19.1  Environmental Report 2000 compliance issues

During 2000/2001 a more systematic process of reviewing compliance with the LWMP HoA has been implemented.  Government agencies provided a Combined Agencies Response (CAR).  The representatives of DLWC, EPA and NSW Agriculture presented their assessment of compliance to the CEC.  The CEC members also had the opportunity to present issues important to the community.

Both the EPA and DLWC provided detailed feedback on issues related to the Environment Protection and Works Licences, and assessment of compliance with licence conditions.

19.1.1  Works Licence related issues

In response to CICL’s 2000 AER, DLWC made three specific requests and 10 recommendations.  All requests made by DLWC were acted upon promptly. 

CICL agreed to six of the 10 recommendations. For two of the agreed six recommendations, CICL has commenced action. For another two of the agreed recommendations CICL has agreed to report on subsequent actions in the next AER.  For the remaining two agreed recommendations DLWC has to act before CICL makes any contribution.  CICL’s response to three requests and all 10 recommendations is summarised below:

Comments on DLWC’s recommendations

  1. It is recommended that a meeting be held with appropriate people to finalise the list (of piezometers) and consider the method of (watertable) analysis, which can then be used for next year’s AER.

  1. It is recommended that average groundwater values based on contouring be used for the calculation of sub district averages and Coleambally as a whole.

  1. It is recommended that the methods used above (‘Kriging or Inverse distance power 3’ for groundwater contouring) be re-considered for future AER.

In the AERs attempts have been made to use the same analysis technique to identify changes in the trends for various environmental parameters.  A number of key environmental parameters in the report are best estimates.  Examples of these are the areas within various watertable depths and the proportions of land within specific soil salinity ranges.

It is CICL’s opinion that the analysis methods used in the AER must be consistent with the data availability and data accuracy.  In the past CICL has demonstrated its commitment to collecting all the relevant data with a high level of accuracy.  The initiatives taken by CICL for the collection of EM-31 data and the achievement of improvements in the geo-referencing of aerial photographs have been recognised in all circles.

CICL intends to continually improve its data collection, storage, management and analysis.  Recently CICL made significant investments in developing systems that will make CICL’s data more accessible to its customers and stakeholders.

  1. It is recommended that once DLWC completes its review of CICL’s salt loads, CICL should adopt a different method of reporting its assessment of real trends in salt loads.

CICL agrees with the recommendation. CICL and DLWC have commenced discussions on the issue to achieve agreement on salt loads.

  1. It is recommended that CICL ensures that the trace of EC data from continuous data loggers is corrected for field sampled EC values collected about once a fortnight, before it uses the information to calculate salt load.

CICL agrees.  This information will be incorporated in futureAERs.

  1. It is recommended that the baseline and targets should be changed to realistic values for future reporting of soil salinity.

CICL agrees and requests DLWC commence work on the issue.

  1. It is recommended that CICL continuously review its policy regarding salinity and salt load management in its area.

CICL agrees.  This is being achieved through discussions with the CEC.

  1. It is recommended that statistics as required by the LWMP be included in the future AERs.

CICL agrees.  This information has been incorporated in Chapter 2, Chapter 9 and at other places in the report.

  1. It is recommended that CICL consider the effect of changing cropping practices on the fertility status and sustainability.

NSW Agriculture is the leading agency for soil investigations; including fertility, sodicity and acidity.  A project on the soil fertility status of macro and micro soil nutrients in rice growing areas is near completion.  The project includes over 50 sites in the CIA.  CICL will access the information once the project is complete.  CICL has already commenced an Education Program unit on fertiliser management, which provides updated information to the landholders.

  1. It is recommended that CICL and DLWC come to a suitable arrangement for incorporating groundwater usage.

CICL agrees with the recommendation. CICL and DLWC have commenced discussions on the issue to achieve an agreement.

Requests made by DLWC

  1. It is requested that CICL provide its rice policy.
  2. It is requested that CICL supply further information on NRM implementation program.
  3. It is requested that CICL clarify the NRM criteria for Southern Coleambally.

All requests have been met promptly.

19.1.2  Environment Protection Licence related issues

The EPA’s response states “the 1999/00 Environment Report reviews environmental performance and generally complies with reporting conditions of the Pollution Control Licence”.

Apart from the above comments the EPA has suggested some improvements and sought clarification on some issues. 

Non-compliance

The EPA has identified two non-compliances against condition R5.3 (f) and R5.3 (g) of the EPL.  The condition R 5.3 (f) requires that the licensee must report the progress of the implementation of the Irrigation Waste Water Control Program (recycling systems).  The condition R5.3 (g) requires that the licensee must report the chemical used by the landholders on their farms.

In the AER 2000 CICL assessed compliance against these issues as “partial compliance”.  The progress on implementation of recycling systems is slow and CICL, EPA and LWMPAT are negotiating to find ways of speeding up the progress of recycling system implementation. 

CICL collects the information on chemicals used by the landholders on their properties through the landholder survey.  In the past this information has been found to be of poor quality and has not been reported in the AER.  CICL proposes to collect this information through chemical suppliers.  Since this will be additional work for chemical suppliers, and with no incentive, CICL proposes to collect this information once every five years.

Other issues raised by EPA in response to the EPL:

There appears to be discrepancy between water delivered (for licensed entitlements) (311 GL) and water delivered to the three LWMP areas (338 GL).  This is probably due to a drainage component in COD District.

Yes.  Water delivered to the COD area is re-use of drainage water allocated to the farms upstream in the CIA.  Therefore, 311 GL is delivered against the licensed entitlements whereas water delivered to the COD LWMP area is drainage water from CIA farms re-used in COD.

Reporting of water inputs to the CIA are somewhat messy, particularly the volume of groundwater bores.

Agreed.  CICL receives bore groundwater usage information from DLWC.  CICL has raised the issue regarding this information with DLWC (see AER 2000 and AER 1999) and currently DLWC and CICL are working to improve the quality of this information.

There is no record in the AER of how many recycling systems currently exist in Coleambally and whether they meet LWMP requirements.  It is recommended that this information should be included in the future AER.

The information has been included in section 9.3.
© Coleambally Irrigation 2001