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The Flinders Ranges Council

SA Water Regulatory Determination 2020 (SAW RD20) -

Regional Water Aesthetics – Quorn, Wilmington and Melrose

2 The Flinders Ranges Council Submission - SA Water Regulatory Determination 2020 (SAW RD20) - Regional Water Aesthetics – Quorn, Wilmington and Melrose

CONTENTS INTRODUCTION .................................................................................................................. 3

Background Information .................................................................................................... 4

Quorn Water Quality .......................................................................................................... 5

Expected Water Quality Improvements .............................................................................. 6

SA Water Prioritisation Process ......................................................................................... 8

COMMUNITY FACILITIES AND INFRASTRUCTURE .......................................................... 9

RESIDENTIAL PROPERTIES ............................................................................................. 10

LOCAL BUSINESSES ........................................................................................................ 13

COMMUNITY CLUBS, GROUPS AND ORGANISATIONS ................................................. 13

TOURISM AND ECONOMIC DEVELOPMENT ................................................................... 14

CONCLUSION .................................................................................................................... 15

LETTERS OF SUPPORT .................................................................................................... 16

CONTACT .......................................................................................................................... 16


INTRODUCTION The following submission is forwarded to the Essential Services Commission of SA (ESCOSA)

in response to the draft determination SAW RD20 with specific emphasis on “A3.6.2.3

Regional Water Quality Improvement Program” and the draft decision by ESCOSA to remove

the $24.8million in proposed improvements for regional water quality.

SA Water in their “Our Plan 2020-24” proposed capital expenditure of $24.8 million during

SAW RD20 to improve water aesthetics in regional towns. The expenditure proposed covered

the connection of Melrose, Wilmington and Quorn with supply from the River Murray at

Booleroo via a 90 kilometre pipeline; construction of a desalination plant at Naracoorte; and,

minor improvements at Swan Reach, Morgan, Nangwarry and Cadell.

The decision by ESCOSA noted that the reason for the removal of the projects are that:

“While the program and level of expenditure are broadly supported by customers, SA Water

has not established a long-term program for regional water aesthetic upgrades (the need for

which was identified at SAW RD16), or a clear line of sight between its proposed infrastructure

projects and the improvements customers should expect.”

Our submission is that Quorn, Melrose and Wilmington be reincluded in the plan as a priority,

on the basis that sufficient prioritization and long term planning has occurred for the next four

years and that a clear line of sight between the projects and the improvement customers can

expect does exist.

It is noted that these three communities have been identified as a priority through a thorough

assessment process by SA Water. Council has been advised by SA Water that the process

that identified these towns as the priority for upgrades used multiple criteria, including social,

technical and financial inputs. For example, the social criteria incorporated customer research

that had been conducted with residents of regional towns, including Quorn, as well as

complaints data, again including feedback from Quorn customers.


It is also noted that a clear line of sight exists between the proposed project and the

improvements customers could expect. The expected water quality improvements are well

known, with a similar connection having recently been completed for Orroroo. The water

supplied to Orroroo after this connection, when compared with drinking water in Quorn,

identified that the aesthetic areas of concern would improve between 615% and 1200%, these

improvements are summarised below.

Therefore it is Council’s position that the two requirements above have been met, further, the

draft determination by ESCOSA identified that these improvements and the level of

expenditure were broadly supported by customers and that the evidence provided by SA

Water included willingness to pay research to inform SAW RD20 and this research found the

majority of customers would accept project costs of $25million to improve water aesthetics in

three regional towns.

Background Information Quorn, situated in the Flinders Ranges and governed by The Flinders Ranges Council, has a

population of 1,230 and is the Gateway to the Outback and Flinders Ranges. The town is a

major service centre for the residents as well as any travelers and visitors. It is home to the

historic Pichi Richi Railway, which alone attracts over 9,000 visitors to the town each year. A

total of 500,000 visitors pass through the Flinders Ranges each year, with the majority of them

travelling through Quorn.

In preparing the submission, the following information is considered relevant as background

information.

• The Flinders Ranges Council and Quorn Community has been actively lobbying SA

Water for at least the last 20 years for improvements in water quality.

• The Township of Quorn is a key service centre for the District with the quality of the

water affecting the collective and wider community and provides essential services to

tourists travelling through the region. A total of 500,000 visitors pass through the

Flinders Ranges each year, with the majority of them travelling through Quorn. With

the use of community and public facilities, the majority of these would also access the

towns water supply. These visitors should be considered in the total “users” for the

Quorn water supply.


• Residents, Business owners and Community Organisations as SA Water customers

within the town have been paying unsubsidised (full) water rates for an inferior water

supply that many do not use as the primary water source due to its poor quality and

salinity (1,175 mg/l)

• The water is undrinkable and therefore is not used as a potable water supply by

residents and business owners.

• Residents and businesses have invested considerable money in establishing and

maintaining rainwater storage and pumping infrastructure for the purpose of a primary

water supply to their premises, including drinking supply. However, the maintenance

and on-going running costs of these systems far exceeds the cost per user of a

pipeline connection as proposed.

• Rainwater supplies are reliant on adequate rainfall and seasonal conditions, with the

supply for use as drinking water being untreated and therefore an uncontrolled source.

This is particularly relevant when considering the overall rainfall for Quorn is 257mm,

and Quorn and the wider region have been in one of the worst droughts in living

memory.

• Food preparation businesses, such as Hotels and Cafes, refuse to use the SA Water

mains water supply due to its aesthetic taste and choose to use rainwater that requires

specific treatment to meet the Food Handling Standards at a cost to their business.

• The corrosive nature of the water and its effect on condition of pipes and infrastructure,

in particular hot water services when heated, and the cost to continue to replace

infrastructure is significant.

• Continuing issues with maintaining sporting fields, public spaces and other essential

and key community facilities to a standard that is considered safe for use and

acceptable to users.

• Quorn is currently supplied via bore water, which is chlorinated and then stored in

tanks until accessed by users. The quality of the water supply does comply with the

AWDG health criteria, however Council further emphasises that the water supply does

exceed a significant number of aesthetic benchmarks for potable water as outlined

under Quorn Water Quality below.

Quorn Water Quality Quorn has had a history of poor water quality, which based on anecdotal information has been

deteriorating. In accordance with SA Water’s reporting for March, the water in Quorn failed

several compliance measures, including scoring a 0% compliance rating for chloride, sodium,

total dissolved solids and total hardness, with a 2% compliance rating for free chlorine levels.


Of concern, are parameters below – which are drawn from the reporting period 1 March 2019

to 29 February 2020:

• Chloride – Aesthetic Guidelines are 0 to 250 mg/L with the sampled water quality

being at 387 mg/L on average with a maximum of 405.

• Chlorine Free – with guidance of 0 to 0.6 mg/L with the sampled water quality

being on average 1.2mg/L with a high of 1.5mg/L.

• Hardness – Aesthetic Guidelines are 0 to 200 mg/L with the sampled water quality

on average at 502 mg/L with the maximum at 518mg/L.

• Sodium – Aesthetic Guidelines are 0 - 180 mg/L with the sampled water quality

being at 239 mg/L with highs of 254mg/L.

• Total Dissolved Solids – Aesthetic Guidelines are 0 - 600 mg/L with the sampled

water quality being at 1,175 mg/L with a high of 1200mg/L.

Summarised in table format as a percentage:

Contaminant Average Measure Maximum allowable contaminants

Percentage

Chloride 387mg/L 250mg/L 154.8%

Chlorine Free 1.2mg/L 0.6mg/L 200.0%

Sodium 239mg/L 180mg/L 132.8%

Total Dissolved

Solids (By EC)

1175mg/L 600mg/L 195.8%

Total Hardness as

CaCO3

502mg/L 200mg/L 251.0%

The results identify why a significant number of residents have focused on additional rainwater

and purchasing in water. The water is basically undrinkable.

Expected Water Quality Improvements It is noted that in the assessment summary by ESCOSA in A3.6.2.3 it is identified that there

is no clear line of sight between the proposed infrastructure projects and the improvements

customers should expect.


Council submits that this is not correct with respect to the Melrose, Wilmington and Quorn

proposed connection to the Morgan Whyalla Pipeline. It is noted that a similar connection,

same water source etc, was recently undertaken for the community of Orroroo and the

outcome of this connection was significantly improved water quality. In fact, a comparison of

the water quality for Orroroo (after connection) when compared with the aesthetic quality

problem areas for Quorn are identified below:

Contaminant Maximum allowable contaminants

Average Measure (QUORN) (mg/L)

Average Measure (ORROROO) (mg/L)

Percentage (improvement)

Chloride 250mg/L 387 47 823.40%

Chlorine Free 0.6mg/L 1.2 0.1 1200.00%

Sodium 180mg/L 239 38.8 615.98%

Total Dissolved

Solids (By EC) 600mg/L 1175 171 687.13%

Total Hardness as

CaCO3 200mg/L 502 42 1195.24%

Therefore, with respect to the key areas of concern, the water is between 615% and 1200%

better than the ‘drinking’ water in Quorn. Council have been advised by SA Water that the

water from Morgan can vary depending on River Murray conditions, but it’s generally

considered some of the best in the state. Some key differences from Quorn’s water are lower

hardness (so less scaling on appliances, etc), lower salinity (less salty taste) and it’s

chloraminated rather than chlorinated (chlorine tends to have a much stronger taste than

chloramine and some people find this unpleasant).


SA Water Prioritisation Process Our submission is that Quorn, Melrose and Wilmington be reincluded in the plan as a priority,

noting that these three communities have been identified as a priority through a thorough

assessment process by SA Water. Council has been advised by SA Water that the process

that identified these towns as the priority for upgrades used multiple criteria, including social,

technical and financial inputs. For example, the social criteria incorporated customer research

that had been conducted with residents of regional towns, including Quorn, as well as

complaints data, again including feedback from Quorn customers.

SA Water has confirmed that “SA Water has a Water Quality Aesthetics Approach that outlines

how aesthetics issues in regional water supplies can be addressed and that a multi-criteria

analysis, incorporating technical, social and financial criteria, has prioritised Quorn,

Wilmington, Melrose and Naracoorte for upgrades in the current initiative.

Quorn has consistently been identified as a priority for an upgrade, based on water quality

parameters, customer research (carried out by an independent consultant), complaints from

customers and the financial viability of packaging a solution that addresses the Quorn,

Wilmington and Melrose water supplies.

As you mentioned, discussions with Flinders Ranges Council and the Quorn community during

the last regulatory period reinforced the community’s desire for an upgrade. Orroroo was

prioritised and found to be prudent by ESCOSA in the last regulatory proposal and even more

detailed and robust work has been carried out for our current proposal.”

Based on the information provided by SA Water on their assessment process and noting that

since the approval of Orroroo in SAW RDA16 more detailed and robust work has been carried

out for the current proposal, Council submits that sufficient prioritisation has occurred for the

proposed communities to be included. This more detailed and robust work has identified the

communities to focus on first Council submits that it does not make sense to wait a further four

years to pursue these improvements. It is also noted that it does not make sense to delay

these critical projects, simply to redetermine that they are required when all the modelling,

more modelling than what was required by ESCOSA to approve Orroroo, identifies that they

are the priority and that this project is prudent.


COMMUNITY FACILITIES AND INFRASTRUCTURE Council experiences many issues with maintaining community facilities and infrastructure due

to the poor quality of the town water supply.

These additional costs are widespread but in the interest of providing specific examples

relating to this year. These include:

• Ongoing replacement of pipe and pump infrastructure at the Quorn Swimming Pool

along with additional costs to maintain water quality within specified standards for the

pool operations. The additional treatment costs associated with the Quorn Swimming

Pool are significant, in particular the hardness of the water has increased the rate of

deterioration of swimming pool cleaning equipment. For example, Council has had to

replace four (4) swimming pool cleaners in the last few years. A quote received as part

of budgeting purposes for a new pool cleaner for next year’s season is $18,000.

• Maintenance of key community facilities including the Quorn Oval, there is a

considerable cost in maintaining irrigation infrastructure at a suitable operational level

due to the corrosive nature of the water supply, with pipes, taps and solenoids needing

to be replaced regularly. It is noted that a recent quote received to rectify solenoids

and pumping at the oval, which requires replacement due to water quality, was

$22,000.

• Maintenance of public toilets and conveniences is also impacted by the quality of

water, again due to the ongoing need to replace taps and other pipe infrastructure. The

cost of this would be many thousands of dollars each year, with at least $5,000 being

incurred in the last three months.

These issues and costs associated with maintaining infrastructure essential to maintaining

adequate community facilities is a direct cost to the community. With an improved water supply

the costs will reduce and quality of the community facilities and infrastructure provided will

improve. It is noted that the $45,000 total indicated would only be part of the total cost of water

quality to Council per annum. These costs have all come to the surface in the last 3 months.

This is approximately 1% of Council’s annual operating revenue.


RESIDENTIAL PROPERTIES Council regularly receives feedback regarding the effect that the current status of the water

supply is having on the daily lives of residents and their household infrastructure.

Almost all residential properties currently rely on rainwater for drinking water and as a non-

corrosive water source to use in hot water services, washing machines and other appliances,

the security of the water supply is highly subject to seasonal conditions.

Rainwater supplies are reliant on adequate rainfall and seasonal conditions, with the supply

for use as drinking water being untreated and therefore an uncontrolled source. This is

particularly relevant when considering the overall rainfall for Quorn is 257mm, and Quorn and

the wider region have been in one of the worst droughts in living memory.

As stated in the introduction most residents within Quorn need to buy in water during lengthy

dry spells due to concern with using the current town water supply within their homes.

Council has estimated the cost of rainwater infrastructure and usage in the diagram below at

a cost of $2,040 per household per annum. The estimate below is a reasonable and

conservative estimate, particularly when considering the very low rainfall in Quorn combined

with significant drought conditions and the fact that the majority of households need to

purchase water twice per annum.

The estimated total cost to Quorn, as estimated below, of $1.4million per annum should

certainly be considered in determining the overall benefit of this project. It is noted that Council

has been informed by SA Water that the cost of the pipeline project is $22million, split between

the three communities that benefit, this would amount to $7.3million for Quorn. On this basis,

the savings associated with residential rainwater tank infrastructure alone, would repay this

investment within 5.2 years.

The improvement will enable residents to use the town water supply within their homes, which

will include for drinking. This will alleviate pressure on residents to continue to maintain

rainwater infrastructure as the primary water source for their homes and the need to buy in

water during times of shortage. In addition, it will further mean that all residents will have

access to a reliable and treated water supply for drinking instead of an uncontrolled rainwater

source.


Rainwater exposes residents to potential contaminants, particularly from bird droppings. It

should be noted that the Flinders Ranges Council area, and Quorn specifically, currently has

an infestation of both pigeons and little corellas, with little corellas flocking in their thousands.

This significantly increases the health hazards to Quorn’s residents to salmonella etc. This

little corella problem is well known, and it should be noted that Council currently has a section

41 committee specifically for dealing with these birds, as well as a little corella control plan.


A reasonable estimate of the cost to residents of Quorn for rainwater usage and infrastructure has been estimated below:

Cost Breakdown Methodology Total Cost ($) Lifespan (years) Cost per annum ($)

Water Tanks (3 x

22,000l)

Quoted price for a 22,000 litre tank is $2,500,

therefore the total of 3 would be $7,500. 7,500 15 500

Pressure Pump and

installation Quoted price 1,000 5 200

Plumbing of water

into residence. Estimate (depends on the exact plumbing required) 1,500 15 100

Cost of additional

water purchases

Quoted price for delivery of 24,000 litres is $620.

This would be required twice per annum depending

on family size and usage.

1,240 1,240

Total estimated cost of water quality on a household relying mostly on rainwater. 2,040

The total number of private dwellings in Quorn is 687 as per 2016 Census data. Therefore, the total cost for residences per annum using rainwater in Quorn could be estimated at:

1,401,480

The average household size in Quorn, as per the 2016 ABS statistics is 2.1. Therefore, the total cost per person per annum can be estimated at:

971


LOCAL BUSINESSES The current impact on local businesses resulting from the current water supply is significant,

with many businesses utilising rainwater where possible as the primary source. This approach

has several problems such as maintaining an adequate water supply to meet demand and

maintaining water quality to ensure that it meets Food Safety Standards that requires rainwater

to be treated before usage.

Where local businesses utilise the current water supply for use in hot water systems, washing

machines and generally throughout their premises there is considerable costs associated with

continued replacement of equipment, appliances and infrastructure again due to the corrosive

nature of the water.

In effect the current water supply is holding back local businesses from expanding their

operations and restricting the ability to be more efficient.

The upgrade to the water supply will simply fix the concerns of the local businesses, will

improve efficiency, reduce costs, enable expansion and mean that food businesses will

automatically meet the Food Safety Standards.

Council has approached the majority of businesses in Quorn and have asked them to make

individual submissions regarding the cost they have incurred, and the effect water quality has

had on their business. It should be noted that Council only became aware of ESCOSA’s

intention of removing the $22million on Wednesday 8 April, and therefore many businesses

will not have enough time to make detailed submissions. Particularly considering the fact a

significant number of businesses are currently shut due to COVID 19.

COMMUNITY CLUBS, GROUPS AND ORGANISATIONS All community clubs, groups and organisations that own and or control facilities, such as the

cricket club, netball/tennis clubs, bowling club and golf club are further impacted by the current

water quality.

As per the issues and concerns raised by residents and businesses, these clubs, groups and

organisations experience the same problems, with all organisations installing rainwater

systems to reduce the need to use the water supply in hot water services, dishwashers and

other appliances, and the need to provide bottled water for drinking.


Further as these organisations are involved in food preparation, a number of additional

procedures must be in place to ensure that Food Safety Standards are met. All the above

impact on the growing financial pressures experienced by clubs, groups and organisations, as

it is the members who are mainly residents of the town who are required to meet these costs.

Therefore, simply put, the upgrade of the water supply will resolve many issues and concerns

facing clubs, groups and organisations.

TOURISM AND ECONOMIC DEVELOPMENT Quorn, situated in the Flinders Ranges and governed by The Flinders Ranges Council, has a

population of 1,230 and is known as the Gateway to the Outback and Flinders Ranges. The

town is a major service centre for the residents as well as any travelers and visitors. It is home

to the historic Pichi Richi Railway, which alone attracts over 10,000 visitors to the town each

year. It is understood that a total of 500,000 visitors pass through the Flinders Ranges each

year, with most of them travelling through Quorn. The Flinders Ranges and Outback region is

also one of the fastest growing regions in South Australia for overnight stays with over 700,000

annually.

Council submits that ESCOSA should ensure that the broader economic benefits captured by

regional visitation are considered in their assessment of the proposed Regional Water Quality

Investment Program, not just the direct customer base in Quorn. All beneficiaries of the

investment, not just the direct must be considered in the cost benefit assessment.

The current water supply has a profound effect on tourism and economic development within

the town. It is not a “good look” when tourist visiting the town are advised “do not drink the

water”.

This message spreads by word of mouth and with a future strategy for the long term

sustainability of the region being to encourage, promote and further establish tourism; it is

paramount that the basic infrastructure is provided at a suitable standard to all visitors alike.


It is noted that there is strong anecdotal evidence that Quorn is starting to be bypassed by its

major tourist group, grey nomads, due to the inability of the town water supply to be used for

refilling water supplies in their caravans, motorhomes etc. Tourism is the largest employer

within the Flinders Ranges Council area, without this key demographic, the town and region

will suffer significantly. This combined with the continued effect of COVID 19 and three years

of drought, should be strongly considered by ESCOSA.

With tourism being one of the most significant employers in the Flinders Ranges region and a

significant economic contributor, it would be a disappointment if the decision to not

immediately support this investment in the significant program could slow or reduce the

economic benefits to the region. The $22million investment, with only a portion of this actually

being in the Flinders Ranges region, is entirely modest in the context of the half-billion dollar

Flinders Ranges tourism industry and the multiplier of that investment in higher quality mains

water would be quantifiable and significant when a broader economic view is taken.

Economic development is affected by the current water supply as there have been over the

years several businesses interested in establishing in Quorn, however the quality of water has

not been at the required standard to sustain the businesses. With the township having a

reliable power supply, excellent transport linkages and other important infrastructure, it is

water that impacts on the ability to encourage growth.

Residential development and choice of retirement is also affected by the current water supply,

with individuals making decisions to reside in other towns that have a better water supply.

The improvement to the water supply will mitigate the problems experienced in the past that

have stifled development opportunities, it will also ensure that Quorn maintains its

competitiveness with other communities which have recently had improvements to their water

supplies.

CONCLUSION Council strongly supports the inclusion of the proposed connection to the Whyalla Morgan

pipeline for Quorn, Wilmington and Melrose. Council calls on ESCOSA to reconsider its

position, particularly given the overall cost this decision will have on a community that is

already doing it tough.


LETTERS OF SUPPORT Two letters of support have been attached to this submission. The vast majority of

submissions have been made directly to ESCOSA and have not been reattached to

Council’s submission.

CONTACT Eric Brown Chief Executive Officer Flinders Ranges Council Street Address: 1 Seventh Street, Quorn SA 5433 Telephone: +61 8 8620 0500 Postal Address: PO Box 43, Quorn SA 5433 Email: [email protected]

mailto:[email protected]

The Commissioner

The Essential Services Commission of South Australia

GPO Box 2605

ADELAIDE SA 5001

[email protected]

Dear Commissioner

I welcome the opportunity to provide a formal submission to the SA Water Regulatory Determination

2020.

In particular I refer to an extract from - SAWRD20 - Draft Decision, that it is not prudent for SA

Water to include a 90km pipeline connecting the towns of Melrose, Wilmington and Quorn to the

Murray River.

The rejection focusses on a lack of identifiable health benefits associated with the proposed project. I

wish to make some points about the three afore mentioned towns:

All are connected to an SA Water supply which is specifically declared non-potable by the

supplier

Consumers in each town pay the same price for water as every other consumer in the state

with first class supplies

Almost without exception, those with a choice in these towns prefer to use rainwater for

drinking supplies

Since July 2006 all new dwellings in excess of 50m2 are required to have a rainwater

catchment

The relevant act requires the rainwater be connected to either the toilet, hot water system or

all cold taps in the laundry (clearly not for drinking)

Businesses in these towns providing tourism services are prohibited from supplying rainwater

for drinking purposes

Furthermore there is a quite obvious inconvenience and cost born by locals as a result of the

current non potable and highly mineralised supply which greatly shortens the life of items

such as water heaters, washing machines, dish washers and air conditioners.

/2

To expand a little on the issues facing tourism operators; each of the towns have strong natural tourist

attractions and have significant investments in the industry and yet businesses suppling services are

prohibited from suppling rainwater for drinking purposes to customers. This places them in a

dilemma, they need to supply a service, they are prohibited from supplying the water that they

themselves drink and the water they pay full price for is un-potable. That and the shortened life on

equipment mentioned earlier are major impediments to investment in the industry.

Your Draft Decision refers to the CNC report which is opposed to the expenditure on the grounds any

expenditure in this area should be funded by government rather than the customer base. This is an

insensitive view which if followed to its obvious conclusion means those within metropolitan confines

will always be looked after and those outside will have to fight for the continuation or extension of

services on a case by case basis ad infinitum. I make the point SA Water’s job is to provide safe,

reliable water to South Australians and to exercise division on the basis of historical context or any

other should not be acceptable.

The supply of good quality water to these towns is long overdue and the proposed works by SA Water

should not be deferred, they should if anything be accelerated.

I urge the Commission to reconsider its draft determination on this matter.

Yours sincerely

ROWAN RAMSEY MP

Federal Member for Grey

15th

April 2020

RR:gw

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