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November 24th, 2004
Water Resources
Department of Primary Industries, Water and Environment
13 St Johns Avenue
New Town
TAS 7008
To Whom It May Concern:
Re: Draft Little Swanport Catchment Water Management Plan 2004
Thank you for this opportunity to provide stakeholder comment on the Draft Little Swanport Catchment Water Management Plan 2004 (LSCWMP).
It is perhaps germane to this submission to provide a very brief overview of the Tasmanian Fishing Industry Council (TFIC) and the seafood industry in Tasmania.
TFIC is the peak representative body for all Tasmanian licenced commercial fishermen, marine farmers and seafood processors. Our members catch and produce over 22,000 tonnes of seafood each year with a landed value in excess of $300 million per annum.
Sea fisheries and marine farming provide employment for around 7000 Tasmanians in the catch and post-catch sectors, and approximately 56% of the Tasmanian seafood production by value is exported earning valuable export revenue for our state and nation.
Our members in the Little Swanport estuary are no exception to this, providing significant employment to the region, with demonstrably high returns to the community that are estimated to be ~$31,500 per hectare (of marine farm lease) per annum.
Shellfish Culture Ltd. Nursery
The Little Swanport estuary contains the nursery for the shellfish hatchery company Shellfish Culture Ltd. This company produces Pacific oyster spat, with the production (taking into account annual fluctuations) supplying 70+% of the Pacific oyster spat for the Tasmanian and South Australian oyster farms, with a limited amount also going to New South Wales.
The importance of the quality and quantity of the freshwater input into the estuary can never be overstated, as the nursery relies 100% on the health of the ecosystem function, drawing water from the estuary to provide natural nutrition to the juvenile oysters. The value of this hatchery to the Australian economy is substantial. Ultimate returns to the Australian community and national GDP are measured by many millions of dollars, as the spat that is produced in the Little Swanport estuary is on-grown intra/interstate, then sold into national and international markets.
The effects of other catchment activities
Activities relating to water use within the catchment can have significant (often adverse) effects upon the ecosystem function within the waterways, as well as on the microscopic communities that are a vital part of that function. This is not only important for the environment and the oyster industry, but also for other recreationally/commercially caught fish species (or their food chain) that rely on that structural habitat for a part of their life cycle. The same water quality and quantity objectives are required for recreational and community needs.
The Tasmanian state policy on water management clearly states:
Part 2 - Objectives
6. Objectives of the Policy
6.1
The objectives of this policy are to:
a): focus water quality management on the achievement of water quality objectives which will maintain or enhance water quality and further the objectives of Tasmania's Resource Management and Planning System;1
When considering the LSCWMP in light of (Part 5:) Statutory Requirements and Assessments 2 , and then relating it to objective 6.1(a) above, i.e., "maintain or enhance", the objectives of the Resource Management and Planning System assume critical importance.
Hazard Analysis and Risk Assessment
To achieve these objectives, a full hazard analysis and risk assessment (relating to water activities) for the entire catchment is clearly needed. The assessments (relating to water activities) carried out within the Little Swanport catchment do not have a consistent structure, in that the requirement to identify hazards and the risk assessment of the likelihood of an event occurring (and any consequences of that event) are absent.
Comment within the LSCWMP appears to be subjective commentary, rather than informed outputs based on recognised and exhaustive protocols for hazard analysis and risk assessment (e.g., Australian Standards 3 ). Any hazards not identified within the early stages of any risk assessment are not carried through that assessment, ultimately leading to an underestimation of risk. This is most certainly the case with the LSCWMP.
Stakeholder meeting October 28th, 2004
An example of this was obvious at the public meeting (on the draft LSCWMP) held at the East Coaster Resort on October 28th 2004. The water managers were asked how they would implement management changes with regard to deteriorating water quality resulting from water use and activities in the upper catchment (at a level that caused environmental harm). The only answer forthcoming was that it would be considered under the review of the Plan after five years. This is clearly at odds with the objectives of Tasmanian Water Management Act 1999 as is evidenced below.
Water Management Act 1999
At the meeting described above, the water managers were unable to identify any other monitoring or adaptive management process to prevent environmental harm or degradation occurring from water use activities. This obviously needs to be addressed in a timely and effective manner.
Flows
The Little Swanport River is an 'almost' intermittent system, subject to both seasonal flood events and minimal flows (sometimes only from groundwater). The draft LSCWMP 'almost' recognises this in 5.3; Para 10, describing 'lower flows' and 'cease-to-flow events'. It also describes 'greater-than-natural' flows that occur as 'a result of water applied during the irrigation season that returns to the main stream… over summer'.
Additive and Cumulative Effects
These irrigation events do not happen in isolation, but are usually a part of a land-based primary production regime that includes the application of fertilisers that contain unnaturally concentrated levels of nitrogenous compounds and phosphates, as well as the seasonal application of various herbicides and pesticides. The residues of some of these chemicals can enter the waterways through both groundwater and runoff, with the potential for unnatural levels of nutrients to contribute to, or cause, eutrophication and algal blooms. Because of this, the additive and cumulative effects of upper catchment primary production activities can clearly cause degradation of the quality of water present in the system downstream.
Hydrological studies indicate that groundwaters contribute to river flows long after significant rain events have ceased (Leaman, 2004a) 4. During periods when the waterways cease to flow, the groundwaters can be a vehicle that can carry and concentrate nutrients and chemicals in pools for weeks.
The State Policy on Water Quality Management 1997 clearly states:
Division 2c - Setting Limits for Discharges to Groundwaters
24. Indirect or incidental contamination of groundwater
24.1
The person who is responsible for an activity which has the potential to indirectly cause the contamination of groundwater must ensure that appropriate safeguards are taken to minimise the risk and the extent of such contamination…
24.2
Regulatory authorities should use their powers to require compliance with clause 24.1 and should not approve applications to undertake activities which have the potential to indirectly cause the pollution of groundwater unless the proposal includes, or has attached as a condition of approval, safeguards which are consistent with best practice environmental management to minimise risk and the extent of the pollution.
(Italics added).
Regulatory Authority?
Given that municipal planning schemes do not appear to require the land-based primary producer to seek permission to change land-use, e.g., from drip irrigation to the intensive irrigation of pasture, or say, a change from grazing to plantation forestry (both representing a potential for increased risk), who is the regulatory authority described in 24.2? What adaptive management strategy is there in place to abate or mitigate environmental degradation and harm?
Groundwater
While the draft LSCWMP addresses this (in part) under 3.1.3, it only recognises the run-off of surface water, while groundwater is ignored entirely. Hydrological expert Leaman states very clearly that all groundwater needs to be assessed and included as a part of any management regime for this catchment 5 .
This is in keeping with the Council of Australian Governments (COAG) Intergovernmental Agreement on the Environment at 3.4.2.
- ensuring that environmental issues associated with the proposed project, program or policy will be taken into consideration in the decision making process
- ensuring that there is a proper examination of matters which significantly affect the environment;
The draft LSCWMP says:
'In addition the conditions should be included on the licence with a view to minimising the potential for such contamination'.
The word 'should' ensures that this remains simply an opinion. This part of the draft LSCWMP must be made prescriptive and mandatory as a licence condition for new water allocations.
It must be inclusive of a clear protocol for recording and reporting that water quality objectives (standards) are being achieved. This mechanism will allow for the 'maintenance or enhancement' as described above in the Tasmanian state policy on water management. The draft LSCWMP should include clear penalties for non-compliance, such as loss of licence, demerit points or fines.
Complementary Planning
The Act, the Policy, and the planning scheme or planning instrument (in this case the draft LSCWMP) all need to be in compliance with each other, leading neatly from one to the other. This not the case with the draft LSCWMP. The plan in this form has the potential to cause environmental harm, particularly during low flow periods when the pools of water maintain the biological diversity of the system. These are at risk of being subject to the introduction of unnatural levels of nutrients (often from groundwater that continues to replenish the pools), resulting in eutrophication and actual environmental harm.
There are eutrophication events now evidenced within the catchment. Preliminary water surveys by DPIWE demonstrate numerous sites within the catchment as exceeding ANZECC guidelines for nutrients 6 . This is of particular concern during times of low flow periods that can also send a concentrated pulse of this degraded water downstream during or after a rain event.
Water Quality Objectives (WQOs) and Water Quality Targets (WQTs)
The State Policy on Water Quality Management (1997) clearly states:
9.1: Water quality objectives for a specific body of water are the most stringent set of water quality guidelines which should be met to achieve all of the protected environmental values nominated for that body of water.
WQO's and WQTs have not been established for this catchment, although Protected Environmental Values (PEVs) have been set. Neither has there been an agreed monitoring system been put in place to achieve these objectives.
The draft LSCWMP (4.9) describes monitoring of water quality parameters at only two points within the catchment. This clearly unsatisfactory and ineffective, especially when considering the need for adaptive management of this resource. The level of monitoring and the cost of monitoring need to be clearly stated in the plan.
For example, the oyster growers in the estuary currently pay ~$4000 annually to monitor water quality as a mandatory licence condition. With gravitational forces bringing downstream all that goes in to it from all of the catchment, surely this cost imposed solely on our members at the bottom of the catchment should be shared with all primary production water users within the entire catchment. Why is it that the 'victim' has to bear the cost for inputs beyond their control? They are paying to monitor inputs that they can not even influence, while those responsible for those inputs appear to be immune from any levy or cost to monitor the results of their activities.
Moratorium
Until WQOs have been set, and an agreed monitoring system put in place to allow for adaptive management to achieve WQO's (in keeping with the PEVs), there should be a moratorium on any new allocations of water (except for stock and domestic). There has been a precedent, as was the case with marine farming when no new leases were granted until management controls and licence conditions were developed and established under marine farming development plans.
A moratorium is justified in this instance, as sustainable development must be 'in a way, or at a rate that…' 7 ensures environmental protection for, and responsible use by, all stakeholders (See Act definition of 'sustainable development' above). As the draft LSCWMP stands, its focus appears to be more on further development with exploitation of an over-allocated and diminishing resource, rather than affording protection for the environment and existing major users of the water downstream in the lower catchment. It is clearly not in compliance with the objectives of the Act, or the State Policy on water quality management, with which this plan must comply.
Existing Models
The SKM 8 assessment of the water available in the catchment appears to be seriously flawed. It uses dated data from the 1971 - 1990 gauging period, ignoring factors such as losses through evaporation from irrigation sprays and from the surface of water storage dams. The scenario appears to ignore the fact that there has been a recorded reduction in precipitation in the region since those years.
Neither do SKM nor Thompson & Brett 9 consider groundwater in their assessments of water availability to the catchment or account for forestry plantations, present or planned. Is there an accurate database that details the status, take and capacity of all dams and water storage facilities within this catchment? If not, the lack of this single factor skews any estimate of water capacity. Without an accurate idea of quantity, allocation becomes risky management that could easily leave the environment and downstream resource users vulnerable.
An accurate audit has yet to determine exactly how much water is actually available to users while maintaining the integrity of ecosystem processes. A new audit should be based on realistic figures, benchmarked and established for both ground and surface waters, taking into account all contributing factors as above, including estimates of evaporation and the recorded reduction of precipitation as predicted due to global warming. Catchment water data from the adjacent catchments may be more useful for some of these factors than the dated and limited data used by SKM, and Thompson & Brett.
Opportunities
While addressing the issue, the draft LSCWMP should be stronger in encouraging the establishment of riparian vegetation buffer zones along all waterways. This will reduce the incidences of stock entering the waterways, will reduce sedimentation from degraded stream banks and act as a natural biofilter for the numerous unnatural inputs entering the waterways.
The draft LSCWMP gives the opportunity to encourage more efficient use of water, such as more effective irrigation techniques, replenishment of aquifers etc. It also presents an opportunity to encourage an audit for the best use of the land (capacity and capability) in the upper catchment. Soil testing for chemical composition and degradation may provide indicators for more effective or appropriate crops and land management practices that give an opportunity for more efficient water usage in the upper catchment.
Thank you once again for the opportunity to have input into this very important issue.
Yours sincerely,
Ralph Mitchell
Executive Officer
References:
1): State Policy on Water Quality Management 1997
2): Draft Little Swanport Catchment Water Management Plan. DPIWE Water Assessment and Planning Branch - September 2004. Page 15.
3): Crawford, 2003. Qualitative risk assessment of shellfish farming on the environment in Tasmania Australia. (In) Ocean and Coastal Management, Vol. 46, pp 47 - 58
4): Leaman, D. E., 2004a Hydrological assessment of some dolerite catchments in eastern Tasmania. Research Report, Leaman Geophysics, January.
5): Leaman, D., (2004); Management of the Little Swanport River: with particular reference to a dam at Stonehenge
6): State of Rivers Reporting in the Little Swanport Catchment, DPIWE 2004
7): Water Management Act 1999, Schedule 1
8): Sinclair Knight Mertz (SKM), 2004. Little Swanport River Catchment - Water Balance Model and Scenario Assessment. January.
9): Thompson & Brett Pty Ltd., 2004. Proposed dam on the Little Swanport River - Stonehenge. Water Assessment Report. January.
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