The submission made by Local Land Services (LLS) includes ... sharing plan... · North West Local Land Services (NWLLS) has provided the attached comments in relation to ... farming

The submission made by Local Land Services (LLS) includes comments from North West LLS, Murray LLS, Central West LLS and Hunter LLS.

North West Local Land Services PO Box 500 Tamworth NSW 2340 Tel: (02) 6764 5970| Fax:02 6764 5995 | www.lls.nsw.gov.au

Natural Resources Commission

GPO Box 4206

Sydney NSW 2001

5 August 2015

Comments on Upper and Lower Namoi and Lower Gwydir Groundwater Source Water Sharing Plans

Thank you for the opportunity to comment on the Upper and Lower Namoi and Lower Gwydir Groundwater Source Water Sharing Plans (WSPs). NWLLS recognises that the areas subject to both of the WSPs are important for the provision of domestic and stock water supplies, irrigation, industry and town water supplies as well supporting important groundwater dependent ecosystems. It is recognised that there is an ongoing high demand for water resulting in these areas being identified as one of the most at-risk groundwater resources in NSW.

General Comments

North West Local Land Services (NWLLS) has provided the attached comments in relation to the extent the WSP’s contribute to the state priorities of Local Land Services, particularly in relation to natural resource management. While NWLLS does not have a direct role in the implementation of the WSPs, NWLLS can provide an extension role in relation to sustainable farming practices relating to water efficiency programs which would also correlate with the protection, management and enhancement of groundwater ecosystems.

NWLLS has considered the WSPs in relation to the NWLLS Transition Natural Resource Management (NRM) Plan (with specific references to the Namoi Catchment Action Plan (CAP) and the Border Rivers – Gwydir (BRG) CAP which cover the area subject to the WSPs) and the Draft NWLLS Strategic Plan (Pre-consultation Draft). The NWLLS Transition NRM Plan identifies a number of goals and targets associated with the WSPs. The specific CAPs provide further detail in regards to critical water thresholds and actions (Namoi catchment) and desired groundwater state (BRG catchment). The targets identified in the Namoi CAP have been developed based on the critical water thresholds.

NWLLS recommends that the CAP documentation (and any associated research since the CAPs were finalised) is incorporated into the review process of the WSPs and that WSP requirements are based on up to date scientific and evidence-based information. WSPs will have a direct impact on how NWLLS can achieve the CAP targets. NWLLS also recommends that potential impacts on groundwater resources from climate change also needs to be investigated further as part of the WSP process.

Local Land Services 2

Specific Comments

Please refer to the attached table for comments in relation to specific questions. The comments are in response to key questions provided to NWLLS by the Natural Resources Commission. Due to the similarity of the comments, one set of comments that relate to both the Upper and Lower Namoi Groundwater Source and Lower Gwydir Groundwater Source have been provided.

NWLLS looks forward to participating in any additional consultation processes as the review is undertaken. For further information relating to the comments in this submission, please do not hesitate to contact me on (02) 6764 5970 or email: [email protected]

Kind regards,

James Hutchinson-Smith

Manager, Strategic Land Services

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North West Local Land Services – Specific Comments on Upper and Lower Namoi and Lower

Gwydir Groundwater Source Water Sharing Plans.

Water Sharing Plan: Upper and Lower Namoi and Lower Gwydir Groundwater Source 2003

Prepared by: North West Local Land Services

Contact Details: James Hutchinson-Smith – Manager Strategic Land Services (02) 6764 5970

The following comments are in response to key questions provided to NWLLS by the NRC.

Productive and Resilient Water-dependent Industries

3.To what extent does the water sharing plan contribute to productive and resilient water-

dependent industries

North West Local Land Services (NWLLS) acknowledges that the Water Sharing Plans (WSPs) has the

potential to contribute significantly to productive and resilient water dependent industries. This is

particularly in relation to sustainable agricultural activities and providing legislative requirements for

long term sustainable protection, management and enhancement of the quantity and quality of

groundwater sources. NWLLS recommends any future WSPs are based on up to date scientific and

evidence-based information. For example, an assessment of the condition (e.g. water quality) of the

groundwater resources of the WSP should be undertaken as part of the review process to ensure

future WSPs are based on up to date information.

The alignment of the WSPs and NW LLS priorities relates mainly to sustainable farming practices but

this only extends to NWLLS’s extension role and provision of advice. In particular, the NWLLS Draft

Local Strategic Plan (not yet available for public consultation) identifies a number of priorities

relating to water management relating to the area subject to the WSP. This includes providing

extension services aimed at improving water efficiency associated with groundwater sources such

as:

• Improving crop water use efficiency through improved practices and technologies such as

Electromagnetic Induction

• Promoting the use of innovation and technology to improve irrigation scheduling for greater

water use efficiency

• Improving the agronomic management of alternate rotational crops to improve

overall farming systems

• Investigation of alternate forage crops to maximise opportunities and improve agronomic

management

• Improved farm business management skills to improve profitability

There are also potential opportunities for NWLLS to develop partnerships with key stakeholders

implementing the WSP to deliver information, knowledge, capacity building and education initiatives

and to drive best practice management adoption in the region in relation to sustainable farming

practices relating to water efficiency activities.

In relation to the NWLLS Transitional Regional NRM Plan, there is a relationship in terms of identified

goals and targets in relation to productive and resilient water-dependent industries.

For example (Namoi CAP-covering the Upper and Lower Namoi WSP):

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Plains/Slopes area

Goal: Resilient communities and landscapes for the future.

Target: Water 2: By 2020, there is an improvement in the ability of groundwater systems to support

ground-water dependent ecosystems and designated beneficial uses.

Water 3: By 2020, there is an improvement in the condition of regionally important wetlands and the

extent of those wetlands is maintained (only applicable where groundwater dependent)

The Namoi CAP also identifies a number of Water Critical Thresholds relating to groundwater e.g.

Alluvial aquifers are not drawn down below long term historical maximum drawdown levels. Due to

the reliance of the Namoi Catchment on its water resources, exceeding critical thresholds for water

assets has the potential to cause significant changes across the entire catchment (NCMA 2013).

The BRG CAP (covering the Lower Gwydir WSP) has an identified desired state for groundwater that

consists of “water tables remain at depth. Deep aquifers maintain stable pressure and water levels.

Quality suitable for agricultural uses.”

NWLLS recommends that the CAP goals, targets, thresholds be met by WSPs and are incorporated

into the WSP review process.

4. How can the productivity and resilience of water dependent industries be improved and made

more cost effective?

Comments from NWLLS can only be made in relation to the programs we offer. As such, NWLLS’s

extension role and provision of advice to farmers in regards to sustainable farming practices can

assist to improve the productivity, cost effectiveness and resilience of water dependent industries

(agricultural related). In particular, the NWLLS Draft Strategic Plan identifies a number of priorities

relating to water management relating to the area subject to the WSP. This includes providing

extension services aimed at improving water efficiency associated with groundwater sources such

as:








management


There are also potential opportunities to develop partnerships with key stakeholders implementing

WSP to deliver information, knowledge, capacity building and education initiatives and drive best

practice management adoption in the region in relation to sustainable farming practices relating to

water efficiency activities.

NWLLS supports requirements that contribute to productive and resilient water dependent

industries and recommends that any requirements are based on up to date scientific and evidence-

based information.

a. How could the management of water access licenses under plans be improved?

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Due to the limited understanding of how the management of water access licences is currently

undertaken, NWLLS has no comment in relation to this question.

b. Are there opportunities for local communities to manage or contribute to managing the

sharing of groundwater (surface water in relation to Patterson WSP) more effectively in

areas of restricted availability?

NWLLS supports opportunities for local communities to manage or contribute to managing the

sharing of groundwater more effectively in areas of restricted availability.

NWLLS’s extension role and provision of advice to farmers in regards to sustainable farming

practices can potentially assist with these opportunities. In particular, the NWLLS Draft Strategic Plan

identifies a number of priorities relating to water management relating to the area subject to the

WSP. This includes providing extension services aimed at farmers to improve water efficiency

associated with groundwater sources such as:








management


There are also potential opportunities to develop partnerships with key stakeholders implementing

WSP to deliver information, knowledge, capacity building and education initiatives and drive best

practice management adoption in the region in relation to sustainable farming practices relating to

water efficiency activities.

In addition, the NWLLS Transitional Regional NRM Plan – Catchment Target Water 2 (Action 47) also

identifies NWLLS role in contributing to opportunities for local communities to manage or contribute

to managing the sharing of groundwater resources more effectively. This is through:

Invest in education, extension, and community engagement, and develop knowledge products to

facilitate improved understanding of groundwater health thresholds and priorities.

Potential impacts on groundwater resources from climate change also needs to be investigated

further.

Secure longterm water supplies for urban and rural communities

3. To what extent does the water sharing plan contribute to security of supply for rural and urban

communities?

NWLLS has no comment in relation to this question as it is not considered within the scope of NWLLS

functions.

4. How can security of supply for rural and urban communities be improved and made more cost

effective?

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functions.

c. Are there risks to availability of groundwater to towns and rural stick and domestic water

users that could be better addressed?


functions.

d. Are there salinity risks associated with land or water management that could be better

addressed?

Salinity risks associated with inappropriate land or water management on natural resource

management values and agricultural activities are a key threat in the WSP areas. Poor water quality

due to salinity can impact on both groundwater and surface water values and salinity impacts may

act as a major ‘shock’(resilience thinking) within the region. Projections of salinity due to climate

change are highly uncertain and need to be investigated further.

The NWLLS Transitional Regional NRM Plan includes targets relating to land management, for

example:

Plains/Slopes (Namoi CMA area)


Target: Land 1: by 2020, there is an improvement in soil health as measured by an increase in

groundcover at the paddock, sub-catchment and catchment scales.

Action: Invest in understanding interactions between improving groundcover and potential impacts

on surface water run-off and groundwater recharge.

NWLLS supports requirements in the WSP that contribute to addressing identified salinity risks

associated with land and water management and recommends that any requirements are based on

up to date scientific and evidence-based information.

e. Are cultural uses and values of water adequately addressed?

There is limited information available to comment on this question. NWLLS recommends further

investigation into cultural uses and ground water values be identified and included within the WSP

where required.

Healthy and resilient water dependent ecosystems

3. To what extent does the water sharing plan contribute to the health and resilience of the

groundwater source and associated water dependent ecosystems?

A report commissioned by Namoi CMA (SKM 2010) identified that the groundwater resources

contained in the aquifers of the Namoi Catchment (including the upper and lower Namoi

groundwater source) are arguably the most intensively developed of any aquifer systems in the state

if not Australia. Surface and groundwater resources support substantial cotton and lucerne

industries among other cropping regimes as well as significant stock, domestic, various industrial and

town water supply use, with mining use increasing in the area as well. Over –extraction of

groundwater as well as declining water quality does pose a significant threat to the sustainability of

terrestrial Groundwater Dependent Ecosystems (GDE) and groundwater resources, along with

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possible impacts on surface water where connected. As such, the WSP has extensive impact on the

health and resilience of the groundwater resources and GDEs in the areas subject to the WSPs.

In addition, the North West LLS Transitional Regional NRM Plan contains specific targets in relation

to improvement in the ability of groundwater systems to support groundwater-dependent

ecosystems.

For example: Plains/Slopes (Namoi CMA area)


Target: Water 2: By 2020, there is an improvement in the ability of groundwater systems to support

ground-water dependent ecosystems and designated beneficial uses.

Water 3: By 2020, there is an improvement in the condition of regionally important wetlands and the

extent of those wetlands is maintained (only applicable where groundwater dependent)

However, the ability to achieve this target is greatly dependent on the legislative requirements of

the WSP. NWLLs can play an advisory role in educating, raising awareness of impacts of extraction of

groundwater (quality and quantity) on GDEs.

4. How can the health and resilience of the groundwater source and associated water dependent

ecosystems be improved?

Six GDEs have been identified in the Namoi catchment part of the NWLLS region. These are

• Phreatophytes – Groundwater dependent terrestrial ecosystems supporting terrestrial

vegetation and associated terrestrial vertebrates and invertebrate (Common, >50%);

• Subsurface phreatic aquifer ecosystems supporting stygofauna (Common, >50%);

• Baseflow streams (surface water ecosystems) supporting aquatic vertebrate and

macroinvertebrates) (Sparse, 10-20%);

• Baseflow stream (hyporheic or subsurface water ecosystems) supporting hyporheic fauna,

stygofauna and riparian vegetation (Sparse, <10%);

• Groundwater dependent wetlands supporting surface aquatic vegetation, aquatic

vertebrates and invertebrates (Rare, <5%);

• Karst and caves supporting both aquatic stygofauna and terrestrial Troglofauna (Rare,

<1%).

SKM (2010) identified 286, 042 Ha of the Namoi Catchment as likely, moderately likely and highly

likely to be GDE vegetation (96.7% terrestrial vegetation, 2% riparian vegetation and 1.3% spatial

extent of wetlands). It is not known the number, extent or condition of GDE throughout the

remainder of the NWLLS region and more specifically in relation the areas subject to the WSP

review. Further information is required in regards to this and should be included as part of the WSP

review.

NWLLS has a number of reports relating to GDEs within the Namoi Catchment area if further

relevant information is required.

The Namoi CAP originally identified that a threshold of 30m was important to sustain and protect

GDEs within the Namoi CMA. It has since been identified that this target “was drawn from available literature at the time of the CAP development but was not specific to the Namoi Catchment and thus required further specific investigation and adjustment based on local conditions”. Consequently, a

report in 2013 (prepared by Stygoecologia) has since reviewed the scientific data behind this

threshold and has now recommended a threshold of 10m. Research referred to in this report

identified that groundwater becomes less important to terrestrial vegetation when depths to

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groundwater exceed 10m. It found that the range of rooting depths for many species of terrestrial

ecosystems identified that there is a requirement for the aquifer water levels to be at or within 10m

of the land surface in order to sufficiently sustain or protect these ecosystems. Terrestrial

ecosystems that rely on groundwater are particularly at risk from water level fluctuations due to the

roots being distributed just above the water table. The recommended 10m threshold will have long

term benefits for the environment by providing water levels more closely in line with natural

variations. As such it is recommended that the WSP reflect this research in relation to extraction

depths.

The effects of groundwater extraction plus impacts from climate change, drought, surface and sub-

surface ecosystems are not fully understood. The number and type of access licences and the

extent of groundwater usage will have a direct relationship with the achievability of this target and

the long-term protection, management and enhancement of groundwater dependent ecosystems in

the NWLLS region.

a. How could confidence in the extent, nature and water needs of groundwater dependent


There is limited information available on the identification, characteristics (including condition) and

location of groundwater dependent ecosystems in the NWLLS region and the areas subject to the

WSP review. Much of what is available offers generic information on GDEs or groundwater, or is

focussed on the overall environmental condition of the region. Further information is required to

identify the extent, nature and water needs of GDEs. In addition, the WSP (s39) refers to specific

extraction distance (eg 100m) and depth of extraction (eg 50m) requirements from GDE and refers

to high priority GDE in Schedule 5. However, there are no GDEs listed in Schedule 5. As such there

would be great difficulty in meeting these requirements. It is recommended that:

• GDEs within the area subject to the WSP be appropriately mapped (e.g extent and type),

baseline condition identified and the groundwater dependency (eg entirely dependent,

highly dependent, proportionally dependent, opportunistic or limited extent dependent)

needs to be identified prior to drafting of the WSP.

• The legislative requirements of the WSP including depth of extraction, distance of permitted

extraction from GDEs and amount of extraction permitted etc are based on this above

baseline data and may vary depending on the identified GDEs. In addition, the WSP need to

address:

• Flow or flux – the rate and volume of supply of groundwater

• Level – the depth below surface of the water table

• Pressure

• Quality – chemical quality of groundwater in terms of pH, salinity, nutrients and

contaminants

• GDEs identified and included in the WSP (e.g. schedule 5 of current WSP).

• Establishment of long-term monitoring points for GDEs

This would also provide a basis for prioritisation for protection and restoration of GDEs in the NWLLS

region and in relation to meet the CAP targets.

b. Are there concerns about groundwater pressure, levels and water quality

NWLLS has concerns over the impacts (short and long-term) on groundwater pressure, levels and

water quality. As identified above, the WSP needs to address:

• Flow or flux – the rate and volume of supply of groundwater

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• Level – the depth below surface of the water table

• Pressure

• Quality – chemical quality of groundwater in terms of pH, salinity, nutrients and contaminants

How GDEs respond to changes in the above attributes varies and an ecosystem can collapse

completely due to changes (e.g. thresholds breached).

c. Are there alternative means for meeting water needs of groundwater dependent

ecosystems to that included in the water sharing plans (e.g. through targeted watering

using water access licences)?

NWLLS recommends that alternative means for meeting water needs of GDEs be

investigated and included in WSP where deemed appropriate to achieve long-term

protection, management and enhancement of GDEs and ground water quality and quantity.

Page 1 of 9

TO Rob Kelly

FROM Helen Wilson, Murray Local Land Services (combined responses)

DATE 7 August 2015

REFERENCE MUR03397 (A2921418)

SUBJECT Murray LLS Response to Lower Murray and Murrumbidgee Groundwater sharing plans NRC Request for LLS input into the review

Purpose:

To provide comments from Murray Local Land Services on the NRC request for contribution to the review

of the two ground water sharing plans that cover part of our region, namely;

i) Lower Murray Groundwater source

ii) Murrumbidgee Ground Water source

Issue:

Request for input into the NRC Water Sharing Plan Review

Current Situation:

Comments have been compiled internally from a sustainable agriculture and environmental perspective in

relation to the contribution of the water sharing plans to the Draft Murray Local Strategic Plan.

Murray LLS comments are more focussed on the lower Murray Groundwater source with some comments

supplied on the Lower Murrumbidgee Groundwater Source, which falls only partly in the Murray Region,

although there are some high volume users in the Murray, highly dependent on this source.

Comment/Options:

Murray LLS has provided more comprehensive comments on the Lower Murray Groundwater Source with

some comments on the Murrumbidgee Groundwater source for Riverina LLS to consider adding to for the

final submission.

Recommendation:

i) That the attached response be considered for compilation into a Local Land Services submission to the NRC.

ii) Murray LLS has not undertaken any rigorous stakeholder consultation in making these

comments and recommends that additional key stakeholder consultation be undertaken to inform final review need decisions

ATTACHMENT 1

Page 2 of 9

Water Sharing Plan: Lower Murray Groundwater Sources

Prepared by: Murray Local Land Services

Contact details: Helen Wilson (Murray Local Land Services) 0428 676 054

Productive and Resilient Water-dependant industries

1. To what extent does the water sharing plan contribute to productive and resilient water-dependent industries? Whilst the overall contribution from this Source to total water availability in the lower Murray system is low

(typically < 10% of the total volume of consumptive water use in this area), it contributes to Goals 1 & 2 of the Draft

Murray Local Strategic Plan in relation to resilient farming systems and communities, particularly in times of climatic

variability and drought. Key points for consideration include:

a. In years when surface water availability is low, it can account for a significant proportion of total water

usage;

b. Industries such as the rice industry have been shown to be particularly reliant on access to this Source

when surface water availability is low.

c. A number of irrigation businesses have developed infrastructure and invested significant capital based upon

ongoing access to this Source;

d. There are several townships reliant on this Source for domestic purposes, in particular when surface water

availability is low and/or when there are water quality issues associated with surface water (such as blue-

green algae);

e. Numerous individual points of groundwater usage are characterised by water quality that is marginal in

terms of its quality – in particular being saline and/or sodic. Usage of such water has implications at an

individual farm level (in particular on soil quality), but may impact on shallow aquifers should recharge

contaminate these shallow aquifers.

f. It is worthy to note that when surface water allocations are low, and individuals have conjunctive access to

groundwater, recent history indicates reduced reliance on deep groundwater in such circumstances. The

reasons for this are varied, but can include the high cost of operation and maintenance of these deep

aquifer bores, and the marginal quality of the water which is characteristic of some of these bores (which

has implications on both short term productivity and longer term soil fertility and sustainability).

g. Murray LLS is not familiar with the breakdown of how this water Source is fully used. To improve the

knowledge of how this water is productively used, it would be useful to obtain better information from the

licensing authority as to the destination of water used from this Source. It is likely that individual

enterprises (for example such as intensive horticultural developments and/or aquaculture) are particularly

dependent upon this water as a significant input into their individual operations.

2. How can the productivity and resilience of water dependent industries be improved and made more cost effective?

Users of groundwater should be aware of the implications of its use, in particular where:

a. the quality of the water being used is marginal or changing over time, and/or

b. the soils onto which the water is being used is of marginal quality, and/or

c. the method of application is not appropriate for the quality of water being used.

As such, it is suggested that a targeted extension program be considered where there is a history of high usage from this Source. Such an extension program should inform landholders of the implications of water quality impacts on soil health and long term sustainability, the overall farm management requirements where marginal water is used, consideration of energy costs of delivery, changing water quality, effectiveness of the range of water conditioners used and impacts on stock and domestic use. This is an area when DPI Water and Murray LLS could collaborate more effectively to ensure groundwater users are well informed of the implications on both the land and water resources of groundwater usage. This action fits within Strategy 2: Provide advisory services that support and enable customers to implement improved practices.

ATTACHMENT 1

Page 3 of 9

a. How could the management of water access licences under the plans be improved?

a. Ensuring real time access to usage information (this may already be provided).

b. Greater ease in the trading of entitlements (permanent and temporary) between end users.

c. Greater transparency in and of the trade process.

d. Improved information transfer between agencies (in particular around monitoring data) and end users, so

that ‘hotspots’ (such as areas with anomalies in aquifer pressures for example) can be identified and

measures implemented to ensure greater responsiveness to aquifer changes.

e. Improved reporting from agencies to end users.

f. Improved usage of historically relevant data – for example, recharge has been calculated based on 1985-

2000 data. We have 15 years of now more relevant data which could be used.

g. Greater recognition of the links between what/how other jurisdictions are managing/implementing water

allocations. Improve understanding of how recharge of aquifers is influenced by the Murray River.

h. Improved communications between Victorian and NSW regulators – to ensure improved consistency in

applying rules and regulations, AWD’s, impacts of implementing certain measures etc

Unless additional external resources are invested in this area Murray LLS does not have the capacity to be involved

in an advisory capacity around the management of water licenses under this plan. Our advisory capacity falls in the

area agricultural advisory extension services and potentially R&D collaboration related to the effective and

sustainable use of groundwater as a production resource rather than in the area of water access and licensing.

b. Are there opportunities for local communities to manage or contribute to managing the sharing of groundwater (surface water in relations to Patterson WSP) more effectively in areas of restricted availability?

There are a number of key stakeholders that should be identified and consulted with for further review of the water

sharing plans including the Customer Service Committees and key industry and producer groups’ dependent upon

this water source.

Murray LLS works with irrigation producer and industry groups to develop priorities for extension and collaboration

programs. Other than these programs, without additional resources being provided there is limited capacity for

Murray LLS to directly contribute to managing the sharing of groundwater more effectively other than in our

capacity to provide sustainable agricultural advice and extension.

The following areas are identified as opportunities for local communities involvement:

a. Greater flexibility built into the WSP to ensure new (verifiable and quantifiable) information is able to be

better incorporated into a legislative and planning framework.

b. If the relevant agency(s) were to provide a summary position each year of the groundwater information

(results from monitoring – such as changes to pressure levels within the aquifer, information concerning

usage, changes in quality etc), it would better inform the community. This would allow informed decisions

to be made about potential changes to AWD’s, LTAEL, targeted approaches in particular localities etc.

c. Maximise the use of the existing Customer Service Committees and their links to other key stakeholder and

industry groups to provide input into the review and implementation of the WSPs, ensuring community

consultation and information sharing.

d. In the spirit of information sharing, it would also be of benefit to the agency(s) if reliable information from

users could be ‘fed back’ to the agency. This could include (but not be limited to) results of water quality

monitoring/analysis undertaken by individual users. Protocols would need to be established, confidentiality

issues would need to be addressed etc, but if nothing else, it may provide agency(s) with a ‘heads–up’

concerning an emerging issue.

ATTACHMENT 1

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General comments These comments relate specifically to issues concerning the Lower Murray groundwater source – which

specifically refers to the groundwater contained in the unconsolidated alluvial sediments of the Calivil,

Renmark, and the Lower Shepparton aquifers deeper than 12 metres below the ground surface, demarcated

by the area bounded by Billabong Creek to the north, the Murray River to the south, and the Corowa-Urana

Road to the east. It does not refer to the shallow (upper) groundwater source.

1. Recharge has been estimated at 83,700 ML/yr. This was based on modelling (MODFLOW) using data

over the period 1985-2000. The Long Term Average Extraction Limit (LTAEL) has been adopted as

83,700 ML/yr (plus supplementary access plus basic landholder rights).

Action: Consider review of the recharge rate based on more current data – both inflows and outflows (via

metering) and use of the groundwater monitoring network (piezometers). This would provide users and

managers with greater understanding of the variability and appropriateness of recharge estimates.

2. It is noted that supplementary water access license share components were originally provided based

on history of use. It is noted this component is being reduced over the life of the plan to ‘0’ by

2015/16. What ongoing consultation is occurring informing license holders of this action?

3. Management of Local Impacts – it is noted that to protect water quality, the Plan requires a baseline

of EC to be established.

Action: Has the baseline EC been established, how has the information been obtained and used to determine

the baseline, and how has/will local management and/or thresholds be impacted and/or used?

4. The Plan refers to the development of ‘Performance Indicators’ – has this been done, how and what

type of information has been used in the development of them, and importantly how is the

achievement (or not) of the performance indicators being used to refine the Plan? Additionally, how

is this information being communicated to stakeholders?

5. The Plan refers to the ‘annual review of the implementation program’ - is this being done, how and

what type of information has been used in the review(s), and importantly how is the information

generated being used to refine the Plan and ensure the implementation program is being achieved?

Additionally, how is this information being communicated to stakeholders?

ATTACHMENT 1

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Secure longterm water supplies for urban and rural communities (Lower Murray Groundwater Sources)

1. To what extent does the water sharing plan contribute to security of supply for rural and urban communities? This is not generally within the scope of Local Land Services Functions generally

2. How can security of supply for rural and urban communities be improved and made more cost effective? This is not generally within the scope of Local Land Services Functions generally

a. Are there risks to availability of groundwater to towns and rural stock and domestic water users that could be better addressed?

This is not generally within the scope of Local Land Services Functions generally

b. Are there salinity risks associated with land or water management that could be better addressed? There are salinity risks associated with land and water management within the area in question. While there are no expected immediate impacts, ongoing and potentially increased clearing of deep-rooted vegetation plus steadily increasing financial pressure on landholders to irrigate inappropriate areas represent a moderate longer term risk for specific areas within the Murray Region through elevating saline water tables and compounding inappropriate groundwater recharge. Opportunities are presented in the WSP to assist with managing these risks through rules that support establishment of local impact areas and application of local access rules, assuming that these could encompass groundwater extraction at key locations to lower groundwater tables at critical times. Murray LLS has not identified broad-scale salinity management as a priority within any of its current planning instruments, however the situation is under a watching brief at key locations in the region. Determination of level of risk is hampered by the paucity of data on groundwater-dependent ecosystems (GDEs) in the region – as noted in the WSP, additional studies of the groundwater dependency of ecosystems within this area are required.

c. Are cultural uses and values of water adequately addressed? Currently the only allowances for social/ cultural uses and values of the water source outside the standard water access licences is for a specific purpose access licence (subcategory “Aboriginal cultural”) or through landholder rights as part of a Native Title claim. Due to the lack of knowledge of social and cultural uses and values of groundwater within the region it is unclear as to whether the current arrangements in the WSP adequately address these needs. Broader stakeholder engagement would be required to evaluate this. A Performance Indicator has been established within the WSP in regard to Aboriginal cultural values (Appendix 2):

Extent of recognition of spiritual, social and customary values of water to Aboriginal people, as measured by:

o Assessment of amount and type of information collected to identify the range of values of water to Aboriginal people.

It is unclear whether this indicator is currently being assessed or reported on. As noted in the WSP, “the collection of information on the values associated with water is considered the first step in addressing the objects of the Act”. This raises the priority for identification of social/ cultural uses and values of the water source to a high level.

ATTACHMENT 1

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Healthy and resilient water dependant ecosystems (Lower Murray Groundwater Sources)

1. To what extent does the water sharing plan contribute to the health and resilience of the groundwater source and associated water dependent ecosystems?

The WSP generally appears to be well-aligned to Murray LLS priorities given current (minimal) identification of groundwater-dependent ecosystems (GDEs) within the Murray region. Determination of the contribution of the WSP to ecosystem health and resilience is hampered by the paucity of data on GDEs in the region – as noted in the plan, additional studies of the groundwater dependency of ecosystems within this area are required. In regards to the health and resilience of the water source itself, we expect that monitoring requirements detailed in the WSP would be sufficient to evaluate whether extraction caps and rules are protecting water quantity and quality. This assumes, however, that the monitoring is actually taking place, the data is being analysed and evaluated, and a clear process is established to initiate local actions over the short term and/or modify the WSP itself over the longer term based on learnings from the monitoring program. Evaluation of the health and resilience of the groundwater source would be enhanced by using multiple lines of evidence including stakeholder experiences and observations. Given the relatively lower volumes compared to surface water sources, and lack of any robust identification of GDEs within the region to date, Murray LLS has not identified broad-scale improvement to the health and resilience of the groundwater source as a priority for action within any of its current planning instruments. As previously noted, some risks related to salinity impacts at specific locations and for suspected GDEs within the catchment (e.g. Green Gully region and a number of individual wetlands) – the situation at these sites is under a watching brief. Current ad-hoc liaison between LLS, NOW and relevant landholders is sufficient for the scale of the issue.

2. How can the health and resilience of the groundwater source and associated water dependent ecosystems be improved?

Not a priority for action in the Murray region apart from ensuring that the monitoring program and WSP adaptation process have been enacted.

a. How could confidence in the extent, nature and water needs of groundwater dependent ecosystems be improved?

As noted in the plan, complete the additional studies of the groundwater dependency of ecosystems within the Groundwater Source area and communicate the findings to stakeholders.

b. Are there concerns about groundwater pressure, levels and water quality? Yes, but only at specific locations throughout the region rather than broadly across the entire Groundwater Source. In particular, saline groundwater intrusion in the Green Gully area is severely impacting on both agricultural production and environmental values of associated ecosystems. Failed infrastructure is limiting the capacity of landholders to utilise provisions within the WSP to manage groundwater levels to address these local impacts.

c. Are there alternative means for meeting water needs of groundwater dependent ecosystems to that included in the water sharing plans (e.g. through targeted watering using water access licences)?

Unknown until additional studies of the groundwater dependency of ecosystems within the Groundwater Source area are completed.

ATTACHMENT 1

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Water Sharing Plan: Lower Murrumbidgee Groundwater Sources

Prepared by: Murray Local Land Services

Contact details: Helen Wilson (Murray Local Land Services) 0428 676 054

Productive and Resilient Water-dependant industries

1. To what extent does the water sharing plan contribute to productive and resilient water-dependent industries? The Lower Murrumbidgee Groundwater source covers only part of the Murray LLS region, with the the majority of bores and use falling in the Riverina LLs region. Water quality from this Source is of higher quality than the Lower Murray Groundwater Source and there are a number of higher use bores in the northern part of the Murray LLS region. As such the Source provides an important source of productive agricultural water and is important in terms of irrigated agriculture and for managing for climate variability and climate change. Water use from this Source contributes to Goals 1 & 2 of the Draft Murray Local Strategic Plan in relation to resilient farming systems and communities, particularly in times of climatic variability and drought.

2. How can the productivity and resilience of water dependent industries be improved and made more cost effective?

Suggest that Riverina LLS comments further on this section Given the high relative volume of groundwater use from these sources it is recommended that broader stakeholder engagement is conducted with the key users and industry group to identify how the productivity of water dependent industries can be improved and made more cost effective. Water use efficiency of crops such as rice and energy consumption are likely to have an impact on productivity and efficiency.

c. How could the management of water access licences under the plans be improved? Suggest that Riverina LLs comments on this section

d. Are there opportunities for local communities to manage or contribute to managing the sharing of groundwater (surface water in relations to Patterson WSP) more effectively in areas of restricted availability?

There are a number of key stakeholders that should be identified and consulted with for further review of the water

sharing plans including the Customer Service Committees and key industry and producer groups’ dependent upon

this water source.

Murray LLS works with irrigation producer and industry groups to develop priorities for extension and collaboration

programs. Other than these programs, without additional resources being provided there is limited capacity for

Murray LLS to directly contribute to managing the sharing of groundwater more effectively other than in our

capacity to provide sustainable agricultural advice and extension.

ATTACHMENT 1

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Secure longterm water supplies for urban and rural communities (Lower Murrumbidgee Groundwater Sources)

3. To what extent does the water sharing plan contribute to security of supply for rural and urban communities? This is not generally within the scope of Local Land Services Functions generally

4. How can security of supply for rural and urban communities be improved and made more cost effective? This is not generally within the scope of Local Land Services Functions generally

d. Are there risks to availability of groundwater to towns and rural stock and domestic water users that could be better addressed?

This is not generally within the scope of Local Land Services Functions generally

e. Are there salinity risks associated with land or water management that could be better addressed? No significant issues are known for the Murray Region component of this Source. Given the high relative volume of groundwater use from these sources it is recommended that broader stakeholder engagement is conducted to introduce additional lines of evidence to support bore monitoring.

f. Are cultural uses and values of water adequately addressed? Currently, allowances for social/ cultural uses and values of the water source outside the standard water access licences include:

provision for an aquifer (community and education) access licence

provision for a specific purpose access licence (subcategory “Aboriginal cultural”), and

through landholder rights as part of a Native Title claim. Due to the lack of knowledge of social and cultural uses and values of groundwater within the region it is unclear as to whether the current arrangements in the WSP adequately address these needs. Broader stakeholder engagement would be required to evaluate this. Performance Indicators have been established within the WSP in regard to native title rights and Aboriginal cultural values (Appendix 2):

Extent to which native title rights requirements have been met, as measured by: o Monitor increase in applications for water supply work (bore) approvals for native title basic

landholder rights. o Number of reports of interference between high yield extraction and native title rights holders, or

number of bores deepened. o Assess frequency and duration of water level drawdown below critical thresholds.

Extent of recognition of spiritual, social and customary values of water to Aboriginal people, as measured by:

o Assessment of amount and type of information collected to identify the range of values of water to Aboriginal people.

It is unclear whether these indicators are currently being assessed or reported on. As noted in the WSP, “the collection of information on the values associated with water is considered the first step in addressing the objects of the Act”. This raises the priority for identification of social/ cultural uses and values of the water source to a high level.

ATTACHMENT 1

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Healthy and resilient water dependant ecosystems (Lower Murrumbidgee Groundwater Sources)

1. To what extent does the water sharing plan contribute to the health and resilience of the groundwater source and associated water dependent ecosystems?

Murray LLS has not identified broad-scale improvement to the health and resilience of the groundwater source itself as a priority for action within any of its current planning instruments. We require additional consultation with stakeholders in order to determine the significance of GDEs associated with this water source, their priority for inclusion in our planning instruments and hence our level of resourcing and focus on these systems for the next three years. This consultation could also inform evaluation of the contribution of the WSP to water dependent ecosystems associated with this Groundwater Source.

2. How can the health and resilience of the groundwater source and associated water dependent ecosystems be improved?

Unknown for Murray Region until we consult with stakeholders. Relying on findings of monitoring proposed in WSP at this point.

a. How could confidence in the extent, nature and water needs of groundwater dependent ecosystems be improved?

Consult with stakeholders to identify priorities for focus and communication needs.

b. Are there concerns about groundwater pressure, levels and water quality? Uncertain at this point from Murray LLS’s perspective. Consultation planned for the main area of relevance to our region (Billabong- Yanco and Tributaries area) will inform our understanding of these issues.

c. Are there alternative means for meeting water needs of groundwater dependent ecosystems to that included in the water sharing plans (e.g. through targeted watering using water access licences)?

Unknown for Murray Region until we consult with stakeholders.

Water Sharing Plan: Prepared by: Susan Madden and Shona Whitfield Contact details: M: 0447 653 761 Landline: 02 6847 8502 Productive and Resilient Water-dependant industries

To what extent does the water sharing plan contribute to productive and resilient water-dependent

industries?

- Provides for value of irrigated agricultural production supporting predominantly cotton but also horticultural industry

- Provides for a degree of drought proofing with groundwater offering a more secure supply than surface water resources in the region

- Currently access/use is well within the long-term average extraction limit suggesting there may be room for some increase in the current level of production within sustainable limits

How can the productivity and resilience of water dependent industries be improved and made more cost effective?

- Rising energy costs are providing some impediment to adoption of more efficient irrigation practices, eg pressured spray techniques, which might be a broader consideration for LLS and other agencies responsible for assisting landholders improve productivity and profitability into the future

o How could the management of water access licences under the plans be improved?

o Are there opportunities for local communities to manage or contribute to managing the sharing

of groundwater (surface water in relations to Patterson WSP) more effectively in areas of restricted availability?

- Plan already has local impact management rules inbuilt, which provides a good example of how local landholders and communities can contribute. Suggest these provisions are maintained.

Secure longterm water supplies for urban and rural communities

- Plan provides for licensing and trading framework to provide for town water supplies

(i.e. local water utility licences) and stock and domestic user, which ensures security of access

- Monitoring needs to be strengthened in the future to ensure water quality objectives are met

- Could follow up with Narromine Shire Council as they have licences for Trangie and Narromine townships – is plan meeting their needs

To what extent does the water sharing plan contribute to security of supply for rural and urban

communities?

How can security of supply for rural and urban communities be improved and made more cost effective?

o Are there risks to availability of groundwater to towns and rural stock and domestic water users that could be better addressed?

- Local impact restrictions, in particular interference rules, may prohibit urban development. This is an area where there is greater scope for facilitating discussion between community and industry.

o Are there salinity risks associated with land or water management that could be better

addressed?

- There have been some quality issues and hot spot identification processes. Scope to ensure that resources are there if there is user demand assistance in managing impacts and risks.

o Are cultural uses and values of water adequately addressed?

- No specific values identified - Scope for greater engagement with Aboriginal community on water management

generally

Healthy and resilient water dependant ecosystems

To what extent does the water sharing plan contribute to the health and resilience of the groundwater source and associated water dependent ecosystems?

- No issue in terms of breach of extraction limits - However, more work needs to be done to monitor and report on process and

outcomes for identifying groundwater dependent ecosystems as scheduled reviews have not occurred

- LLS needs this information to meet its objective of contributing to maintenance and restoration of GDEs in the region

How can the health and resilience of the groundwater source and associated water dependent


- Current hydro monitoring otherwise suggests resource is tracking well in terms of

pressure, levels and quality against baseline - However, need to ensure climate change projections are considered in long term

planning

o How could confidence in the extent, nature and water needs of groundwater dependent ecosystems be improved?

o Are there concerns about groundwater pressure, levels and water quality?

o Are there alternative means for meeting water needs of groundwater dependent ecosystems to that included in the water sharing plans (e.g. through targeted watering using water access licences)?

Hunter Local Land Services 816 Tocal Road (Private Bag 2010) Paterson NSW 2421 Tel: 02 4930 1030 | Fax: 02 4930 1013 | www.lls.nsw.gov.au/hunter

Objective File Reference: HCR06173 (A3044927)

Review of the Paterson Regulated River Water Sharing Plan

Natural Resources Commission

GPO Box 4206

Sydney NSW 2001

Submission on the Review of the Paterson Regulated River Water

Sharing Plan

Dear Sir/ Madam,

Hunter Local Land Services (LLS) is pleased to make a submission on the review of the Water

Sharing Plan for the Paterson Regulated River Water Source regarding the decision to replace

or extend the plan when it reaches the end of its term in 2017.

Hunter LLS works with land managers and the community to improve primary production within

healthy landscapes and assist rural and regional communities to be resilient, profitable and

sustainable into the future. Hunter LLS understands the Natural Resource Commission’s role is

to advise the Minister on:

the extent of the water sharing plan’s contribution to the state priorities for Local Land

Services that relate to natural resource management (as defined in the NSW Local Land

Services Act 2013).

whether changes to water sharing plan provisions are warranted.

General Comments

Hunter LLS provides the following comments in relation to the extent the WSP’s contribute to

the state priorities of Local Land Services as well as the Hunter’s priorities as contained in our

Draft Local Strategic Plan.

The Hunter LLS Draft Local Strategic Plan (not yet available for public consultation) identifies a

number of priorities relating to water management including the priority to work with

stakeholders and land managers on surface and groundwater resource availability that sustains

productive agriculture and natural assets.

While Hunter LLS does not have a direct role in the implementation of the water sharing plans,

Hunter LLS can provide a regional perspective on environmental water management and assist

Hunter Local Land Services 2

in coordinating effective communication with regional communities on environmental water

management and extension on sustainable water use in agriculture.

Consistency with rules for the Hunter Regulated Water Sharing Plan (WSP)

The process to replace the Hunter Regulated WSP is in train at the current time. There are a

variety of rules changes that have been drafted for consideration, some of which will make the

operation of the plan more simple and flexible for water users.

Water users in the Paterson Regulated Water Sharing Plan should be afforded equivalent rules

and flexibility as is agreed when the Hunter Regulated WSP is adopted to provide equity.

Environmental Contingency Allowance and Environmental Water Advisory Group

The Paterson River Water Sharing Plan has planned environmental water provisions including

flow targets at reference sites, sharing of supplementary flow events and an environmental

contingency allowance (ECA). Under the plan an ECA of 2000 ML is to be reserved at the start

of each water year in Lostock Dam. The ECA account cannot be carried over and resets at the

beginning of each water year.

The Plan allows for releases of the ECA to be made in accordance with procedures established

by the Minister to assist in management of critical environmental events, such as algal blooms

and chemical spills, and to provide flows at critical times for purposes such as fish migration or

stony bed scouring, and identified environmental benefits within the Plan area.

To date the Paterson Regulated River ECA has only been used once as part of a study to

measure the benefits of environmental flow releases in February 20071. As for the Hunter

Regulated River, the Paterson ECA has not been used to date because there was no formal

release program or identified environmental benefits within the Plan area.

In 2012 an Environmental Water Advisory Group was established to administer the

Environmental Water of both the Hunter Regulated River Water Source and the Paterson

Regulated River Water Source. The Group was Chaired by Susan Hooke (the current Chair of

Hunter LLS) and coordinated by an Executive Officer from Hunter LLS. A draft discussion

paper intended as a starting point for developing a robust and adaptable framework for

administering and implementing the environmental water allowance in the Hunter and Paterson

Rivers was prepared for the Environmental Water Advisory Group. The paper was not adopted

or implemented as the Group was unofficially suspended in 2013 (after 2 meetings), when the

Office of Environmental and Heritage was restructured and the Catchment Management

Authority was absorbed into Local Land Services.

In regards to the Environmental Water Advisory Group governance arrangements Hunter LLS is

interested in being represented on the Group and providing input on the use of environmental

water including any approved expansion of its purpose as it applies to both the Hunter and

1 Rolls R.J., Boulton A.J., Gowns I.O. and Maxwell S.E. 2010. Response by Fish Assemblages to an

Environmental Flow Release in a Temperate Coastal Australian River: A Paired Catchment Analysis

Hunter Local Land Services 3

Paterson regulated rivers. Hunter LLS considers the development of a robust accountability

framework for implementing the ECA, and associated governance arrangement a priority of a

replacement plan.

Monitoring, evaluation and reporting

Hunter LLS is interested in obtaining a report card on the effectiveness of the implementation of

the Water Sharing Plan for the Paterson Regulated River to gain an understanding of how much

water was allocated and utilised over the reporting period / past plan period, and performance

against its objectives and performance indicators. Absence of appropriate performance

reporting for implementation of the water sharing plan would potentially undermine the veracity

of, and public confidence in, the plan.

Cultural uses and values of water

Hunter LLS has established an Aboriginal Community Advisory Group to provide advice on

priorities and programs for delivery in the Hunter Region. As yet this Group has not provided

input to the identification of water dependent cultural assets, however Hunter LLS would be

supportive of raising this item at the next meeting and inviting representatives from DPI Water or

the Natural Resources Commission to attend.

It is noted that the draft Water Sharing Plan for the Hunter Regulated River contains a new

cultural purpose for which the environmental water allowance can be used for. Hunter LLS

considers that the environmental contingency allowance in the Paterson River Water Sharing

Plan should be consistent with that of the Hunter Regulated River and hence include provisions

that state the environmental water may be used for servicing environmental assets or

environmental functions of Aboriginal cultural significance.

Hunter LLS looks forward to participating in any additional consultation processes as the plan is

finalised. If you require any further information regarding this submission, please do not hesitate

to contact Karen Fitzherbert on 4938 4923 or email [email protected] for

assistance.

Kind regards,

Cal Cotter

Manager Land Services

24 September 2015

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