that water stops being taken at the original location, and an equivalent volume of water can be taken at the new location. A transfer does not mean physically moving water from one area to another.

Transfers are assessed under the rules in the relevant water allocation plan. The transfer rules in the draft EMLR WAP aim to protect users and the environment from impacts of new water use in their area as a result of a transfer from one place to another.

Note that having an allocation is separate from the approval to build a new dam or well to capture that allocation. A water affecting activity permit is required for new dam or well construction, and permit assessments are governed by the rules in the relevant plan (water allocation plan and/or Regional NRM Plan). Having an allocation does not mean that a permit to build a new dam or well will be automatically granted.

111. So is the transfer of water just on paper? (Strathalbyn - 26 May) A transfer can involve a change of ownership of a water entitlement, for example on sale of property, or it can involve approval for a change in the location where a water entitlement can be taken. Both represent a ‘real’ transfer of water rights between people or locations.

112. Why are transfers being allowed? Who really benefits? (Strathalbyn - 26 May)

Transfer allows water users to gain additional water from another user, within sustainable limits. This can allow a user to start a new business, expand or change an existing business, or to manage water supply risks to existing businesses by having extra water (e.g. buy in extra water to be taken from a back-up well to help to drought-proof a business that largely relies on water from a dam). Transfer also allows someone to realise the benefit of their water asset if they no longer need it by selling it to someone else, in the same way as they can sell other assets.

113. Are the water licences with the property or the person? What about the poor people who buy a property with no water? You shouldn’t be allowed to sell the water without the property. (Mt Pleasant - 24 May)

Water licences sit with the person, not the property. The NRM Act allows water to be transferred separately from land, in accordance with Council of Australian Government initiatives. This allows, for example, a person who wants to expand their irrigation area to buy unused allocation from a neighbour. If someone sells their water allocation separately from their property, then this is likely to reduce the value of their property as an ongoing business - but this is the decision of the seller.

Water for watering free-ranging stock and for domestic purposes is not licensed in the Eastern Mount Lofty Ranges and therefore cannot be traded.

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114. What happens if a property is kept and the water is sold? Does the property never have the opportunity to get its water back? Water should stay with the land (or the base rate of it). (Mt Compass - 30 May)

Water licences are owned by the person rather than being inseparable from a parcel of land. This allows, for example, a person who wants to expand their irrigation area to buy unused allocation from a neighbour. At some time in the future, the person who sold the water could buy water back either from the person they sold it to, or another licensee in the region, provided that it meets the rules within the water allocation plan.


115. Are there any mechanisms to put a caveat on your water so it can only remain on your property? (Mt Compass - 30 May)

An allocation on a water licence is tradeable, but it is up to the owner to decide whether they want to try to transfer their water. The NRM Act does not include any provisions whereby the seller of an allocation can impose conditions on the new owner of that allocation.


116. I am concerned with trading water allocations. Is there anything to protect the licences to stay in the districts? (Mt Compass - 30 May)

The draft EMLR WAP does not allow water to be transferred to be taken outside the Eastern Mount Lofty Ranges region, except for instances where properties straddle the boundary of adjoining areas. However, it does allow water to be transferred within the Eastern Mount Lofty Ranges region within limits. The decision to try to transfer remains that of the licence holder.

117. Can water be transferred from Tookayerta to Yundi? (Mt Compass - 30 May)

Yes, this may be allowed by the rules proposed in the draft EMLR WAP, provided that the transfer meets all of the rules in the plan.

118. Is it right that we have let a lot of licences go interstate? (Mt Pleasant - 24 May)

Along the River Murray Prescribed Watercourse, there is capacity for transfer of water between the states, and such trades do occur. This is reflecting the fact that this is a single resource which crosses state boundaries. However there is no capacity for interstate trade from any other of the prescribed areas in the state, as trade is only internal within each prescribed area.

119. What happens to the water? Will licences go to someone interstate or overseas? (Mt Barker - 31 May)

The draft EMLR WAP does not set out policies around who can own the right to take water.

120. When you transfer a water license, is there a loss of volume of that transfer? (Mt Pleasant - 24 May)

No, that is not proposed in the draft EMLR WAP.

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121. Is the SAMDB NRM Board aware of the proposed amendments to the NRM Act going through parliament in relation to reduction of dam capacity? (Strathalbyn - 26 May)

The SAMDB NRM Board is aware that a large number of amendments to the NRM Act are going through parliament. Any amendments in relation to reduction in dam capacity on transfer of allocation have not been considered in the draft EMLR WAP.

122. If you have a licensed situation and the owner sells their allocation to someone else, does the dam then have to be destroyed? (Strathalbyn - 26 May)

There is no requirement for dams to be removed when an allocation transfer occurs between two existing dams.

There could be a situation where a landholder chooses to remove an existing dam to ‘free up’ capacity for a new dam to be built at a new location, however this relates more to the approval to construct a new dam than to the allocation transfer itself.

123. The Commonwealth Constitution prohibits laws and regulations to be made allowing for water trade. (Mt Compass - 30 May)

The NRM Act (which the draft EMLR WAP sits under) allows for trading of water allocations, in accordance with Council of Australian Government initiatives. We are not aware of any challenges to the validity of this legislation.

It is assumed that the comment relates to Section 100 which is the only part of The Constitution which mentions water (apart from marine waters). Section 100 reads:

100 Nor abridge right to use water

The Commonwealth shall not, by any law or regulation of trade or commerce, abridge the right of a State or of the residents therein to the reasonable use of the waters of rivers for conservation or irrigation.

The Commonwealth has certain powers to make laws with respect to trade and commerce. Section 100 makes it clear that the Commonwealth may not make a law in respect of trade or commerce that would limit a State or an individual’s rights to the reasonable use of the water of rivers. This section does not have the effect of prohibiting State laws and regulations in relation to the transfer of a water licence or a water allocation.

124. Water trading is a big no. Water should be valued. (Strathalbyn - 26 May)

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Rollover

125. With regard to rollover, how much is it and for what period of time, to allow for flexible dependencies on different resources? (Mt Compass - 30 May)

126. How do you apply rollover to water taken from dams? (Mt Compass - 30 May)

127. Can you give a more practical example of how rollover works? (Strathalbyn - 26 May)

The draft EMLR WAP proposes that if a licensee doesn't use all of their allocation in a water-use year, they can roll over some of their unused allocation to be used in the next water-use year.

The amount of unused water allocation that can be rolled over into later years is capped at 10% of allocation, and in the case of dams, the rollover plus base allocation can't exceed dam capacity.

Rollover allocations for surface water and watercourses have a "life" of one year - that is, unused allocation from year one could be used in year two, but not in year three. Rollover allocations for groundwater have a "life" of two years - that is, unused allocation from year one could be used in year two and/or three, but not in year four.

Base allocations are used before the rollover allocation.

A hypothetical example of rollover from a dam is given below.

A licensee has a 10 ML allocation which they can take from a 15 ML dam

In year one, the licensee uses 8 ML, so 2 ML is unused. They can roll over 1 ML into year two (as 1 ML is 10% of their 10 ML allocation).

The licensee would have an 11 ML allocation in year two (10 ML base allocation + 1 ML rollover)

The licensee uses 10 ML in year two. This means the whole 10 ML base allocation is used (as base allocations are used before rollover), so no rollover is earned for use in year three. The rollover allocation "earned" in year one was not used, and so expires and is not available in year three.

So the allocation in year three would be 10 ML (base allocation only).

Note that having an allocation means that the licensee can take that water if it is available from their licensed sources. It does not guarantee that the water will be available. So a user may earn a rollover allocation in the example above, but would not physically be able to take it if there is only 9 ML in their dam that year.

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128. Does rollover exclude stock and domestic use? (Strathalbyn - 26 May)

Yes, it is intended that rollover excludes stock and domestic use. That is, the volume of water used for non-licensed purposes (like stock and domestic use) is not counted as part of the allocation volume used, and so would be excluded from the determination of potential rollover allocations.

Stock and domestic use is exempt and does not require a licence, so there is no need to ‘roll over’ water for stock or domestic use.

Other policy areas in the draft plan

129. How come the SAMDB NRM Board is having a recommendation for no further allocations? (Mt Barker - 31 May)

The proposal for no new allocations is a cautious approach in the face of uncertainty, particularly in terms of climate change and variability.

The proposal is that existing users will be allocated water within the sustainable limits, and then the responses of the water resources, users and the environment will be monitored. An important feature of the planning process is that the data would be evaluated when the plan is reviewed within five years (as required under the NRM Act), and a decision made then on whether further allocations can be made. Users could still obtain water for licensed use during this time via transfer from another licence holder.

The proposal of no new allocations was recommended by the community advisory committees, but there was vigorous discussion on this issue and the committees were almost evenly divided on the issue. The SAMDB NRM Board is particularly interested in broader community feedback on this proposal.

130. Is forestry going to be allocated water similar to the South East? (Mt Compass - 30 May)

Not currently for the Eastern Mount Lofty Ranges.

However, amendments have been proposed to the NRM Act to identify commercial forestry as a water affecting activity. If this occurs, then new commercial forestry occurring after that would require a permit under the draft EWMLR WAP. Section 7.2.9 (from page 170) of the draft plan outlines the proposed policies for assessing such permit applications, including assessment against groundwater and surface water limits.

Note that the volume of water estimated to be intercepted or used by commercial forestry is counted against the consumptive use limits in the draft plan.

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General water affecting activities

131. We still have a policy where country towns put effluent into the water. We need to change the whole attitude. (Mt Compass - 23 May)

Putting effluent into a watercourse requires authorisation under the Environment Protection Act 1993, or in minor cases, requires a water affecting activity permit under the Regional NRM Plan (or EMLR WAP once adopted). In both cases, there are safeguards to minimise risks and impacts to the water resource, water users and the environment.

132. Why do I need a water affecting activity permit for pushing weeds, rubble for a creek crossing, preventing gully erosion, for digging a clay pit for clay spreading, for putting a fence across a creek, or for filling in sink holes/gutters so employees stay safe when doing stock work? (Mt Compass - 30 May)

133. I live in the Inman Valley and I applied for 3 dams. They changed the rules while I had my permit in. They are treating people like they know nothing about dams. We are not allowed to push things in a creek because that is deemed as a water affecting activity. (Strathalbyn - 26 May)

Most landholders do the right thing when doing works on their properties. However, in some cases this does not occur. The permit system allows works in and around watercourses to be managed to reduce the risk of negative impacts on water resources, water users (including other users who may be affected), and the environment.

Pushing material into a creek has the potential to lead to negative impacts like blocking flow, and creating or worsening erosion and sedimentation. This may affect other water users and the environment, for example by reducing downstream flow, or by eroded silt going into dams and pools and making them shallower.

134. 50 years ago we took over a property that had serious gully erosion. We spent thousands of dollars to control the erosion. The property is now 95% free of gully erosion. But now we have to apply for a permit to control any erosion that may occur. It is an insult to 50 years of work. It is a slap in the face. It is a money grab. (Mt Compass - 30 May)

Monitoring

135. Who does the monitoring? (Mt Compass - 30 May) The SAMDB NRM Board and the Department for Water have existing monitoring programs for flow, salinity, groundwater level and native fish. Community members and groups and other agencies also monitor a range of parameters including groundwater level, water quality and macro-invertebrates.

The Department for Water also monitors water use via meter reading. The draft EMLR WAP proposes that water users provide information on water use practices, building on the existing water use reporting that already occurs in the lower Angas-Bremer area under the current groundwater water allocation plan that applies there.

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136. It is a very good plan and I am pleased to hear about it. There is a lot there to monitor. Will you have staff there to monitor? How are you going to resource this? (Langhorne Creek - 25 May)

The SAMDB NRM Board and the Department for Water will need to continue to resource their existing monitoring programs and provide support for the excellent monitoring work done by community members and groups. The levy raised by the Board contributes to the monitoring of the system.

Returning low flows

137. Are low flow bypasses for new or existing dams? (Strathalbyn - 26 May, Mt Barker - 31 May)

138. Are the low flow bypasses only for dams over 5 ML? (Mt Barker - 19 May)

139. Is the low flow water device needed on existing dams? (Mt Barker - 31 May)

140. Who works out who needs a low flow bypass? (Mt Barker - 19 May)

141. Not every 5 ML dam will need the low flow bypass? You will assess each dam individually? (Mt Compass - 23 May)

142. Is the allocation requirement dependent on a low flow water device? (Mt Barker - 31 May)

It is proposed that low flow bypasses would be required for:

All new dams and watercourse diversions (where the diversions require a permit)

All existing licensed dams and watercourse diversions

All existing non-licensed dams with a capacity of 5 ML or more

The SAMDB NRM Board and the Department for Water will work together on a strategic location project to see if the same environmental outcomes can be achieved while providing low flow around fewer dams and diversions. The outcomes of this project may (or may not) reduce the number of existing dams and diversions that are to provide low flows.

143. Low flow bypasses have to be installed on licensed diversion points. What does this mean? I have never had a license. (Mt Compass - 23 May)

Water licences have not yet been issued.

Existing users need to have applied for a water licence by 8 March 2006, and commonly hold an authorisation to continue their existing use.

Note that a water licence is not required for domestic water use (including watering up to 0.4 hectares of garden), providing drinking water for free-ranging stock, and for some other specific uses such as fire fighting.

144. There is no option? This is going to happen? [in regard to low flow bypasses] (Mt Barker - 19 May)

This is what is currently proposed in the draft EMLR WAP and for the existing user allocation process.

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145. Aren’t a number of dams already regulated with low flow bypasses? (Mt Barker - 31 May)

Yes. New dams have been required to include a low flow bypass as a condition of a water affecting activity permit since 2003. A water affecting activity permit (or development approval) has been required for dam construction in the Eastern Mount Lofty Ranges since 2003 under the former Catchment Water Management Plan for the River Murray in South Australia, and now under the South Australian Murray-Darling Basin Natural Resources Management Board Regional Natural Resources Management Plan.

146. If there weren’t low flow bypasses on dams then how would the surface water demand maps change from how the green and orange areas are now? (Mt Barker - 31 May)

Returning low flows means that the consumptive use limit is significantly higher than it would be if low flows are not returned. The surface water demand maps would have many more orange zones if low flows were not returned around dams and watercourse diversions.

147. I am in favour of the whole concept (of returning low flows), however, how many dams will have 100% bypass because they have too much storage? (Mt Barker - 19 May)

The draft EMLR WAP and the existing user allocation process does not currently propose to reduce dam capacities or have a higher bypass rate for areas with a high level of dam development.

148. If you have an existing dam and allocation, do you have to put in a low flow bypass before you get you license? (Mt Barker - 31 May)

No, but the licence will have a condition that enables the Minister to require a low flow bypass to be fitted within a certain timeframe. This timeframe has not yet been finalised but is likely to be a number of years.

149. What is the point and fairness of the low flow bypass if a dam downstream of less than 5 ML receives the water and they don’t have to bypass low flows? (Mt Barker - 31 May)

Water-dependent habitats between the two dams will benefit from the returned flows, which may include damp areas supporting reeds and temporary water-bug communities or more aquatic habitats like pools.

The downstream dam will also fill and spill sooner, providing downstream flow earlier.

150. If you have a 5 ML dam higher than a neighbour’s smaller lower dam and you bypass the 10%, the neighbour will not be very happy. (Mt Barker - 19 May)

The neighbour will probably be happy to get additional water in their dam.

If the neighbour's dam is used for licensed purposes, or is used for non-licensed purposes with a capacity of 5 ML or more, then the neighbour's dam will need to bypass the low flows received from upstream as well.

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151. A low flow bypass on my dam would mean that the water would flow downstream and fill my neighbour’s dam. (Mt Compass - 23 May)

If the neighbour's dam is used for licensed purposes, or is used for non-licensed purposes with a capacity of 5 ML or more, then the neighbour's dam will need to bypass the low flows received from upstream as well.

If the neighbour's dam doesn't need to return low flows, then the additional bypassed water will mean the neighbour's dam will fill and spill sooner, returning flow downstream sooner. Any water-dependent habitats between the dams will also benefit, which may include damp areas supporting reeds and temporary water-bug communities or more aquatic habitats such as pools.

152. When will the low flow bypass work? When will it save some frogs down the creek? (Mt Compass - 23 May)

The low flow policy works such that low flows at or below a threshold flow rate are to be returned or not captured. This means that some flows will be returned to the catchment when there is flow present, passing from dam to dam down to the watercourses. Flow will start in watercourses earlier and last longer. This means that refuge pools are less likely to dry up while waiting for flow to begin, and water-dependent animals and plants will have more time to complete their life cycle.

A Flinders University study found that there were environmental benefits downstream of dams with low flow bypasses, when compared to similar dams without low flow bypasses, in the Marne catchment. These benefits included an improvement in water-plant cover and an increase in abundance and diversity of aquatic macroinvertebrates (water-bugs).

153. Are you sure about your research of history and the timeframe used? Rodwell Creek would normally go dry from October to March/April and there were no pools or fish ever before the dams. The creek flows to Lake Alexandrina naturally. I don’t see how in practical terms, if you get 3 months of sun and no rain, how we are going to get the environmental benefits. (Mt Barker - 19 May)

Rodwell Creek will stop flowing over summer and autumn, like many streams in the Eastern Mount Lofty Ranges. However, pools remain in Rodwell Creek (and other places in the Eastern Mount Lofty Ranges) and support plants and animals that need to live in and around water. For example, the last remaining known population of River Blackfish in the Bremer catchment are found in Rodwell Creek. Those pools persist over the drier seasons because of sufficient depth to last through the season, inflow of groundwater via springs and seeps, and inflow from occasional rainfall events (or a combination).

Much of the runoff from summer and autumn rainfall events and at the break of season is likely to be captured by dams which are usually not full at that time. This capture delays the natural start of the flow season. As a result, refuge pools are more likely to become too salty to support plants and animals, or may even dry up altogether, before flow starts in the creeks. Returning low flows means that the pools will get flow earlier and for longer in the flow season.

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154. The whole creek near me dries up in summer for 4-5 months. If you install a low flow bypass then you will only get flow down the creek when you get runoff. Have you ever done field work? The science is rubbish. (Mt Compass - 23 May)

It is well understood that the creeks in the Eastern Mount Lofty Ranges generally stop flowing in summer and autumn, and this has been incorporated into the work done to assess environmental needs and to set water taking limits and rules. As you have identified, the intention of the low flow proposal is that low flows would only need to be returned around dams when flow is actually occurring.

155. We have two dams with a creek between each. These have been fenced and planted and have an established ecosystem. A second creek starts behind our second dam with an existing ecosystem. I think this is under threat with lower flows. Does environmental impact have to start when it reaches the big creeks into the Bremer? (I realise the second creek will be ok as will be fed by bypass flows but not the first creek). (Mt Barker - 19 May)

We still have more work to do to develop an implementation program with the community, including consideration of how to deal with situations where returning low flows may threaten ecosystems.

156. If the dam is not on the watercourse then wouldn’t that be classed as bypassing low flows? (Mt Compass - 23 May)

No. Such a dam still captures surface water runoff flowing over the land, including low flows. This runoff would ultimately end up in the watercourse if it wasn't captured by the dam.

157. The plan says that we are not to stop the low flows, it is automatic. Is that correct? (Mt Barker - 31 May)

Yes, that is correct. The draft EMLR WAP includes a principle that says that devices to return or not capture flows at or below the threshold flow rate shall be designed and constructed to ensure that its correct operation is automated (principles 54 a) and 175 b))

158. Is it good enough to have a manual diversion or does it have to be automatic? One of our dams has a large pipe at the bottom of the bank, and water could be released manually though this pipe. (Mt Barker - 19 May)

The draft EMLR WAP requires that low flow bypasses operate automatically. It makes sense to use or adapt existing infrastructure (such as pipes through dam walls) where possible. We still have more work to do to develop an implementation program with the community and other experts, including exploring different design options.

159. Have you considered erosion problems with this water being diverted? (Mt Barker - 19 May)

The draft EMLR WAP requires that low flow bypasses be designed and constructed to minimise the risk of erosion and damage to infrastructure. The low flow volumes (flows below the threshold flow rate) are small in comparison to total flow. Erosion associated with these low flow rates is expected to be small and able to be managed for (e.g. suitable rock placement or other protective measures at outflow)

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160. My dams have a wide inflow. Can we siphon the amount of water out instead of putting in a low flow bypass? (Mt Barker - 31 May)

161. What about a contour bank? (Mt Compass - 23 May)

162. My dam is large but it leaks. Wouldn’t this deal with the low flows? (Mt Barker - 31 May)

163. How will my low flow leaking dam be evaluated in regards to having to install an automatic low flow installation at the high side? (Mt Barker - 19 May)

164. I have a leaking dam that is continually flowing to the environment. Does that get factored in? (Mt Barker - 19 May)

There are lots of different ways that low flows could be returned. "Low flow bypass" is a catch-all term for any type of device that returns low flows at or below a nominated threshold flow rate in accordance with the requirements (e.g. operates automatically). So long as the right outcomes are achieved, the approach to returning low flows can be fit for purpose.

We still have more work to do on how the program for returning low flows will be implemented, including exploring different design options. A low flow bypass could include a siphon system. A contour bank may be a good solution for some situations.

Consideration could be given to assessing whether a leaking dam returns low flows in accordance with the requirements, but these details need to be worked out as part of the implementation program.

165. How do you pass low flows in spring fed dams? (Mt Compass - 30 May)

We still have more work to do to develop an implementation program with the community. This includes consideration of appropriate design and approach for spring-fed dams.

166. Why are spring fed dams excluded from having a low flow bypass? Surely they are part of the watercourse? (Strathalbyn - 26 May)

Spring fed dams are not excluded from having a low flow bypass.

167. According to you, my dam holds over 5 ML. As we speak now it has an inbuilt low flow system. Water is continually flowing into the environment. It has only overflowed 3 times. How can I meter that low flow? (Mt Barker - 19 May)

It is not expected that the amount of low flow returned needs to be metered.

168. Who drew up the low flow guidelines? High flow areas will be a nightmare. (Mt Barker - 31 May)

Low flow bypasses have been installed on many dams since 2003, including in high rainfall areas. We still have work to do on an implementation program to return low flows, including working with the community and other experts to identify issues and solutions.

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169. Water users with large dams should be given the option of lowering the level of the spillway rather than being forced to build a low flow bypass device. Please advise if this option has been considered. (Mt Barker - 31 May)

If the dam is only used for non-licensed purposes, then the landholder could consider reducing the spillway so that the dam capacity is less than 5 ML, which would mean that that dam does not need a low flow bypass.

Reducing the dam spillway is not a substitute for returning low flows at or below a threshold flow rate. The dam will still need to fill and spill before flows continue on downstream. Lowering the spillway will mean that this occurs sooner during the flow season, but the dam will still intercept early season flows and flows during drier seasons.

170. What if the inflow of the dam is under the boundary fence? Who is responsible for paying for the weir? What about liability if my neighbour has to do work on my property? (Mt Barker - 31 May)

The low flow program is in the very early stages and the exact details of how it might be rolled out in situations such as this are yet to be determined. As every site will be slightly different, there will be a need for a detailed on-site assessment to be made of all the practical and logistical details at each site, and these sorts of details would need to be sorted out at that stage.

171. You are being very friendly here tonight and saying that this will be done on a property by property basis, but I never saw that written anywhere in the materials that have been provided. Where does it state that? How can we take your word that this will be done on a property by property basis? (Mt Barker - 19 May)

172. A one on one consultation when my dam is individually assessed will be important. (Mt Barker - 19 May)

173. Dams will need to be individually assessed and worked through with the owner on how to achieve the necessary low flows. (Mt Barker - 19 May)

174. Who pays for the dams to be assessed? (Mt Barker - 19 May)

The draft EMLR WAP is written assuming that low flows will be returned by all licensed dams and watercourse diversions, and by all non-licensed dams of 5 ML or more. The SAMDB NRM Board and the Department for Water intend to do more work to see if the same environmental outcomes can be achieved by returning low flows around fewer dams and watercourse diversions. However, this work may find that this can't be achieved - that is, it may be that all these dams and watercourse diversions still need to return low flows.

We still have more work to do on developing an implementation program with the community, including the process (and costs) for assessing dams.

From an implementation perspective, there is no "one size fits all". To make this program work, we will need to work with individual landholders to find a good solution for each case in terms of design, cost, impacts and environmental outcomes.

175. When is someone going to come and assess our dam for its catchment to see whether we need a low flow bypass? (Mt Compass - 23 May)

176. Will the assessments be done prior to the Minister adopting the plan? (Mt Barker - 19 May)

We don't know yet. We are still in the early days of developing the policy of returning low flows and the implementation program, and we can't anticipate the Minister's timeframe or decisions on adopting the plan. The SAMDB NRM Board will continue to provide information on the low flow bypass project as it develops.

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177. Who installs the low flow bypass? (Mt Barker - 19 May) We still have more work to do to develop an implementation program with the community. Installation could be done by the landholder, or a contractor. We will work with the community on this.

178. The first I’ve heard about low flows is tonight. Section 31 of the NRM Act gives you special powers. You can decide what dams should be made to bypass low flows and then go onto that property and do it. (Mt Barker - 31 May)

Section 31 of the NRM Act includes a number of checks and balances when undertaking works. This section only allows NRM Boards to construct infrastructure on private land with the agreement of the owner, or if the Board has first acquired an easement or similar over the relevant land. Acquiring an easement is an instrument of last resort and would only be used if a situation arose where the particular works were very important for the management of the catchment and all attempts to negotiate with the landholder had failed.

179. Is five years going to be long enough for all of this to happen? (Mt Barker - 19 May)

We hope so. We still have work to do to develop an implementation program together with the community.

180. Who will be responsible for the maintenance of the low flow bypass? (Mt Barker - 19 May, Mt Compass – 23 May)

181. What are the maintenance costs for a low flow bypass? (Mt Barker - 31 May)

182. The low flow bypass will silt up and the landowner will have to clean it. The landowner will have to pay for maintenance. (Strathalbyn - 26 May)

183. Why do you think that I would have the resources to maintain the low flow bypass? (Mt Barker - 19 May)

We haven’t worked out the implementation program yet, but maintenance will most likely be the landowner’s responsibility. If it is a licensed dam then maintenance could form a part of the licence condition.

Cost or effort required will depend on the type of design. Landholders from trial sites in the Marne catchment with the small weir and bypass pipe design have reported that the maintenance requirements are small. They clear debris off the weir and out of the small sump by hand several times a year.

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184. Can you give us an estimate of the cost for a low flow bypass? (Mt Barker - 31 May)

185. Someone I know had to pay $20,000 for a low flow bypass and then $2,000 for the meter. (Mt Compass - 30 May)

186. You haven’t told us anything about the cost of the low flow bypass. You must have a ball park figure by now. (Strathalbyn - 26 May)

187. In the Western Mount Lofty Ranges it cost between $15,000 and $20,000 for a low flow bypass. The landowners will have to pay for this. (Strathalbyn - 26 May)

The cost of a low flow bypass will depend on the type of design, type of infrastructure (e.g. watercourse diversion or dam, size of the dam) and the nature of the landscape. Low flow bypasses have been fully installed by a contractor from under $4,000 as part of a Flinders University project, although the cost will increase for larger dams and complex situations. The cost will be less for materials only, smaller dams and potentially simpler designs.

It is proposed that costs will be shared between water users and secured funding sources. The Department for Water and the SAMDB NRM Board are pursuing funding to assist with low flow bypass costs.

188. Who is going to pay for the low flow bypass? (Mt Compass - 30 May, Mt Barker - 31 May)

189. Will the owners have to pay the cost? (Strathalbyn - 26 May)

190. What happens if you can’t afford the system? We don’t want to have to get a loan and be paying it off for ever. (Mt Compass - 23 May)

191. What if farmers haven’t got the money to do this? (Mt Compass - 23 May)

It is proposed that costs will be shared between water users and secured funding sources. The Department for Water and the SAMDB NRM Board are pursuing funding to assist with low flow bypass costs.

192. You say that the cost of the low flow bypasses will be shared. Will it be a 50/50 share? (Strathalbyn - 26 May)

We don't know what the cost share will be yet. The size of the share will be partly determined by the total cost and how much external funding can be secured. The total cost is still to be determined as there is more work to do in terms of design and number of devices to be installed. For example, we still need to do the strategic location project to work out whether we can get the same environmental outcomes by installing fewer low flow bypasses.

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193. I remember the 1965, 1966 and 1967 droughts. I caught a piddle of water for 3 years. If you returned that water for low flows then I wouldn’t have anything. There are vineyards around my property, so I don’t get much water. I will have none if I return low flows. (Mt Barker - 31 May)

194. If you bypass 10-15% out of my dam, it will dry up every summer. Will this be taken into account? (Mt Barker - 19 May)

195. We just have enough flows to keep our dams going. With the bypass this water will be diverted. (Mt Compass - 23 May)

196. I have a 90 acre block with two dams. They are the only water supply for that block. These dams never fill. If I had to put a low flow bypass on then there wouldn’t be any water left, not even for stock. What about animal welfare? (Strathalbyn - 26 May)

197. Whose expense is it if the low flow bypass on my dam leaves my dam empty in dry years? Where will I get my water from? (Mt Barker - 31 May)

198. The increased ratio of low flow to high flow incidents with predicted future climate change will increase the percentage total flow bypassing a greater than 5 ML dam. This could severely affect the viability of a property. Perhaps there should be a cap on the bypassed volume (this would mean a meter of course). (Mt Barker - 19 May)

Low flows make up around 10-15% of total flows, but this varies from year to year. Returning low flows will only have a small impact on reliability of supply for dams that fill and spill in most years. It is recognised that there will be a bigger impact for dams that rarely fill.

It will be important to monitor changes in flow patterns over time and to continue to assess the impact of returning low flows on water users and the environment.

199. The 10-15% figure may be misleading. Some people may be required to bypass 50%. (Mt Barker - 19 May)

The low flow policy works such that low flows at or below a threshold flow rate are to be returned or not captured. The volume of water below the threshold flow rate is around 10-15% of total flows over the long term, but this percentage will vary from year to year.

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200. Rebalancing of the system will only happen if it rains. Since 1998 summer rains have been non-existent. (Mt Barker - 19 May)

201. What is meant by ‘passing low flows’ in dams with no flow? (Mt Compass - 30 May)

The low flow policy works such that low flows at or below a threshold flow rate are to be returned or not captured. So if there is no flow coming into a dam, then nothing needs to be returned. If there is no flow in a watercourse, then water can't be captured from the watercourse.

202. How is the low flow number to be calculated? (Mt Compass - 23 May)

203. If your dam is at the bottom end of the catchment area then you will get all the low flow bypassed from the top end of the catchment. Does this mean the people at the low end will have to bypass more water? (Mt Barker - 19 May)

204. If there is a 5 ML or more dam on land that is now much smaller than what the dam was originally constructed for, then when the low flow bypass goes on that dam, does the size of the land and its use come into account for the size of the low flow bypass? (Mt Barker - 19 May)

205. If you are trying to work out the amount of low flows to divert then somehow there is going to be metering to work this out. (Mt Barker - 19 May)

The low flow policy works such that low flows at or below a threshold flow rate are to be returned or not captured. The threshold flow rate is calculated using a factor that incorporates local runoff conditions for the management zone, multiplied by the size of the catchment area upstream of the dam.

This means that the size of the catchment area upstream of the dam (and hence the threshold flow rate and amount of water to bypass) will get higher as you go further down the catchment.

This also means that the property size is not used to calculate the rate of low flows that are to be returned or not captured. Instead, the size of the catchment area above the dam or diversion point is used.

The device to return low flows can be designed so that it returns flows at or below the threshold flow rate, without metering being required.

206. Concern about low flow bypasses for existing dams. (Mt Barker - 31 May)

207. My dam is in a lower rainfall area of the Eastern Mount Lofty Ranges. We only have one type of flow (low or fast). No idea on your decision. The watercourse does not flow at all unless there is a significant downfall of rain. The rest of the time it does not have flow at all!! This watercourse does not run into the catchment. Only once in 100 years it came close to the lake. People grow crops in the actual creek in the lower regions where it is closer to the lake. (Mt Barker - 31 May)

208. Other work needs to be put in if we need to put in a low flow bypass. (Mt Barker - 19 May)

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Dam size

209. Why did you choose 5 ML as the number [where non-licensed dams of 5 ML or more are to return low flows]? (Mt Compass - 23 May)

Larger dams have the greatest impact on low flows, because they take longer to fill and spill. You need to draw a line somewhere – it is a trade-off between cost and benefit. Five megalitres aligns with the requirements in the Western Mount Lofty Ranges prescribed area (where all dams of 5 ML or more are licensed), as well as Development Act definitions.

210. How do I know if I have a 5 ML dam? (Strathalbyn - 26 May) If you would like to know how big your dam is now, then you may contact the Department for Water who can provide you with the estimate based on a standard formula (tel. 8463 7007). You must be able to provide your CT reference or land parcel details.

211. My (non-licensed) dam is very shallow over two thirds of its area. Will it be more correctly measured for its volume? (Mt Barker - 19 May)

212. The whole ‘low flow returns’ have to be better thought out and the 5 ML size of dams must be more accurately assessed than aerial survey. (Mt Barker - 19 May)

213. Can I hire a surveyor to prove that my dam is less than 5 ML? (Mt Barker - 19 May)

214. What will be the process to go through as a property owner to put our case forward? (Mt Barker - 19 May)

If it is determined down the track that your non-licensed dam must have a low flow bypass installed, then the Department for Water will contact you with the details, including the volume of the dam calculated by them. If you believe your dam has a different volume you can advise the Department and they may in turn pre-arrange to visit your property to take measurements.

If there is still a discrepancy between how big you think the dam is compared to the Department’s measurement, you may get the dam surveyed by a surveyor.

215. If I put a wall in the middle of my dam and cut it into two smaller dams, am I exempt from having to put a low flow bypass in? (Mt Barker - 19 May)

If you undertake works that mean that the resultant maximum capacity of your non-licensed dam is less than 5 ML and this change is permanent, you will not be required to bypass low flows.

216. If I decide to reduce my dam from 9 ML to 5 ML, will funding be available? (Mt Barker - 19 May)

Funding is not currently available from the SAMDB NRM Board or Department for Water for reduction in dam capacity.

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217. If you have a 9 ML dam when full and it no longer gets above 5 ML, how is that dam classed? (Mt Compass - 23 May)

218. Who decided who had dams that were over 5 ML? While my dam has a reasonable area of water, it is only a couple of meters deep. There is not that much capacity for water. Are you using the capacity at construction or the present capacity? (Mt Barker - 19 May)

For the purpose of the prescription process, the estimate of dam size is based on the size at the time of construction. It is about dam capacity, not how full it is.

The process for determining dam capacity is described below in this section. Dam capacities have been determined by the Department for Water.

219. What formula is used to determine how much volume a dam holds? (Mt Compass - 23 May, Mt Pleasant - 24 May, Mt Compass - 30 May)

220. Dam measuring / size determination questionable as raised by the meeting. (Mt Compass - 23 May)

221. Your basis for measuring dams is flawed. (Mt Compass - 30 May)

The best available information has been used to determine dam capacities.

First and foremost, information on dam capacities has been collected directly from landholders by the Department for Water during pre-arranged site visits to properties using water for licensed purposes. This information includes existing survey and construction information, and on-site measurements.

Where this information has not been collected, dam capacities have been estimated using aerial photography to determine the surface area of dams. A tested formula was then used to determine depth and calculate volumes. The dam capacity estimate is based on the dam size at the time of construction.

If it is determined down the track that your non-licensed dam must have a low flow bypass installed, then the Department for Water will contact you with the details, including the volume of the dam calculated by them. If you believe your dam has a different volume you can advise the Department and they may in turn pre-arrange to visit your property to take measurements.

Once depth measurements have been taken, a formula of surface area multiplied by the depth of the dam is used, with a factor built into the equation to reflect the fact that the dam has batters which are generally 3 to 1 batters. There is also a separate gully dam formula used in instances where a dam is built in a steep gully. A project was undertaken to test the accuracy of the formula against a variety of dams in the Mount Lofty Ranges which had a known capacity. This project helped refine the formula. In general, the formula provides an acceptable level of accuracy in dam measurements.

If there is still a discrepancy between how big you think the dam is compared to our measurement, you may get the dam surveyed by a surveyor.

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222. How can I get a map of my dam size? (Mt Barker - 19 May) These maps are used for assessment purposes by the Department for Water. Producing maps on request is not a service provided by the Department for Water or the SAMDB NRM Board. However, landholders can produce topographic maps or aerial photographs of their properties at no cost by using the NatureMaps website (www.naturemaps.sa.gov.au). This site is managed by the Department for Environment and Natural Resources.

Licensed and non-licensed purposes

223. Does a green area of grass surrounding a home as a firebreak of an area greater than 0.4 hectare count as a garden? (Mt Compass - 23 May)

Irrigating or watering an area larger than 0.4 hectare (1 acre) requires a water licence, regardless of purpose.

224. What are the definitions of stock and domestic and the difference between a commercial farm and others? (Mt Compass - 23 May)

225. You need to explicitly mention commercial use in the plan. Don’t assume that we know what you mean by it. We need to know the Board is interested in our commercial business. (Mt Compass - 30 May)

226. The word commercial enterprise has to be in here somewhere. (Mt Pleasant - 24 May)

Domestic use includes household use and watering up to 0.4 hectare of garden, and excludes water used in the course of carrying on a business (except for personal use of persons employed in the business).

Stock use means drinking water provided for stock that are not intensively kept (effectively free-ranging stock).

Intensive animal keeping means keeping animals in the course of carrying on the business of primary production in which the animals are usually confined to a small space or area, and are usually fed by hand or a mechanical means (e.g. piggeries, permanent feedlots).

Whether or not the water use is commercial is not relevant in the water allocation plan and licensing process. The prescription process deals with two categories of water use, being licensed and non-licensed use. In the Eastern Mount Lofty Ranges this means:

Non-licensed use: includes water used for domestic purposes (as above) and to provide drinking water for stock that are not intensively kept (regardless of whether it is a commercial operation or not), as well as some other specific uses like fire fighting.

Licensed use: anything that isn't non-licensed, including irrigation, industrial use, intensive animal keeping and recreational use.

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227. I am running livestock. How many would you consider domestic? (Mt Pleasant - 24 May)

Whether an activity constitutes ‘stock and domestic’ use is not influenced by stocking numbers. Stock use is defined as watering stock (other than stock subject to intensive farming) with no limits on stocking numbers.

228. You say that stock and domestic won’t be metered, what about a commercial enterprise? (Mt Compass - 23 May)

Drinking water for free-ranging stock is not licensed or metered in the Eastern Mount Lofty Ranges, regardless of whether the enterprise is commercial or not.

229. I have cattle and pigs in a feed lot. Does stock and domestic include this? (Mt Pleasant - 24 May)

The definition of stock and domestic excludes intensive animal keeping (as above). It is therefore likely that cattle feed lots and piggeries would not be covered by the definition of stock and domestic.

230. What are you going to tell the mining industry? (Mt Barker - 31 May)

Mining is a licensable water use and requires a water allocation in the same way that any other licensable water use requires a water allocation. Representatives from the mining industry have served on the community advisory committees for the draft EMLR WAP. In addition, Primary Industries and Resources South Australia (PIRSA), which is the State Government department that oversees mining, has been consulted on the draft plan.

231. I feel that this is a system that is highly convoluted and complex. It is likely that people will get frustrated and confused. I can’t find anything in the plan that says that Adelaide, industry, mining etc will have the same level of scrutiny. (Mt Pleasant - 24 May)

The draft EMLR WAP relates to the water resources of the Eastern Mount Lofty Ranges, which do not supply Adelaide. Water used for industry and mining are licensed purposes, and are subject to the same rules as any other licensed purposes in the plan (such as irrigation). See page 35 of the draft EMLR WAP for examples of licensed purposes.

232. Where do vineyards and dairies fit it? (Mt Pleasant - 24 May) They are considered as licensed use.

General allocation issues

233. How can you allocate surface water if it doesn’t rain? (Langhorne Creek - 25 May)

234. What you have put up tonight is a lot of rubbish. You are trying to regulate our water. When the water isn’t there are you going to supply it? (Mt Pleasant - 24 May)

A water allocation is a right to take a certain amount of water when it is available. It does not guarantee that that water will be available to be taken at a given time.

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235. I only have dams. If I run out of water, where do I get the water? Can I get it from a neighbour? (Mt Barker - 31 May)

That depends on the situation. If you are using the water for non-licensed purposes (e.g. stock or domestic use) then the prescription process and water allocation plan don't regulate how much water you use. If your neighbour is willing to enter into a supply arrangement, then that is up to you both.

If you are using the water for licensed purposes, then the water would need to come from within an allocation and the water sources associated with that allocation. If your neighbour has spare water within their allocation, they could consider supplying some of it to you from their sources. The use of that water on your property would need to be recognised on your neighbour's licence and would be subject to assessment under the water allocation plan (e.g. principles on assessing impact of water use on water resources and other natural resources such as soil).

Another possibility if you are using water for licensed purposes is to transfer in an allocation from another user - that is, buy the right to take water from someone else so that they stop taking water at their place, and you start taking it at your place. Transfers are subject to the rules in the water allocation plan.

236. What about animal welfare? (Mt Barker - 31 May) Where animal welfare is a factor it will be taken into account.

Existing user allocations

237. How will the water allocation for each licensed user be determined? (Mt Barker - 31 May)

238. Who makes the decision with regards to how much water I can take from my dam? (Mt Compass - 30 May)

239. How are you working out how much water we are allowed to have? (Mt Compass - 30 May)

The information sheet The Allocation of Water to Existing Users explains how the allocation volumes will be determined for existing users by the Department for Water. This sheet was distributed to existing users and stakeholders during consultation, and is available on the SAMDB NRM Board’s website at www.samdbnrm.sa.gov.au, or by phoning the Board on (08) 8532 9100.

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240. When was the survey done to get the reasonable requirement amounts and the consumptive use limit? (Strathalbyn - 26 May)

A Land and Water Use Survey commenced in late 2003 to identify all existing users within the Eastern Mount Lofty Ranges. An existing user is someone who

• Took water between 1 July 2000 and 15 October 2003 or committed significant resources towards a proposed water use prior to 15 October 2003, and

• Applied for a water licence by 8 March 2006.

See the “Water availability and limits” section for information on work done to set the consumptive use limits.

241. If water wasn’t applied for between 2001-2003 and I can show average long term use, will I be able to get a greater allocation? (Mt Barker - 31 May)

No. Details of who qualifies for an allocation as an existing user, and the methodology for allocating water to existing users, are described in the information sheet The Allocation of Water to Existing Users. This sheet was distributed to existing users and stakeholders during consultation, and is available on the SAMDB NRM Board’s website at www.samdbnrm.sa.gov.au, or by phoning the Board on (08) 8532 9100.

242. The word theoretical has been thrown around a lot. Why isn’t the data you’re using based on physical data and requirements? (Mt Barker - 31 May)

The use of theoretical crop requirement rates (plus management factors) was selected as the basis for determining the reasonable requirements of existing users following stakeholder workshops held in 2007. This approach was selected as it considers the variation in climate across the region, considers the reality of different management factors across enterprise types and is socio-economically sensitive because it has been based on the needs of commercial, rather than non-commercial users.

According to this methodology, water requirements have been determined using the internationally recognised Food and Agriculture Organisation (FAO) methodology which calculates the amount of water that needs to be applied to a crop in an average year. This is an internationally used, accepted and recognised method for determining crop water requirements.

243. Why can’t the water be allocated per hectare across the whole catchment so that the base rate stays with the land, so every paddock always has an allocation of water? (Mt Compass - 30 May)

This approach would result in redistribution on water allocations such that existing users who have a business dependent on access to water would not receive sufficient water allocation to continue their business. A central part of the prescription process is to protect the rights of existing users to continue their existing use.

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244. Does the 70% allocation limit apply to dams if seepage and evaporation losses were reduced through dam lining and use of anti-evaporation systems? (Mt Compass - 30 May)

245. You say there is 30% evaporation. What if the person can use more water because the evaporation wasn’t that much or the dam has a bigger capacity than what you say? (Strathalbyn - 26 May)

In general, it is considered that dams fill over winter and water is used over summer and there is therefore a limited volume of water available for use from dams. It is considered that in general, at least 30% is lost from a dam via evaporation and seepage.

Whilst this is the starting position for reasonable requirements from dams as it is likely to reflect actual volumes generally extracted, the Department for Water recognises that there may be exceptions to this rule (i.e. spring fed dams) and there may need to be some flexibility here.

If you can demonstrate that you can access more than 70% from your dam, possibly through the use of a dam lining or an anti-evaporation system, you will have the opportunity to discuss this with the Department during the coming ‘consultation phase’ on licensing. If the Department is satisfied that this is the case, more than 70% of dam capacity may be allocated.

246. Is the 70% on dam capacity or take? (Mt Compass - 30 May) 70% of dam capacity.

247. What happens if your allocation is capped at 70% of the estimated dam capacity, and you use this volume before the end of the season, with water still in the dam to finish off a crop? That is, there is more water available than the 70% cap. (Mt Compass - 30 May)

Once you have an allocation, it will be your responsibility to manage your water use to keep within that allocation in any particular season.

If you have water remaining in your dam once your full allocation has been taken, you may be able to obtain additional access rights through transfer of allocation from another water user, or though accessing any accumulated rollover credits.

248. How will people, who in good faith have purchased properties with allocations, be certain they will get that allocation and not have it reduced when licences are issued? (Strathalbyn - 26 May)

Considerable effort has been put into developing a process for allocating water to existing users that, wherever possible, gives landholder their full reasonable requirements for water.

In those management zones where the demand for water exceeds the sustainable capacity of the resource, licensees will be consulted with individually regarding strategies to balance demand and available water.

Where a licensee wishes to increase the volume of their allocation, they may consider the option of purchasing additional allocation from other licensees.

(On a technical note, water users in the Eastern Mount Lofty Ranges, [part from those using Angas Bremer groundwater, currently extract water under ‘authorisations’. Formal licences with allocations will be issued after the water allocation plan has been adopted.)

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249. In previous meetings you have said that we are over allocated already. Is that correct? (Mt Barker - 31 May)

The current information shows that demand exceeds the consumptive use limits in some areas, where demand is estimated non-licensed use plus reasonable requirements for existing licensed users.

250. People are saying that they are pumping now to retain the water for their licence. (Mt Compass - 30 May)

Water allocations are based on the reasonable requirements for an activity (e.g. water required for 10 hectares of potatoes) rather than usage, so there is no gain to people from pumping more water now. The information sheet The Allocation of Water to Existing Users provides additional details on the process for determining reasonable requirements. This information sheet was distributed to existing users and stakeholders during consultation, and is available on the SAMDB NRM Board’s website at www.samdbnrm.sa.gov.au, or by phoning the Board on (08) 8532 9100.

251. There is a fundamental flaw in this plan. There is nothing there encouraging conservation and less water use. People are wasting water to support their claim for a water allocation or a water license. (Mt Compass - 30 May)

Water allocations are based on the reasonable requirements for an activity rather than usage, so there is no gain to people from wasting water. Volume based allocations will encourage efficiency as the more efficient a water user becomes, the further they will be able to spread their water allocation.

The draft EMLR WAP includes policies requiring water to be used efficiently (e.g. principle 8 on page 118). The draft plan also includes rollover policies that allow users to roll a portion of their unused allocation over for use in a later water-use year. These rollover policies may encourage licensees to use less water in order to earn rollover water.

252. I run beef cattle but I want to grow vegetables. I can’t do this because I can’t get a water licence when I have plenty of water that I am not using. We are doing everything right and are being penalised for it. (Mt Compass - 30 May)

By taking more water out of your dam(s), you would increase the amount of water that needs to flow into your dam(s) before it fills and spills. This additional amount would reduce the volume of water available for use by downstream users.

One possible mechanism to obtain an allocation may be to purchase (or lease) allocation from another landholder, subject to the rules in the water allocation plan. For further information on water transfers, see the information sheet Allocation and Transfer Policy Overview (available at www.samdbnrm.sa.gov.au or by telephoning the SAMDB NRM Board on (08) 8532 9100), or call the Department for Water on 8463 7007.

253. Is the theoretical enterprise requirement an annual allowance? (Mt Compass - 30 May)

Yes.

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254. When we get our allocation will it stay fixed? (Mt Compass - 30 May)

Water allocations will be a fixed volume of water that can be taken each year.

As monitoring improves our knowledge of the resources, the amount of water available for allocation may be reviewed in the future.

255. Is my water allocation secure from season to season? Especially in a wet year like this year where we did not irrigate any pastures. Would the allocation be changed because in some years we did not use up to the allocation? (Mt Barker - 31 May)

The allocation will be a right to take a set annual volume. It is not expected to vary season to season. There is some capacity to provide for flexibility to increase the available allocation between years through the allowance of the rollover of up to 10% of unused water from the previous year.

256. What if I want to change from a low water use to a higher water use crop? I am concerned that I will be locked into an allocation applicable to a lower use. (Mt Compass - 30 May)

Once allocations have been finalised, they will be expressed as an annual volume of water that can be taken. There will be no restriction to a particular crop type or area.

257. Will there be an opportunity to discuss and negotiate the allocation split between resource types? (Mt Compass - 30 May)

Yes. The Department for Water is currently finalising the reasonable water requirements of existing users, particularly for industrial and commercial water uses. It is expected that in early 2012, the Department will be writing to existing users detailing their proposed allocation and providing existing users the opportunity to discuss their allocations and the volumes assigned to their water resources, particularly for multi-resource users.

258. How will you allow for variable dependencies between resources? (Mt Compass - 30 May)

259. Will you give consideration to the use of back-up water supplies, given the significant investment in these supplies? (Mt Compass - 30 May)

There will be an initial split of allocation between different resources. It is expected that in early 2012, the Department will be writing to existing users detailing their proposed allocation and providing existing users the opportunity to discuss their allocations and the volumes assigned to their water resources. This will provide the opportunity to refine this split.

The consultation process described above will provide the opportunity to ensure that all relevant sources, including back-up sources, are included on water licences.

There is also the capacity in the draft EMLR WAP to allow the ‘rollover’ of up to 10% of unused allocation from one year, allowing that allocation to be taken in the subsequent year(s). The draft plan also includes transfer policies, which may allow users to buy extra water allocation from willing sellers to provide additional back-up water supplies.

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Metering

260. Are you going to provide people with a list of what meters comply with the specifications? (Mt Barker - 31 May)

Currently there is no comprehensive list of complying meters. Any meter that meets the SA Licensed Water Use Meter Specification can be used. Under future national metering specifications, it is likely that there will be a process in place for validating or approving particular meters, at which time it should be possible to provide details of complying meters.

261. What happens to existing meter installations that are not consistent with the future meter installation guide? I refuse to install any further meters or change the current installation. (Mt Compass - 30 May)

If any installations that are approved under the existing State specifications are subsequently deemed to be non compliant under any future federal standards, there will be a ‘grandfathering’ provision put in place to allow these installations to be altered over a period of time bringing them into line with the new standards.

262. Are you aware that if you place a meter on something then you are subject to calibration? How are you going to deal with calibration? (Mt Barker - 31 May)

Yes, it is known that flow meters require periodical checking to ensure they retain calibration. This is an issue which will need to be considered as part of a meter implementation plan for the area.

263. Where is it declared in legislation to require metering? (Mt Compass - 30 May)

264. Is there a requirement for metering? Where does this requirement come from? (Strathalbyn - 26 May)

265. Why meter use from dams when the allocation is capped at 70% of the capacity? (Mt Compass - 30 May)

266. Would it make better sense to licence the capacity of the dam and allow the flexibility to take what you want from a given dam? (Mt Compass - 30 May)

All Australian governments have committed, through the National Water Initiative Agreement, to the implementation of nationally consistent non-urban water metering standards. This agreement includes a requirement to meter licensed water sources, which includes dams.

This position is also reflected in the South Australian Licensed Water Use Meter Specification.

267. Will there be flexibility to delay metering on complex situations? (Mt Compass - 30 May)

Yes. Metering of sources has been a phased program and there is flexibility for longer timeframes for complex installations. A number of water users have already been granted extended timeframes for meter installation for a number of reasons such as financial hardship, large numbers of meters and complexity of installations.

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268. No consistency. We have a meter, others are years away. Neighbours pumped for 6 months to go top green for aerial photos to sell property. (Mt Barker - 31 May)

In the Eastern Mount Lofty Ranges, water users have been progressively directed to install meters as their Authorisations have been issued.

This has been a phased process, and approximately 50% of sources have been confirmed to be metered. Of the remainder, a number have been granted an extension of timeframe for metering.

269. I have a multipurpose dam, where do I stand in regard to metering? How do you work out how much is used for stock and domestic? (Mt Compass - 23 May)

270. How do I manage joint use of a dam for stock, domestic and irrigation? How will it be measured, metered etc? (Strathalbyn - 26 May)

The Department for Water is aware that many users access stock and domestic water and irrigation water from the same water source.

It is difficult to come up with an easy answer to this given that each setup is different, and in a lot of instances it may not become a problem as the stock and domestic use is considered minor in relation to the irrigation water.

One option is to separately meter the stock and domestic water and deduct that from the meter reading from the source. Another option is to account for the water via estimates or other means.

The benefits of accounting accurately for your stock and domestic usage include being able to calculate accurate rollover, and also to ensure that you don’t exceed your water allocation (which can incur penalties) because of stock and domestic water going through the same meter.

The Department is currently working on strategies to ensure that non-licensed water is not counted towards the licensed water measured. Further information on options for this will be available in a future user guide for meter installations.

271. Can you slap a meter on my stock and domestic stormwater? (Mt Pleasant - 24 May)

There is no requirement for stock and domestic water use to be metered.

272. When will you start reading meters and how will the Department deal with accessibility issues? (E.g. permissions to enter and other access issues (gates, livestock, dogs)). (Mt Compass - 30 May)

273. Who reads the water meters? No one in this room would be licensed to read the meters. (Mt Compass - 30 May)

In the Eastern Mount Lofty Ranges, further consideration needs to be given to what meter reading program would need to be put in place giving consideration to issues such as frequency of reading, access to meters for reading etc. An answer to this question would be resolved as part of this consideration.

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274. Does the entire NRM Board agree with metering from dams? It is suggested that several members did not agree. (Mt Compass - 30 May)

Metering is managed by the Department for Water.

Costs

275. I am a River Murray water user and we had to buy the meters ourselves. Are you telling the people here tonight the price of a water transfer and the levy on water? Will this all happen in the Eastern Mount Lofty Ranges? (Mt Pleasant - 24 May)

276. We want to know and should be told up front of the full cost of licensing, such as licence fees, metering, levies etc. (Mt Compass - 30 May)

277. What is the cost? Application = $159, pipe work = $250 - $1500 /m plus installation and labour. (Mt Compass - 30 May)

278. What are the future costs going to be? (Mt Pleasant - 24 May)

279. On 20/10/05 I paid $159.50 for a water licence and was told by letter that licences would be issued in 2-3 years time. How do you come at the price of water? (Mt Barker - 31 May)

Water levy: The annual water levy rate for 2012-13 is proposed to be $5.30/ML of water allocated. This rate is expected to increase in the future by CPI at a minimum.

Returning low flows: The costs for installing devices to return low flows are expected to be shared between water users and secured funding sources. The Department for Water and the SAMDB NRM Board are seeking external funding to assist with this process, so the cost sharing split cannot be determined until such funds are secured. The cost for devices to return low flows is highly variable, depending on the landscape, type of infrastructure and design of the low flow bypass device.

Licence applications: Water users have already made application for a water licence. This was a once off administrative fee of $159.50 at that time. There are no additional ongoing licence fees.

Transfer costs: The cost for an application to transfer a water licence is $371 plus a technical assessment fee of $249 (as of 1 July 2011). When water is transferred between two licensees, the cost of that water is set by the person selling the water, as occurs when other assets are sold.

Metering: costs for metering are discussed later in this section.

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280. How much is the cost per kilolitre? How will we be charged for our allocation? (Mt Barker - 31 May)

The annual water levy in the SAMDB NRM region for 2012-13 is proposed to be 0.53 cents/kL of water allocated, which equates to $5.30/ML.

The levy rate is proposed each year by the NRM Board through their business plan, and

consulted upon with the community during consultation on the business plan. The NRM Board

then seeks approval for the levy rate from the Minister for Environment and Conservation. If

there is a new levy (eg for a new area where licences have been issued for the first time) or any

levy increase is above the CPI, the levy needs to be endorsed by the Natural Resources

Committee of Parliament (the Committee is made up of a mixture of members from both

major parties, minor parties and independents). Once the Minister adopts the final levy rate, it

is published in the South Australian Government Gazette.

Following licence issue, the Department for Water will send out annual levy notices to licence holders. The amount payable annually is the levy rate multiplied by the licensed allocation. The levy is to be paid to the Department and then the Department for Water transfer it to the NRM Board.

281. The water costs $5.30/ML. Will that go up with CPI? (Mt Barker - 31 May)

282. What is the forward projections for increases in the $5.30/ML levy? (Mt Compass - 30 May)

The water levy rate is expected to increase by CPI at a minimum. The levy rate is consulted upon with the community during consultation on the SAMDB NRM Board's business plan.

283. Why is the South East only charged $2/ML? (Mt Barker - 31 May) Each NRM region sets its own levy rates for prescribed water resources in their region to reflect the requirements to contribute to funding their Regional NRM Plan. The levy rate is consulted upon and adopted by the Minister as outlined above.

Water levy rates for irrigation use in 2011-12 range from $2.51/ML to $24.50/ML in different prescribed areas, with the rate in the SAMDB region for that period being $5.15/ML of water allocated.

284. We were told initially that we are going to be charged a levy. Is it a levy on usage or on full allocation? (Mt Compass - 23 May)

The annual water levy raised by the SA MDB NRM Board is charged on the volume allocated, not the volume used.

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285. What will the levies be spent on? (Mt Compass - 30 May) The draft EMLR WAP recommends a range of monitoring activities, annual water use reporting and continual review of information. The costs of undertaking and managing these activities will be primarily met via the water levy.

The levies collected will also contribute to funding the programs set out in the SAMDB NRM Board's Regional NRM Plan, which includes a wide range of programs over the key assets of people, water, biodiversity, land and atmosphere. The Board's Regional NRM Plan is available on our website (www.samdbnrm.sa.gov.au).

286. If we have to start paying a water levy, what happens to the levy we are currently paying to the Murray? (Mt Barker - 31 May)

The "Save the Murray" levy funds a separate program to contribute to the health of the River Murray, managed by the Department for Water. Paying a water levy to the SAMDB NRM Board does not affect the requirement to pay the Save the Murray levy.

287. Why do licence holders have to pay for that part of their water allocation that they do not use? (Mt Barker - 31 May)

288. If we don’t use all of our allocation then we still have to pay for it. That is grossly unfair. (Mt Barker - 31 May)

289. The cost of water is going to be $5.30/ML. If my allocation is 200 ML and I only use 120 ML then I have to pay for the 80 ML of water that I didn’t use. We are paying for water that we aren’t using to support the rest of the state. (Mt Compass - 30 May)

290. You should only be charged for the water that you use. In metropolitan Adelaide they only pay for what they use. (Mt Compass - 30 May)

291. Unless you guys own the water, then how can you charge us for it? Our land captures it. Why aren’t you trying to help us? (Mt Compass - 30 May)

292. Don’t charge farmers for water you don’t own. We have to pay enough for water licences and pumping costs land etc. Why do you think you have the right to charge irrigators for water that they have bought the right to use? (Mt Compass - 23 May)

The water levy is not a charge on water use. The purpose of the water levy is to contribute to the funds required to implement the SAMDB NRM Board's Regional NRM Plan to assist sustainable natural resources management in the region. The EMLR WAP will be part of the Regional NRM Plan, and levy funds will contribute to a range of monitoring activities, annual water use reporting and continual review of information recommended in the EMLR WAP.

The NRM Act gives NRM Boards the ability to collect a water levy for water allocated in prescribed areas.

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293. How much are the meters going to cost to run? (Mt Barker - 31 May)

294. I was required to put a meter on in 2007. The cost was about $800. (Mt Barker - 31 May)

The cost of meters varies widely and depends on the type of meter and pipe size. For example, for a standard mechanical two inch meter with a straightforward installation, the cost of the meter and installation could be as low as $300 - $400.

However as pipe size increases, the cost of both meters and installation will increase. For example, installation of a meter into six inch pipework with a more complex installation is likely to cost over $1000.

There are also more sophisticated meters on the market such as electromagnetic and ultrasonic meters which have a higher starting price, but which provide greater flexibility for installation, reading and data management. At larger pipe sizes, these meters also become increasingly price competitive.

295. Are we going to be charged for meters? (Mt Pleasant - 24 May) Holders of water licences will need to meter their water use. In order to do this they will need to purchase a water meter that meets particular specifications. There is a range of water meters that meet the specifications.

296. What is the cost to read the meters? (Mt Barker - 31 May) There is no set cost to read a meter. Currently in other prescribed areas, the department reads meters at regular intervals as part of their ongoing business.

In the Eastern Mount Lofty Ranges further consideration needs to be given to what meter reading program would need to be put in place giving consideration to issues such as frequency of reading, access to meters for reading etc.

297. If a food producer cannot afford the costs of metering, is that considered to be non-complying under the NRM Act? (Mt Compass - 30 May)

As discussed above in the “Metering” section, there will be flexibility in metering timeframes so people having difficulty will have time to get sources metered.

298. What is the estimated cost of managing the plan (ongoing)? (Strathalbyn - 26 May)

The draft plan recommends a range of monitoring activities, annual water use reporting and continual review of information. The costs of undertaking and managing these activities will be primarily met via the water levy.

299. Will there be concessions to pensioners such as SA Water provide in metropolitan areas (Mt Compass - 30 May)

There are no concessions of this nature.

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300. What are the ‘fines’ costs? (Mt Compass - 30 May) When a licensee takes water in excess of their volumetric allocation, a penalty charge per kilolitre is incurred. There are two categories of penalty charges:

a) for taking water in excess of a water allocation, but less than 10% in excess, and b) for taking water more than 10% in excess of a water allocation.

The penalties for (b) are substantially higher than for (a). The actual penalty varies from resource to resource due to differences in the value of water in different prescribed water resources areas. The penalties are published each year in the South Australian Government Gazette. The actual penalties that will apply to the Eastern Mount Lofty Ranges when licences are issued have not yet been determined.

That gazette notice also sets out a penalty per kilolitre for taking water without a licence, which is substantially higher again than the penalty for (b).

In addition, the NRM Act contains a number of offences for which a financial penalty may be incurred. These include such matters as breaching licence conditions, erecting a dam without a permit or interfering with a water meter. For minor breaches a warning may be given, or an expiation may be issued. Expiation fees for water related offences currently range from $250 to $750 depending on the type of offence. For serious breaches, the case is heard by a Magistrate. If the Magistrate finds a person guilty they may impose a financial penalty. The maximum penalty under the NRM Act for a water related offence is $70,000 if the offender is a body corporate or $35,000 for an individual. Where the offence includes taking a volume of water without a licence, and the per kilolitre penalty fee is greater than the maximum penalty, the per kilolitre penalty may apply.

301. There is probably not one person here who is against prescription. Also not one person here would not be an environmentalist. However I am concerned about the cost. We can’t afford it. The government should be footing this cost. (Mt Barker - 31 May)

302. How much has the government submitted to landowners for construction of things we have there now? They have submitted nothing. Now they expect us to pay more. (Mt Compass - 23 May)

303. I am a large water user and $5.30/ML is virtually nothing compared to other costs such as electricity. (Mt Compass - 30 May)

304. If this plan gets through then all we are doing is paying taxes to the labour government. (Strathalbyn - 26 May)

305. All infrastructure costs must be 100% footed by government, as this is not to be borne by farmers. It is a national expense - we can’t afford this! (Mt Barker - 31 May)

306. Concerned about the levy cost. (Mt Barker - 31 May)

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Consultation process

307. Do we get charged to receive a copy of the plan? (Strathalbyn - 26 May)

There is no cost to you to receive a copy of the draft EMLR WAP.

308. Are there other water meetings in the future, and how will we know about them? (Mt Compass - 23 May)

309. It could or would be a good idea perhaps to have a local meeting in the Wistow region. (Mt Barker - 19 May)

Five public meetings on the draft EMLR WAP were held and have been advertised in local papers and in mailouts to stakeholders. The SAMDB NRM Board has hosted 10 local-scale "shed meetings" on request, advertising the opportunity to request a meeting in the local papers.

310. Why did some people get invitations for tonight’s meeting and some didn’t? (Mt Compass - 23 May)

The SAMDB NRM Board set initiations for two meetings to people believed to have a stock and domestic dam that is 5 ML or more. If you didn’t receive an invitation, then, according to the data that we have, you didn’t fit this criteria. A further five public meetings were provided to discuss the draft EMLR WAP in general

311. Why are the eastern zones having meetings and the westerns are not? (Mt Compass - 30 May)

Consultation meetings on the draft Western Mount Lofty Ranges (WMLR) Water Allocation Plan were held in November - December 2010. Please contact the Adelaide and Mount Lofty Ranges NRM Board on tel. (08) 8271 9100 for information on the draft WMLR Water Allocation Plan.

312. I don’t believe the Department will take any notice of people’s concerns. (Mt Barker - 31 May)

The SAMDB NRM Board is committed to seeking the wider community’s views on the draft policy and will consider all submissions.

313. What have you got out of this meeting from us? (Mt Barker - 19 May)

Sharon Starick, Presiding Member, SAMDB NRM Board: There have been a number of questions and concerns about low flow bypasses and what it means for you. There have been suggestions for things that are not written in the draft plan such as a holistic approach. We have also been asked if we can look at reducing dam sizes - this is currently not a policy but has been suggested.

Colin Milburn, SAMDB NRM Board member: Concerns about hoarding of water with excessive dam capacity on properties, and reduction of dams. There are a lot of people who have a dam under 5 ML who will voluntarily put in a low flow bypass and this needs to be considered.

Ceris Crosby, Ranges to River NRM Group: Concerns about letting animals trash the creeks.

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314. The Board is now attempting what it should have commenced years ago - explaining why the WAP is important to the community. I am sure that quite a few people did not realise that Mount Pleasant is not in the MDB. This should have been explained at the start. There should be a realistic statement up front of what could eventuate without a WAP. (Mt Pleasant - 24 May)

Public consultation was undertaken at the start of the process in 2003, and the SAMDB NRM Board has also distributed a number of newsletters on the water allocation process to date.

315. Truth, trust and common sense is not there. We don’t trust the NRM Board. (Mt Compass - 23 May)

316. Truth, trust and common sense. (Langhorne Creek - 25 May, Mt Compass - 30 May)

317. The process is good. You need to keep coming back to local communities and show them the new data and keep talking to them. (Langhorne Creek - 25 May)

318. Actually listen to the people and get the answers right. (Mt Pleasant - 24 May)

319. Apples being grown at Harrogate is something that does not give any confidence to the hostile meeting. They already suspect that you don’t know what you are talking about. Please use an illustration that is useful to the cause. (Mt Pleasant - 24 May)

320. Honesty, justice, open listening – democratically. (Mt Pleasant - 24 May)

321. Less glossy brochures and more facts. (Mt Pleasant - 24 May)

322. Presentations need to be explained in simple English. (Mt Pleasant - 24 May)

323. There is animosity between Landcare groups, NRM groups and farmers. It is very sad that NRM groups have got so many people offside. We can’t fully trust you. We cannot be assured by this plan. (Strathalbyn - 26 May)

324. We have a right to freedom of speech and public servants will answer our questions. (Strathalbyn - 26 May)

325. ROPES [meeting rules] needs to be fully understood. (Mt Barker - 31 May)

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Water issues outside scope of Eastern Mount Lofty Ranges prescription

326. What is the law that has excluded water from land? (Mt Compass - 23 May)

Under the Council of Australian Governments Reform in 1994, a national water reform policy was adopted which included water rights being separate to land rights and the ability of water to be traded.

In 1996, an amendment to the regulations under Water Resources Act 1990 effectively separated water rights from land rights in South Australia.

This policy was continued at a state level through the Water Resources Act 1997, which has now been replaced by the NRM Act.

This means that water rights are personal property and are separate from land, and the right to take this water can be transferred away from the land to be taken at another location subject to transfer rules in any applicable water allocation plan.

327. It has been acknowledged that we had no drought. Are you aware of this? It was a result of the over allocation of the River Murray. (Mt Pleasant - 24 May)

It is widely recognised that there have been some dry times in the last 10 years in the Eastern Mount Lofty Ranges. Over-allocation in the River Murray is generally not likely to affect water resources in the Eastern Mount Lofty Ranges, except at the lower end of catchments where they meet the River Murray and Lake Alexandrina.

328. What happened in the Peake and Sherlock area? (Mt Barker - 31 May)

New intensive groundwater extraction led to decreasing groundwater levels, which affected the ability of local stock and domestic users to access water from their bores. A water allocation plan has been developed for the area to provide for more equitable sharing and sustainable management, and the SAMDB NRM Board has provided funding to help affected stock and domestic users deepen their bores.

329. We also want Queensland, New South Wales and Victoria to pass flows through to South Australia. (Mt Barker - 19 May)

The Basin Plan under development by the federal Murray-Darling Basin Authority aims to bring water use in the basin to within sustainable limits. It is understood that the draft Basin Plan will be released for consultation later this year, providing an opportunity to make submissions on passing flows to South Australia from upstream states.

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330. Do reservoirs have to put in low flow bypasses? (Mt Compass - 23 May)

There are no public water supply reservoirs in the Eastern Mount Lofty Ranges area.

It is not proposed that reservoirs in the Western Mount Lofty Ranges will need to put in low flow bypasses. However, the draft water allocation plan for the Western Mount Lofty Ranges proposes that SA Water release up to 15 GL of environmental flows annually from its reservoirs. The Department for Water will negotiate with SA Water to ensure the timing and location of these releases has maximum benefit for downstream ecological assets.

331. In the 1900s the government provided us with wells and we didn’t pay for water. The government took on that responsibility. Why don’t they now? (Mt Compass - 23 May)

Government policies generally try to balance the benefit to the community against costs. As the context of policy changes (in this case many wells have been constructed) then the balance between benefit and cost changes and the policy is changed to reflect the new circumstances.

332. If you’re so concerned about the security of everyone’s water then why are you allowing overseas investors to come in and buy huge amounts of land? (Mt Compass - 30 May)

333. If you’re so serious about our precious water then stop the sale of it to overseas. (Mt Compass - 23 May)

334. What about multi-nationals and nationals buying excess water? (Mt Pleasant - 24 May)

335. How much water is available for you to sell to overseas investors? (Strathalbyn - 26 May)

336. Why have you capped the Bremer River when people can sell water interstate and overseas? (Mt Barker - 31 May)

The purpose of the water allocation plan and licensing process is to provide for sustainable capture and use of water. Policy on foreign ownership of assets is a Federal Government issue.

337. With all the concerns regarding water availability, why is the Australian Government encouraging population growth? What efforts have been made to curtail population growth and to ensure that those who make decisions regarding population growth are made aware of the water shortage / restrictions and the impact on food production? (Mt Barker - 31 May)

It is beyond the scope of the water allocation plan and licensing process to address Commonwealth population policy.

There are a range of State Government strategies to build consideration of water resource availability into population growth decisions. For example, the Greater Adelaide 30 Year Plan includes targets to minimise the use of water in growth areas through water sensitive urban design, and use of alternative water supplies. The State Government water security plan, Water for Good, includes actions to reduce demand on potable water supplies and to identify and develop stormwater harvesting and recycling projects.

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338. If the Board manages the water then are you going to be responsible for erosion, corrosion and flooding? (Langhorne Creek - 25 May)

The prescription and water allocation planning process sets up a system for allocating and transferring water entitlements and regulating water affecting activities. Control of erosion, corrosion and flooding is outside the scope of this process.

Other NRM issues

339. There needs to be a holistic approach. Other properties are not worried about the environment. Why should I let 10% of water go when there is stock from other properties [defecating] in it? (Mt Barker - 19 May)

340. Are you relying on the goodwill of the landholders to do things like fencing their property to keep stock out of watercourses? (Mt Barker - 19 May)

The water allocation plan can only deal with the taking and use of water, and specific water affecting activities that are identified in the NRM Act. Stock in watercourses is not identified as a water affecting activity under the NRM Act.

The SAMDB NRM Board's Regional NRM Plan includes targets for protecting and restoring watercourses, achieved through Board sponsored incentive payments and education and awareness programs. The Board works with community groups such as the Local Action Planning Associations to achieve this. This work complements the work by landholders, groups and other agencies in managing and protecting watercourses.

The holistic approach is a good idea and is something to be explored as part of development of an implementation program for returning low flows.

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341. What are you doing about the noxious weeds that are growing everywhere? (Mt Compass - 30 May)

342. You will have to have weed management as well, otherwise there is no point. (Mt Compass - 30 May)

343. You say that the plan is underpinned by returning low flows. What if your dam is passing all that low flow to a noxious weed area? Shouldn’t we be doing something about all the noxious weeds in our creek lines? (Strathalbyn - 26 May)

344. Concerned about the lack of persistence with noxious weeds i.e. Blackberry. (Mt Compass - 30 May)

The water allocation plan can only deal with the taking and use of water and specific water affecting activities, not weed issues.

The SAMDB NRM Board's Regional NRM Plan includes targets and actions for addressing weed issues. The Board supports a range of programs working with the community and other stakeholders and agencies to address weed issues, including:

Detection and early management of new pest incursions, including implementation of a rapid response program for new pests and diseases, and establishment of an enthusiastic, well informed network of people willing to undertake pest surveillance and management

Managing the impact of established pest plants, including:

o awareness, education and training of landholders

o working with other agencies on implementation of an intervention scheme using subsidies and incentives for high priority pests

o implementation of operational programs for the management of priority pest plants in each NRM region

o collecting information on priority pest distribution and monitoring effectiveness of control programs to inform best practice pest management

345. Can the plan be scrapped and have qualified people to draft the plan with emphasis on eliminating weeds and cleaning up the watercourses? This will alone go a long way in sustaining both farms and the environment. (Strathalbyn - 26 May)

The water allocation plan can only deal with the taking and use of water and specific water affecting activities, not weed issues or cleaning up watercourses.

The SAMDB NRM Board's existing Regional NRM Plan includes targets and actions for protecting and restoring watercourses and for managing pest plants and animals, as outlined above.

346. Do you think farmers are responsible managers of their own land? (Mt Compass - 30 May)

Yes, in general.

The water allocation plan and licensing process provides a way for water, which is a shared resource, to be managed for the benefit of all users (including the environment).

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347. How can people trespass on my property without my permission? (Mt Compass - 23 May)

As a matter of general practice and courtesy, the vast majority of landowners are contacted prior to any property visits.

However, the NRM Act gives Authorised Officers the power to enter property, but only when required in connection with administration or enforcement of the Act. Authorised Officers cannot exercise their powers in relation to a person’s home, other than with the authority of a magistrate’s warrant (or at the invitation of the owner).

In some cases, property visits may not be pre-arranged when the visit is undertaken to seek evidence of criminal behaviour, such as theft of water, breaches of orders or other instances of serious and ongoing non-compliance.

348. What are the ramifications of refusing entry to an NRM Officer to my property? (Strathalbyn - 26 May)

An Authorised Officer has the power to enter any place as may be reasonably required in connection with the administration, operation or enforcement of the NRM Act. An Authorised Officer may only enter residential premises at the invitation of the owner or with a warrant. NRM officers who are not Authorised Officers do not have any specific authority to enter a property.

The NRM Act provides a range of actions that may be taken in order to carry out the administration, operation or enforcement of the Act. Which particular action was taken would depend on the circumstances and the reason for the Authorised Officer attempting to enter the property. For example if the reason was to read a water meter or collect a sample for salinity testing, then the next step may be to negotiate with the landholder by letter or telephone. A different approach may be taken if the landholder was suspected of seriously breaching the NRM Act, and may include seeking a warrant to enter the property from a magistrate.

The NRM Act also includes a provision that makes it an offence to hinder an authorised officer.

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349. There are occupational health, safety and welfare issues when accessing properties. Who does the liability and chain of responsibility sit with? (Mt Compass - 23 May)

The responsibility for occupational health, safety and welfare issues, in terms of NRM Board or Department for Water staff, lies with the employer of those staff when accessing properties in the course of work duties. When NRM Authorised Officers are working in line with regulations and duties of the NRM Act, then liability for an act or omission made in good faith lies with the Crown. The SAMDB NRM Board’s and the Department’s NRM Authorised Officers have completed training on lawful or reasonable procedures in line with the NRM Act, and also operate within a range of Safe Work Instructions and Board and Departmental policies when accessing properties.

Ultimately, all people have the same common law duty of care in terms of liability for acts or omissions, including both landholders and people entering property.

350. How does the Board ensure there is no disease spread when accessing properties? What guarantee can the Board give us that their vehicles are clean? (Mt Compass - 23 May)

351. If you had a highly contagious disease, would you go out in public? Why are you allowed to go on my property with diseases on your vehicles? (Mt Compass - 30 May)

As a matter of general practice and courtesy, the vast majority of landowners are contacted prior to any property visits and can discuss concerns about managing the spread of pests and diseases at the time.

In addition, NRM Officers from the SAMDB NRM Board hold pest management technician licences and work under related legislative requirements. The Board’s NRM Officers undertake training in farm and equipment hygiene procedures, and use decontamination equipment and procedures following visits to properties with a recognised biosecurity risk. In other circumstances, the Board’s NRM Officers are required to perform a standard check when accessing a property which includes checks on transport of pests.

352. How many NRM Boards are there in the Eastern and Western Mount Lofty Ranges? (Mt Compass - 23 May)

There are two NRM Boards in these regions. The Western Mount Lofty Ranges is covered by the Adelaide and Mount Lofty Ranges NRM Board. The Eastern Mount Lofty Ranges is covered by the South Australian Murray-Darling Basin NRM Board. South Australia has eight NRM Boards in total.

353. What Board are we talking about? (Mt Pleasant - 24 May) The South Australian Murray-Darling Basin Natural Resources Management Board is responsible for the development of the draft Eastern Mount Lofty Ranges Water Allocation Plan. The Adelaide Mount Lofty Ranges Natural Resources Management Board is responsible for the development of the draft Western Mount Lofty Ranges Water Allocation Plan.

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354. This is all as a result from input from your Board members. Many of them don’t really know anything. They are hobby farmers. NRM has become a South Australian empire. How did you find and choose your Board members? (Mt Compass - 23 May)

355. Who really wrote the first draft? MDB members? Some UN think tank? (Mt Pleasant - 24 May)

The draft EMLR WAP has been developed by the SAMDB NRM Board in consultation with community advisory committees made up of local people using water for a range of industries, and also with input from technical experts from a range of fields.

NRM Board members are selected through an open call for members advertised through local papers as well as the Advertiser and Stock Journal. The Minister appoints Board members on the basis of relevant skills and expertise.

356. What are the qualifications of the official people here tonight? What are the qualifications of the people on the Board? (Mt Compass - 23 May)

Qualifications of SAMDB NRM Board and Department for Water staff present at the meeting include business management, science, environmental management and a range of NRM qualifications.

Board members are selected on the basis of relevant skills and expertise. Enterprises that current SAMDB NRM Board members are involved in include olive production and processing, community engagement, sheep and beef cattle production, economic development in Aboriginal communities, citrus and winegrape production, local government, business administration, viticulture, dryland cropping and piggeries.

357. Why do the NRM believe themselves to be of any use to anyone? (Mt Compass - 23 May)

358. How come we have so many people employed talking so much [rubbish]? We didn’t need NRM in the 1900’s, why do we need NRM now? Why do we have so many people paid now to manage the environment when we don’t need it? (Mt Compass - 23 May)

The SAMDB NRM Board provides support to the community and industry to assist achieving sustainable natural resources management through provision of funding, technical support, coordination, capacity building, and contributing to regulatory systems to help manage shared resources for the benefit of the whole community.

359. How many staff on the NRM? How much does it cost taxpayers each year? How do you fill in your days? Why do you drive two cars of people to a dam inspection? (Mt Compass - 23 May)

360. How much money has gone to the environment? (Mt Compass - 30 May)

As outlined in the SAMDB NRM Board's 2011-2014 business plan, the Board's staffing resources are 82.5 full-time equivalent positions in 2010-11. The business plan outlines that the Board's budget for 2011-12 is approximately $16.4 million, derived from a range of funding sources (business plan is available on the Board's website at www.samdbnrm.sa.gov.au).

Board members and staff work with the community, government and industry to assist achieving sustainable natural resources management.

The Board are not aware of cases where two cars of people have driven to a dam inspection, and this is not usual practice.

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361. How many NRM Officers are there in the western and southern region? (Mt Compass - 23 May)

There are currently eight field NRM Officers who work in the “Ranges to River” sub-region of the SAMDB NRM region, which includes the Eastern Mount Lofty Ranges as well as the Murray Plains either side of the River Murray south of Swan Reach.

362. Who here tonight is being paid by the NRM? (Mt Pleasant - 24 May)

The Board staff and members present, plus the facilitator.

363. Are you aware of the Public Sector Act 2009 and the code of ethics for the South Australian sector? (Mt Barker - 31 May)

Yes.

364. The presenters should have knowledge of the proposed government amendments to the NRM Act. (Strathalbyn - 26 May)

The current consultation process is on the draft EMLR WAP, and the presenters at the meetings are there because of their knowledge of the draft plan and associated licensing process. Your local MP should be a contact for the detail of any proposed amendment to the NRM Act.

365. Spring fed, high rainfall land conveyed to intensive housing. Shame! (Mt Barker - 31 May)

366. Everyone who owns land knows how to look after the environment better than NRM and they do. (Mt Compass - 23 May)

367. Has the Water Board payed off the NRM Board in a back door deal? (Mt Compass - 23 May)

368. I have spent many dollars on keeping my property weed and disease free and as a result do not allow any vehicles on my property. (Mt Barker - 31 May)

draft eastern mount lofty ranges water allocation plan public

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