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Help Protect Groundwater – Submission draft and Guideline

GREAT ARTESIAN BASIN DRAFT WATER PLAN

The Draft Water Plan has been released and is open for comment until 5pm on Tuesday 18 April 2017.

To help you with your submission, EDO NQ and CSG Free NQ have prepared a template submission as set out below. This tells you who to address your submission to, where to email it to, and the key points.

Submissions are always more powerful if you can include your own examples, facts, stories and passion.

The significant policy gap that puts our precious groundwater at risk is the poor regulation of the water that both the mining and petroleum and gas industry’s take as a consequence of drilling for resources. The water is taken according to a statutory right, but this ‘associated water’ is not monitored for quantity or quality. Setting a volumetric limit for the take of groundwater does not make sense if it does not include all groundwater. More water for resources means less water for groundwater-dependent ecosystems such as ecologically and culturally significant springs. Say no to unregulated take of water and no to depletion of our precious ecosystems.

 

[insert date]
Your email]
Your telephone
Your return address
[Your name, organisation

Chief Executive
Attention: Diana Ly
Department of Natural Resources and Mines
PO Box 15216
City East QLD 4002

By email: wrpGreatArtesianBasin@dnrm.qld.gov.au

Dear Chief Executive, DNRM,

Submission on Draft Great Artesian Basin and other regional aquifers water plan, management protocol and water entitlement notice

Thank you for the opportunity to make a submission in relation to the Draft Great Artesian Basin and other regional aquifers (GABORA) water plan, management protocol and water entitlement notice released on 6 January 2017.

[Insert who you are or who your organisation is and why you or your organisation is making this submission]

[Insert your own examples from your own experience or your region and any evidence or information in support]

SUGGESTIONS TO HELP YOU WRITE YOUR SUBMISSION (these are more effective if you can write them in your own words and use your own examples or evidence}

Environmental outcomes
The Water Plan must state the desired economic, social and environmental outcomes of the management and allocation of water. The Draft Water Plan fails to state the desired environmental outcomes for the use of associated water by the petroleum and gas industry. In particular, the plan should state the requirements for monitoring the quantity of associated water used by the petroleum and gas industry; and the requirements for protecting water quality or monitoring water quality parameters.

Petroleum and gas industry under regulated
The sources of water for the dewatering of mines by the mining industry and the groundwater required to ‘make good’ impaired bores by both the petroleum and gas and mining industries are not stated in the Draft Water Plan. It is not clear whether this water is intended to come from the reserves of unallocated water and if so, whether it is the General, State or Indigenous Reserve of unallocated water.

In fact, the take of water by both the petroleum and gas and mining industries is not addressed at all in the Draft Water Plan and this is a significant gap in the understanding of water usage and therefore protection of groundwater. Just one instance is the recent unlimited groundwater allowance given by the Queensland government to the Adani Carmichael coal mine in the Galilee basin. This allowance could be as much as 26 million litres per day at maximum coal production and 355 billion litres over the proposed life of the mine, this is equivalent to almost two thirds of the volume of Sydney Harbour removed from this one mine and discharged to the surface along with all the salt it contains. The potential impact of drawdown and salinity for adjacent farmers dependent on borewater is enormous. The proposed “make good” provisions are totally inadequate and attempt to compensate for harm rather than avoid it.

The bore separation distances in the draft management protocol are clearly imposed to protect groundwater. However, the separation distances do not appear to apply to coal seam gas wells and ‘make good’ arrangements.

The overall volume of water – section 13 of Draft Water Plan
Whilst the decision not to increase the average volume of water taken from the Great Artesian Basin is welcomed, how can this decision be effectively implemented when: not all bores are monitored; and the take of associated water by both the petroleum and gas and mining industries is not monitored or regulated.

Associated water
Under the Water Act 2000, both the mining and petroleum and gas industries are granted a statutory right to take associated water. Any decision about water allocation under the Water Act 2000 is governed by the purposes of the Act, which include providing a framework for “…the management of impacts on underground water caused by the exercise of underground water rights by the resource sector (see section 2(1)(c)).”

Associated water is not accounted for in the Draft Water Plan, by way of monitoring of the quantity of water taken or monitoring water quality. Associated water must be accounted for, particularly because of the known impacts of contamination of water from coal seam gas and other unconventional gas winning practices.

Monitoring – inadequate and lack of transparency
The government’s own environmental assessment, the Review of Water Resource (Great Artesian Basin) Plan 2006 – Environmental Assessment Report prepared by the Department of Science, Information, Technology and Innovation (environmental assessment report), said monitoring of groundwater dependent springs was poor or non existent.

The monitoring requirements for groundwater dependent ecosystems in the management protocol are vague and non-specific and do not improve on the existing 2006 Water Plan.

There is no indication in the Draft Water Plan where the groundwater dependent ecosystem data is held or whether the data or results are publicly available.

Groundwater dependent ecosystems must be protected
The purposes of the draft water plan include identifying priorities and mechanisms for dealing with future water requirements and to provide a framework for reversing, if practicable, the degradation of natural ecosystems (see section 2 of the draft water plan). The outcomes sought include: “…to protect the flow of water to groundwater-dependent ecosystems that support significant cultural and environmental values” (see section 11(a)(i) of the draft water plan)”.

The government’s own environmental assessment report provides that one quarter of the GAB springs have not been assessed or classified. Of those that have been assessed and classified only half have been classified as having ecological value. The basis for this classification appears to be that the spring supports endemic species or species that have a restricted distribution. However, neither the Water Act 2000, draft water plan nor the management protocol define what the cultural and environmental values are and what the criteria for determining whether those values are significant are.

The draft water plan needs to set out a framework for assessment and classification of springs because this knowledge is important for the conservation of these ecosystems. However, it is not clear why the flow of water is protected to only those ecosystems that support “significant” cultural and environmental values.  If the purpose of the plan is to “reverse” degradation of natural ecosystems, then the flow of water to all ecosystems, no matter what their state of health is, must be protected.

Another outcome of the draft water plan is to manage and allocate groundwater in recognition that the state of aquifers and ecosystems has changed because of the past use of groundwater (see section 11(b) of the draft water plan). This outcome is alarming if it seeks to raise the baseline for what a healthy aquifer or ecosystem is. This outcome should be clarified to make sure it means that recognition of change is a reason to seek to reverse degradation and not a reason to avoid enhancing modified or degraded ecosystems.

Whole of government approach to water management and environmental protection
A whole of government (both intra- and inter-government) approach to the management of groundwater appears to be lacking in the documents.

The Great Artesian Basin is a national asset that should be managed in accordance with national priorities. Since 2001, the community of native species dependent on natural discharge of groundwater from Great Artesian Basins have been listed as an endangered threatened ecological community under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act). The Threatened Species Scientific Committee listed the community on the basis of a decline in geographic distribution due to the excessive extraction of artesian groundwater from the Great Artesian Basin.

The Recovery Plan for the community of native species dependent on natural discharge of groundwater from the Great Artesian Basin, 2010 (State of Queensland, DERM, p. 22) provides that the future actions to reduce the threats of aquifer draw-down include completion of bore capping; ensure future water allocations preserve spring flow; development of capacity to monitor spring flows; monitor the impacts of coal seam gas and petroleum extraction on aquifer draw-down. As already pointed out, the draft water plan and management protocol do not implement the future actions recommended at the national level.

The recommendations of the government’s own environmental assessment report of the existing 2006 water plan have not been adopted.

There is no mention of how ecosystems can be included in the protected area estate in order to meet the Queensland and Australia’s obligations under the United Nations Convention on Biological Diversity target of increasing the coverage of the protected area estate from to 8% to 17%.

Yours sincerely,

[signature  – although not needed if by email]
[INSERT your name, role in organisation]

Kind regards,
Tania Heber
Principal solicitor, EDO NQ 

Anthony Too
President, CSG Free NQ
6 April 2017

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