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Government of South Australia Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island Environment Protection and Biodiversity Conservation Act 1999 Reference: Number 2007/3484 July 2009

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Page 1: Supplementary Environmental Impact Statement

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Environment Protection and Biodiversity Conservation Act 1999 Reference Number 20073484

July 2009

Permissive Licence

This document may be reproduced in whole or part for the purpose of study or training subject to the inclusion of an acknowledgement of the source and to its not being used for commercial purposes or sale Reproduction for purposes other than those given above requires the prior written permission of the Department for Environment and Heritage

Disclaimer

While reasonable efforts have been made to ensure the contents of this publication are factually correct the Department for Environment and Heritage makes no representations and accepts no responsibility for the accuracy completeness or fitness for any particular purpose of the contents and shall not be liable for any loss or damage that may be occasioned directly or indirectly through the use of or reliance on the contents of this publication

Reference to any company product or service in this publication should not be taken as a Departmental endorsement of the company product or service

Acknowledgements

The South Australian Government acknowledges the Ngarrindjeri People as traditional owners within the lands where the temporary weir is proposed

The Department for Environment and Heritage would like to express appreciation to the Lower River and Lakes residents organisations and community groups and the numerous people who gave their time and expertise to the development of this report A large number of people contributed in the overall development process including through participation in working groups submissions Community Information Sessions and Targeted Group Information Sessions

Submissions received during Public Consultation

This Supplementary Environmental Impact Statement (Supplementary EIS) addresses the issues raised that are within the scope of the Guidelines for the content of the Draft Environmental Impact statement on the proposed temporary weir at Pomanda Island near Wellington South Australia published on 30 August 2007 in written submissions during the period for Community Consultation The Draft EIS was submitted to the Australian Minister for the Environment Heritage and the Arts in early Marc h 2009 Written submissions from any person or organisation who believes they can improve refine correct inaccuracies or generally add value to the draft Environmental Impact Statement on the proposed temporary weir near Pomanda Island were invited during the period of pub lic c onsulta tion from 12 Marc h 2009 to 9 April 2009

All submissions received are on the website at wwwenvironmentsagovaucllmmtemporaryshyweirhtml except where the respondent requested confidentiality

ISBN 978-1-921466-91-5

Printed July 2009

copy Department for Environment and Heritage

Format of Supplementary EIS

This Supplementary EIS is in two parts

Part One is the Supplement to the Draft EIS It provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report This Report over views and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Proponent s details

South Australian Government represented by

Name Peter Croft

Title Director Coorong Lower Lakes and Murray Mouth Projects

Department Department for Environment and Heritage

Address GPO Box 1047 ADELAIDE SA 5001

Proponent s environmental record

The South Australian Department for Environment and Heritage (DEH) is responsible for South Australias nature conservation heritage conservation and animal welfare

DEH collects and provides information and knowledge about the states environment

DEH manages the states public land including national parks marine parks botanic gardens and the coastline

DEH also advises on environmental policy

DEH is part of the Environment and Conservation Portfolio and reports to the South Australian Minister for Environment and Conservation DEH delivers the Governments environment policies d irectly and through partnerships These are with other government agencies including the Department of Water Land and Biodiversity Conservation (DWLBC) the Environment Protection Authority (EPA) Zero Waste SA Natural Resources Management Boards and Primary Industries and Resources SA as well as a wide range of non-government environment organisations industry bodies and the community

DEH s work is determined by its ob liga tion to ac hieve rela ted ta rgets in South Austra lia s Strategic Plan to administer legislation dedicated to the Minister for Environment and Conservation and to respond to the needs of South Australians

Table of Contents

PART ONE SUPPLEMENT TO THE DRAFT EIS 1

1 Introduction to the Supplementary Environmental Impact Statement (EIS) 2

Overview of Supplementary EIS structure 2 Purpose 2 DEWHA issues 2

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region 3

Submissions received and responses 3

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir 5

Submissions received and responses 5 Murray-Darling Basin Authority submission 5 The time required to remove the temporary weir 5 Floods 5 Phytophthora at the temporary weir construction site 6 Weir Causeway 7 Weir Site 7 Weir Construction and Environmental Management Plans 7 Weir Materials 8 Weir Crest 8 Pumping 8 Permanent Weir 8 Triggers for Removal 9 Salinity measuring locations 10 Decommissioning 11 Modelling 11 Virtual Weir 13

4 Supplementary comment on expected impacts of the temporary weir on soils and water 14

Introduction 14 Submissions received and responses 14 Acid Sulfate Soils (ASS) 14 Water quality 16 Wind seiche 16 Impacts upon Coorong and Lake Albert 17 Dredging of Murray Mouth 18 Water quality impacts near Narrung Narrows 18 Algal blooms 20 Summary of water quality impacts 21 Connectivity of Surface and Ground Waters 22 Surface Waters 22 Groundwater 23

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels 24

Introduction 24 Upstream impacts 24 Impacts of altered water regime in weir pool 24 Impacts to Pelican Lagoon and Nalpa Station 25

Weir Footp rint Impac ts 25 Impacts of Habitat LossDegradation 25 Impacts upon fish migration 26 Impacts of noise upon wetland birds 27 Monitoring during constructiondecommissioning 27 Timing of construction and presence of migratory species 28 Downstream impacts 28 Impacts of water level changes upon aquatic vegetation 28 Impacts of temporary increase in salinity upon aquatic biota 28 Impacts upon tributary wetlands 31 Impacts upon the Milang Snipe sanctuary 31 Impacts upon primary determinants of ecological character 32 Impact upon keystone species 32 Impact upon habitat availability 32 Impact upon salinity 33 Impact upon turbidity and sedimentation patterns 33 Impact upon water levels 33 Impact upon water regime 33 Impacts upon migratory shorebirds 34 Impacts upon Australian Painted Snipe 34 Impacts upon Orange-bellied Parrot 34 Impacts upon Great Egret Cattle Egret and Caspian Tern 35 Impacts upon pelagic birds 35 Impacts upon bush birds 35 Impacts upon Mt Lofty Ranges Southern Emu Wren 36 Impacts upon White-bellied Sea Eagle 36 Issues of scope adequacy and definition 36 Adequacy of species and communities examined 36 Current status of waterbirds 37 Adequacy of EPBC Act threatened species and communities lists 37 Adequacy of discussion of EPBC Act-listed species 37 Omitted flora and fauna records 37 Definition of keystone spec ies 38 Spec ies c onsidered of partic ula r signific anc e 38 Adequacy of description of different wetland types 38 Regional importance of the Coorong Lower Lakes and Murray Mouth 38

6 Notes on significant issues outside the scope of the draft EIS For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities 39

Ngarrindjeri People 39 Social and economic issues 39 Climate change 40 Dust and health 40 Other themes 40

7 Suggested text changes errata additions clarifications and references 41

References 53

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA) 54

General comments 54 Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth 54 More specific comments 61 Water supply 68 Removal triggers (pg 1-6) 70 Wetlands 72 Re-wetting of upstream wetlands 75 Threatened and migratory species 77 Fishway 81

PART TWO COMMUNITY CONSULTATION REPORT 85

1 Introduction 86

2 Community Information Sessions 86

3 Targeted Meetings 89

4 Overview of media articles (see Appendix VII) 89

5 Receiving submissions and developing the Supplementary EIS 90

PART TWO COMMUNITY CONSULTATION REPORT - APPENDICES 93

Appendix I - Submissions received Individuals 94

Appendix II - Submissions received Organisations 96

Appendix III - Participants and notes from Targeted Meeting Sessions 97

Appendix IV - Organisations that participated in Community Information Sessions 109

Appendix V - Participants and notes from Community Information Sessions 110

Appendix VI - Advertising copy used in the consultation process 127

Appendix VII - Media generated by the consultation process 146

Appendix VIII -Summary information of enquiries and submissions for provision of the proposed temporary weir 148

Appendix IX - Table of submissions 149

Executive Summary

The purpose of this Supplementary Environmental Impact Statement (EIS) for the temporary weir near Pomanda Island is to address Issues of National Environmental Significance (NES) (as defined in the Environmental Protection and Biodiversity Conservation Act 1999) arising from written public submissions and government comment during the period of public consultation for the Draft EIS

Part One is the Supplement to the Draft EIS provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report provides an overview and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Part One of the Supplementary EIS is divided into 6 key sections

Section 1 contains an overview of the document

Section 2 considers the role of the temporary weir within the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth Region These comments are made in response to a number of submissions that suggested that the temporary weir was being considered in isolation

The sec tion outlines the Government s multi-faceted strategy to combat the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region

This strategy includes both long and short-term plans including worst-case scenario measures that would only be implemented as an option of last resort should a fresh-water solution not be found

Section 3 considers submissions relating principally to Chapter 5 of the Draft EIS Proposed Works to be Undertaken

The Murray-Darling Basin Authority (MDBA) submission outlined the approvals necessary under the Commonwealth Water Act 2007 and in particular under clause 49 50 and 63 of the Murray-Darling Basin Agreement

The South Australian Government submitted a detailed application to the MDBA on 15 May 2009

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process however the Authority sought details on the method of removal of the temporary weir in the event of a flood coming down the River

As the flood scenario was not discussed in the draft EIS it is addressed in the section 3 of the supplementary EIS

Any flood moving down the River is most likely to have originated in the upper reaches of the river system and can take up to six weeks to reach the temporary weir location During this time an assessment will be possible as to the appropriate method of management of the temporary weir structure

A significant cluster of submissions were made regarding triggers for removal or decommissioning of the temporary weir

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria stated in the Draft EIS remain appropriate

Other submissions considered in Section 3 relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the proposed temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir A number of submissions also raised concerns about modelling

By way of response section 3 outlines the environmental management framework for the temporary weir including an Environmental Management Plan which ensures management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Section 4 provides an overview of submissions relating to expected impacts of the temporary weir on soils and water

A number of submissions raised concerns regarding acid acidity and Acid Sulfate Soils (ASS) These submissions support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible

ASS field investigations and modelling will enable key information gaps to be addressed and be fed back into the ongoing planning and measures undertaken

Wind seiche and its impact on water quality also formed the basis of several submissions as did possible increases in algal blooms within the weir pool itself

While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes

Some submissions sought clarification regarding the interaction between surface and ground waters

Section 5 Submissions discussed in Section 5 relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

A process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Another issue of concern raised in many submissions is the potential impact of increased salinity within the Lower Lakes upon aquatic biota By way of response Section 5 adds considerable detail regarding predicted salinity changes and the likely biotic response

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Section 6 briefly overviews issues raised in submissions which lie outside the scope of the Supplementary EIS In some cases ideas were contributed which are worthy of note

There is a suggestion about the importance of consulting with and recognising the Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

Another submission argues for having more than one scenario when drafting the EIS (not only d rought but a lso c limate c hange) and another c ontextua lised the c urrent p red ic ament of

the Coorong Lower Lakes and Murray Mouth in ideologies about unsustainable growth

A number of submissions outlined the current social and economic conditions of the Coorong Lower Lakes and Murray Mouth region indicating that there is considerable social and economic suffering attributable to drought and over-allocation of River water

Many submissions expressed discontent with over allocation of water resources and a significant majority expressed opposition to the temporary weir A minority supported the temporary weir and some indicated a preference for seawater flooding of the Lower Lakes (rather than a limited incursion)

There was almost no comment about water security issues for Adelaide and the majority of South Australian country towns

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part OnE Supplement to the Draft EIS

1

1 Introduction to the Supplementary Environmental Impact Statement (EIS)

Overview of Supplementary EIS structure

Rather than replacing the Draft Environmental Impact Statement (EIS) this Supplementary EIS d iscusses those issues raised in submissions Thus most of the tables and figures from the Draft EIS are not repeated Section 7 of the Supplementary EIS lists a range of text changes (corrections deletions additions and minor clarifications)

Note This Supplementary EIS needs to be read in conjunction with the Draft EIS for the proposed temporary weir near Pomanda Island There is no re-written version of the Draft EIS

Purpose

The purpose of this Supplementary EIS for the temporary weir near Pomanda Island is to address issues relating to Matters of National Environmental Significance (NES) that are within the scope of the guidelines arising from written submissions lodged during the period of public consultation for the Draft EIS

DEWHA issues

The Commonwealth Department of the Environment Water Heritage and the Arts (DEWHA) raised a number of issues with the South Australian Department for Environment and Heritage (DEH) Many of these issues are pertinent to the Supplementary EIS and a copy of the response to these issues is provided in Appendix 1

Supplementary EIS for the temporary weir near Pomanda Island -2shy

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region

Submissions received and responses

A number of submissions suggested that the temporary weir was being considered in isolation and several suggested that there should be one encompassing environmental impact statement for actions being considered in the Coorong Lower Lakes and Murray Mouth (CLLMM)

The scale and complexity of the problems associated with lack of inflows to South Australia suggests that there must be a well coordinated set of solutions The South Australian Government has developed a multi-faceted strategy in response to the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region This involves development of a short-term strategy to protect the quality and access of major public water supplies to protect the local and regional environment from irreversible damage and to minimise adverse impacts on infrastructure and the regional community It also involves the development of a long-term management p lan Refer to tab le Summary of SA Government Projec ts in the Lower Lakes Coorong and Murray Mouth in Append ix 1 Question 3

Water security involves water quantity and quality to ensure a potable water supply to Adelaide and Regional South Australia The drought and anthropogenic1 uses have drastically reduced inflows to South Australia and water levels have dropped below Lock 1 (near Blanchetown) increasing salinity and exposing Acid Sulfate Soils (ASS) in the Lower Lakes The oxidation of ASS upon drying can result in acidic water and mobilised metals some of which are toxic to humans above certain concentrations The temporary weir aims to ensure adequate weir pool level for operation of the pumps supplying water to Adelaide and regional South Australia in addition to presenting a physical barrier to acidic andor saline water migrating upstream towards the pump stations from the Lower Lakes

The temporary weir is not considered the only solution to issues in this region The South Australian Government is writing a long-term p lan the initia l version entitled The Coorong Lower Lakes and Murray Mouth Directions for a healthy future This was released for pub lic comment during May 2009 Following a period of public consultation community feedback and with scientific input the final version of the long-term plan will be completed in October 2009 and submitted to the Australian Minister for the Environment Heritage and the Arts (MEHA) as required under the Murray Futures Funding Deed

In addition to the long-term plan the South Australian Government has had to take a number of emergency measures which while separate in their own right form part of a strategy of inter-connected short-term actions

The South Australian Government has referred five proposals to the MEHA for consideration under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) These are

A referral to establish a temporary weir near Pomanda Island (EPBC 20073484) which was determined to be a controlled action in July 2007 (the subject of this EIS process) The South Australian Government has stated that this temporary weir would only be constructed as a last resort and that the Government is continuing to pursue options for a freshwater solution The weir if approved and constructed would be a temporary weir aiming to protect the water supply of Adelaide and many country towns The draft EIS was released for public comment on 12 March 2009 This Supplementary EIS is prepared in response to public submissions that closed on 9 April 2009

A referral to upgrade the Pomanda Peninsula causeway to allow access to the temporary weir embankment site on Pomanda Island (EPBC 20084674) was referred to the MEHA on 23 December 2008 The Minister decided on 23 January 2009 that this p roposa l was not a c ontrolled ac tion

1 of relating to or resulting from the influence of human beings on nature

Supplementary EIS for the temporary weir near Pomanda Island -3shy

A referral to open the barrages that separate the Lower Lakes from the Coorong (EPBC 20084618) as a last resort should this prove necessary The aim of this proposal is to allow the controlled entry of a limited amount of seawater to maintain the water level in the Lower Lakes above the critical trigger level of acidification The proposal has been deemed a controlled action The final guidelines for the Content of a Draft Environmental Impact Statement were released on Friday 13 March 2009 (Note that The Murray-Darling Basin Ministerial Council approved a Real time management strategy to avoid acidification in the Lower Lakes (November 2008) involving the introduction of seawater through the Barrages when certain trigger points are reached The Council recognised the threat of acidification and approved this strategy essentially as a last resort)

A referral to construct a below ground pipeline that is capable of delivering 30 GL annually from the River Murray (at Jervois) to the Langhorne Creek and Currency Creek landowners was submitted on 18 February 2009 (EPBC 20094743) The pipeline will deliver irrigation water to communities and industries in the region that are currently reliant on the Lower Lakes for their water supplies This was assessed as not being a controlled action if undertaken in a particular manner and completion is scheduled for late 2009

An emergency first response referral to mitigate the multiple adverse impacts of Acid Sulfate Soil exposure in the Goolwa channel and its tributaries (Finniss River and Currency Creek) was submitted on 6 April 2009 (EPBC Reference No 20094833) This involves the construction (1) a temporary environmental flow regulator within the Goolwa Channel near Clayton (2) a temporary low-level regulator in the mouth of the Finniss River (3) a temporary low-level regulator in the mouth of Currency Creek The referral also involves pumping water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel This was assessed as not being a controlled action if undertaken in a particular manner

If more fresh water could be secured to flow into South Australia and Acid Sulfate Soil managed to mitigate impacts on water quality then the temporary weir would not be needed

Supplementary EIS for the temporary weir near Pomanda Island -4shy

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir

Submissions received and responses

Submissions discussed in this section generally relate to the content contained in the Draft EIS Chapter 5 titled Proposed Works to be Undertaken The major sections of that Chapter include weir location design parameters and time constraints construction environmental constraints and site selection alternative design options operation decommissioning and removal

Written comment received on Chapter 5 from the public and government agency respondents raised a wide range of issues A gap relating to the temporary weir and the effect of flood was identified and there was a significant cluster of submissions related to triggers for removal or decommissioning the temporary weir

Other submissions relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir

Murray-Darling Basin Authority submission

A submission from the Murray-Darling Basin Authority (MDBA) stated that approval for the construction of the temporary weir was required under clause 49 50 and 63 of the Murray-Darling Basin Agreement and detailed exactly what was required as part of the approval process The South Australian Government subsequently wrote to MDBA (15 May 2009) seeking approval for the construction of the temporary weir

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process However many of the details requested are relevant to the temporary weir

The MDBA sought details on

Quantifiable triggers for removal

The time required to remove the temporary weir

The method of removal if a flood is travelling down the river when the level of Lake Alexandrina is low

The effect of increased salinity levels

The effect of the potential increase in heavy metals and

The effect of an increased sediment rate of acid production around Pomanda Island

On 30 June 2009 the MDBA approved plans for the proposed weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

The time required to remove the temporary weir

Refer to discussion on floods below

Floods

The MDBA submission has requested information about the removal of a temporary weir during a flood

Response

Given the exceptionally low storage levels in the Murray-Darling Basin system it would take considerable rain over a prolonged period of time and throughout a significant proportion of the Basin to generate a flood of sufficient flow resulting in all the decommissioning triggers

Supplementary EIS for the temporary weir near Pomanda Island -5shy

specified in section 58 the draft EIS being met Should a flood event signal the achievement of the weir decommissioning triggers the decommissioning and removal would only proceed after the flood has passed

Nevertheless advice has been sought from relevant authorities regarding both the specific level of rainfall necessary to create flood conditions in the Murray-Darling Basin catchments and the lead time available to remove the temporary weir in the unlikely event of a flood

Any significant flood moving down the river is most likely to have originated in the upper reaches of the river system and therefore can be expected to take up to six weeks to reach the location of the temporary weir During this time an assessment will be possible as to the appropriate method of management of the structure of the temporary weir

The temporary weir contains a spillway which is designed to pass 15 GL a day with a minimal rise in the upper weir pool level This flow rate was given by the MDBA as a nominal upper flow limit for normal river management and represents a 15 fold increase from the current flow past Wellington of approximate 1 GL per day A design for higher flood events was not included in the draft EIS due to the expected very low probability of occurrence plus the expectation that if flood event were occurring then the river system would have recovered and the temporary weir would not be required

The impact of flood flows over the temporary weir are being reviewed and initial indications are that flows much greater than 50GL per day could be passed without the upper weir pool level rising above the normal full supply level (FSL) of 075m AHD

In the unlikely event of a significant flood two reactions are available Firstly the flood could be allowed to pass over the temporary weir or secondly a breach in the temporary weir could be made to assist passage of the additional flow

The choice of the best option depends on the flood flow size the water level in Lake Alexander and the degree to which it could be flushed by the flood and the likelihood that the temporary weir will still be required after the flood (ie whether the conditions for weir removal have been met)

If the temporary weir is required after the flood then breaching the weir is unlikely to be a preferred option If the flood is allowed to pass over the temporary weir the likelihood of significant damage will depend on both the size of the flood flow and the downstream water level It is expected that flood damage should be low due to the width of the spillway (This is still to be confirmed by additional design analysis)

In a worst case situation a sufficiently large breach in the temporary weir could be done in the available time The method of removal remains the same however the work method will need to control all risks associated with different upstream and downstream water levels that may exist

The South Australian Government will work with the MDBA to develop a weir flood management plan Given the current exceptionally low water levels throughout the Murray-Darling Basin system it would take considerable rain over a prolonged period and over a significant proportion of the Basin to generate a flood of sufficient flow to require removal of the temporary weir The low water levels in storages and the River system also provide the opportunity to regulate a large percentage of high flows

Phytophthora at the temporary weir construction site

One submission claimed that impacts of weeds and pests such as Phytophthora cinnamomi were omitted and that therefore the weir construction could potentially have a significant environmental impact

Response

The Draft EIS (chapter 15) provides details on the environmental management framework for the temporary weir including Environmental Management Plan (EMP) to ensure management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Supplementary EIS for the temporary weir near Pomanda Island -6shy

Once a contractor has been selected the contractor is expected to manage the temporary weir project in accordance with best practice mitigation measures to effectively reduce the environmental risks and avoid adverse impacts associated with site level impacts during the construction operation and decommissioning of the temporary weir

It is recognised that weeds and pests if not managed appropriately can present a long-term threat and impact on the native plant communities in the area

Consequently weed and pest management in general and the specific management of Phytophthora a re a c ritic a l element of the c ontrac tor s Environmenta l Management Plan (EMP) Selection criteria for contractors also include specific environmental compliance and best practice evidence

As part of this project detailed weed assessments will be conducted as part of the risk assessment in the Construction Environmental Management Plan (CEMP) via desktop studies (especially for Phytophthora) weed surveys and expert advice Project-specific mitigation measures are then included in the EMP and a specific (during and post-construction) weed management plan Specific measures may include but are not limited to

Avoidance of weed-infested areas for land-based construction activities (for example by relocating stockpile areas etc)

Construction activities restricted to approve construction corridors only

Weed management plan endorsed by the South Australian Murray-Darling Basin Natural Resource Management Board (SA MDB NRMB)

Wash-bay areas established according to weed management plan

Record kept of hygiene measures conducted prior to entering the site (for example plant trucks materials working clothes shoes boots etc)

Phytophthora cinnamomi distribution is contained to the wetter areas of the state It is highly unlikely that this fungus would be spread at the temporary weir site

For more information see httpwwwenvironmentsagovaubiodiversityplantsshyanimalsdiebackhtml

Weir Causeway

A submission claimed that as the level of the causeway would be higher than the temporary weir this would form a barrier and create new flow patterns

Response

There is no evidence that a flow path across the causeway exists with normal water level conditions The existing causeway and beach area on the western side contain no wash ways On the contrary there is evidence that only minor amounts of water in storm-driven waves have moved over the causeway

Weir Site

A submission from the SA MDB NRMB requests a better explanation of why this site is the preferred site

Response

This is explained through extensive studies summarised in Section 56 of the Draft EIS which concluded that no other feasible site exists down stream from Murray Bridge

Weir Construction and Environmental Management Plans

Some submissions criticised the lack of an EMP

Response

Specific mitigation measures will be developed in consultation with State environmental agencies to ensure that they are consistent with the relevant Acts and regulations (for example the Environment Protection Act 1993 (SA) the Natural Resources Management Act 2004 (SA))

Supplementary EIS for the temporary weir near Pomanda Island -7shy

The EMP is reviewed and endorsed by a number of agencies before any works can be carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) for the overarching EMP SA Water Corporation and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Weir Materials

One submission states that information about sourcing of material is not complete and raises doubts as to whether materials can be transported Will pollutants be introduced to the water

Response

The draft EIS (section 542) addressed the first two issues raised

The issue of pollutants to the Lake from the embankment material is covered in the requirements for an EMP and CEMP in the Draft EIS

One submission claims that mud waving will create a structure fault where the weir embankment fingers join It also claims that the structure will slip

The possible impact of mud waves on the structure is recognised and is one of the key elements in the c ontrac tor s c onstruc tion method The stab ility of the struc ture is a norma l design issue that is mitigated by using a design review process

The EIS provides all the available knowledge on material sources As the contracting method leaves the material source decisions to the contractor no further information will be available until a contract is awarded

Weir Crest

The MDBA requires confirmation that the temporary weir crest can resist erosion from flow

Response

Specific details for the temporary weir crest design were incorporated in an application sent to MDBA on 15 May 2009 This is not related to the draft EIS or the Supplementary EIS

Pumping

One submission claimed that the option of relocating the pump stations would involve a short timeframe and thus avoid the environmental impacts of constructing a temporary weir

Response

The option of re-locating pump stations is stated in the Draft EIS to involve a risk of continuity of supply The submission has also not recognised that the timeframe for moving a pump station individually upstream of Lock 1 (near Blanchetown) is similar to building a larger pump station upstream of Lock 1 and laying the required connecting pipeline Both options would require feasibility studies and engineering designs as well as the necessary State and Commonwealth approvals and assessments Should an EIS be required for these options it is envisaged that the projects would not be in place to ensure a potable water supply to Adelaide and Regional South Australia within the next two years

Permanent Weir

One submission claimed that impacts of permanent weirs are severe and therefore another weir should not be built on the River Murray

Supplementary EIS for the temporary weir near Pomanda Island -8shy

Response

The impacts have been examined and reported (See for example Draft EIS Section 831) taking into account the temporary nature of the proposed weir The Draft EIS concludes that the impacts of not building the temporary weir when critical trigger points are reached are more signific ant as muc h of South Austra lia s wa ter sec urity is threa tened

Triggers for Removal

A number of submissions claim that triggers are inappropriate because they specify conditions that have not prevailed for more than a decade and that they lack detail and are unlikely to occur within the next decade References are made to water levels in Murray-Darling Basin storages salinity in Lake Alexandrina and general water quality risks in Lake Alexandrina

Response

Triggers

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria as agreed by the Water Security Council and accepted by the MDBA and stated in section 58 of the Draft EIS remain appropriate

Removal of the temporary weir is highly dependant on the seasonal conditions as well as decisions by Murray-Darling Basin Ministerial Council on water sharing water recovery and water allocation policies The South Australian Government has selected a nominal 3 year life for the temporary weir as indicative

Stages

The graph below is available on the MDBA website and shows that storage levels dropped below the long-term average in 2002 and have not exceeded this since that time The time to recover storages to these levels is primarily dependent on inflows and while based on historical data it might take a series of years to recover to average inflows equally it could be much quicker in a single year with high inflow For this reason the life of the temporary weir has been referred to as nominally 3 years

Supplementary EIS for the temporary weir near Pomanda Island -9shy

Salinity in Lake Alexandrina

Similarly the graph below shows historical salinity levels in Lake Alexandrina where the salinity did not increase above 3000 EC (Electrical Conductivity) until 200708 This graph shows salinity averaged at four sites - A4261157 (Milang) A4261158 (West Pomanda Point) A4261133 (Beacon 90) and A4261156 (West Point McLeay)

Water quality in the Lakes is unlikely to improve until additional freshwater flows down the river to either dilute the Lake water or flush it to the sea The third trigger has been purposely expressed as water quality rather than salinity to allow for possible acidification impacts and associated mitigation measures

As fresh water flows eventually increase the salinity level in Lake Alexandrina will initially fall due to dilution and the Lake will fill with freshwater Salinity levels will then fall further as lake water is flushed to the Coorong and the ocean The extent of flushing required to reach the trigger level is dependent on how long the higher flows persist

Salinity measuring locations

One submission suggests that the target of 3000 EC lacks detail on where it is to be measured Another submission suggests that the target on storages should be replaced with a target on-flow to South Australia

Response

The 3000 EC trigger is intended to be a general salinity measurement in Lake Alexandrina Specifying a single measurement location is not appropriate because there can be areas of localised higher salinity and some of the sites where salinity has been measured over many years are now out of the water The intent is to take a rolling 7 day average over the four representative existing sites (Milang Mulgundawa Poltallock and Raukkan) Data from these sites have been collected for many years and existing protocols will be continued As part of these protocols the sampling sites have moved to accommodate the shift in shoreline

The flow to South Australia comprises a combination of ordered water (and South Australias entitlement flow of 1850 GL is in this category) and unregulated flow which is water that cannot be captured in Murray-Darling Basin (MDB) storages normally due to rainfall in the

Supplementary EIS for the temporary weir near Pomanda Island -10shy

lower parts of the catchment It is therefore possible to get high flows in any single year but the MDB storages could still be empty at the end of the year

It is only when the Hume and Dartmouth reservoirs have returned to normal operating levels (and other decommissioning triggers specified in section 58 the draft EIS have been met) that the South Australian Government can have confidence that the temporary weir would no longer be required The MDBA state that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

Decommissioning

A respondent questions how a structure designed for 3 years can be reconciled with a possible continuing drought and the removal triggers

Response

The temporary weir is designed to a nominal three year structural life and is expected to be removed when current drought conditions abate sufficiently with confidence that the improved River Murray flows are sustainable Detailed information on the triggers for decommissioning are specified in section 58 the draft EIS

As indicated in chapter 4 of the draft EIS the Murray-Darling Basin is six years into the worst drought on record It has led to low water River Murray flows over the border No-one knows when the drought is expected to end or how much water is expected to become available so it is necessary to plan for the worst scenario

Modelling

A number of submissions raised concerns about modelling

Water level forecasts may be incorrect due to assumptions about net evaporation There were questions about whether drought is the fundamental cause of the problem considering recent rainfall history in the Murray-Darling Basin

Modelling is only carried out for a period of 3 years despite the unknown length of the proposed operation

That modelling is only reported for an allocation to South Australia of 896 GL

That there is a lack of modelling results for temperature turbidity and acidification

That the temporary weir will cut off low water inflows

That water level modelling is flawed and underestimates local winter inflows

That the temporary weir will stop salts moving into Lake Alexandrina and these salts will be forced back into the River channel and

Further modelling particularly related to a virtual weir was sought

Response

The following graph (Department of Water Land and Biodiversity Conservation 020709) shows the drop in water levels in Lake Alexandrina over recent years The falls are quite uniform and the projections are consistent with recent history The models used have been accurate in projecting water levels to date

Supplementary EIS for the temporary weir near Pomanda Island -11shy

_

Lake Alexandrina Level

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Modelling projections have only been made for a period of 3 years because of the low probability of a continued period of extended drought and increasing uncertainty about future management responses Modelling using 896 GL flow over the South Australian border was used as it reflected the water sharing agreement for South Australia This figure is considered the worst case flow into South Australia

Flows to the Lower Lakes are currently determined by the minimum River flow needed to ensure that the maximum salinity at Murray Bridge remains within potable limits The temporary weir will not cut off flows to the Lower Lakes and once the pool behind the temporary weir is filled water will flow over the temporary weir into Lake Alexandrina at the rate of at least 350GL per annum

Modelling does not support the contention that the temporary weir will not prevent saline water from moving upstream into the River channel This is fully described in the Draft EIS

The Draft EIS acknowledged limitations with the model used to predict the movement of saline water in the Lakes but also notes that it provides the best information available and was based on numerous model runs (Refer also to section 443 of the Draft EIS) It is considered that running the models for a broader range of scenarios would not substantially alter the advice on impacts of the temporary weir The salinity model cannot be calibrated to a high level of certainty simply because there is no historic reference The current conditions are outside the bounds of normal lake operation

An adaptive approach will be required for managing the filling process for the pool upstream of the temporary weir to ensure that there is an appropriate balance between the various competing interests This will need to take into account issues such as technical constraints related to the construction program potential environmental impacts on Lake Alexandrina during the period of no flow or low flow to the lake flow requirements for the proposed fishway through the temporary weir and possible impacts on wetlands reclaimed swamp areas levee banks and the river bank as the water level rises upstream of the temporary weir Some of these issues will only become clear as the water level rises and the filling process will need to be adjusted in response to these impacts

It is apparent from the early contractor engagement process that the initial construction method adopted for the modelling described in the draft EIS will be slightly modified due to

Supplementary EIS for the temporary weir near Pomanda Island -12shy

technical constraints In addition a fishway will be provided through the temporary structure As a result of these factors the basic refilling process has been modified from that proposed at the time the draft EIS was published

The current proposal (assuming the inclusion of a fishway through the temporary weir) is to have a minimum dilution attraction flow of 200 MLday past the structure at all times during refilling An initial period of refill of some 2 to 3 weeks is proposed when level will be raised from -15m AHD to -12m AHD and the flow past the temporary weir would be limited to the 200 MLday This will be followed by a period of approximately 25 to 3 months when the level is held at -12m AHD and the passing flow will be approximately 1500 MLday Finally there will be a period of approximately 2 to 25 months as the temporary weir is refilled from -12m AHD to the nominal pool level of +01m AHD and the passing flow will be limited to approximately 200 MLday

However it is proposed that this refill strategy will be modified in response to any impacts arising from the refilling process as identified above

Virtual Weir

A submission suggests models need to be used with caution and asks whether models have been run at lower levels and with salinities less than seawater and what flow past Wellington would be needed to make a virtual weir work

Response

It is agreed that the model used to predict the movement of saline water from Lake Alexandrina to the River channel needs to be used with caution There is limited data with which to calibrate the model

The value of the model is to better understand the mechanisms of how saline water moves upstream and how it is dissipated This information is included in section 443 of the Draft EIS

The model indicates that current flow rates are too low to ensure mixing of fresh and saline water and prevent a saline layer making its way up the River Murray The modelling indicates that flows would need to increase by a factor of 5-10 times before this issue could be resolved As indicated in the draft EIS if this volume of water was available then no saline water would enter the river channel

Since the release of the Draft EIS the MDBA engaged WBM-BMT to undertake further hydrodynamic modelling to investigate the potential for and risks associated with a virtual weir Modelling will incorporate several months of new data and involves a number of new scenarios in respect of water levels lake salinities and wind strength direction and duration

It is anticipated that the outcome of this work will be available progressively during July and August 2009 and will further inform the technical feasibility of implementing a virtual weir

Supplementary EIS for the temporary weir near Pomanda Island -13shy

4 Supplementary comment on expected impacts of the temporary weir on soils and water

Introduction

The draft EIS involved discussion of soil and water quality impacts within many sections of most chapters The chapters specifically detailing soil and water quality impacts were

Chapter 8 Potential impacts of the proposed temporary weir

Chapter 10 Changes in water levels and salinity

Chapter 11 Soil and Water quality impacts

A significant number of submissions and government responses to the draft EIS included comments related to soil and water quality Government agencies such as the Environment Protection Authority (EPA) the Department of Water Land and Biodiversity Conservation (DWLBC) MDBA and the SA MDB NRMB have suggested changes in the light of new data or further information DEWHA has requested further clarification

Submissions received and responses

The major points raised by the submissions are detailed below along with responses involving a discussion and conclusion in regard to the points raised

Acid Sulfate Soils (ASS)

Submissions raised the following questions and concerns

Who is completing monitoring for alkalinity in Lake Alexandrina and where is monitoring data being stored Can the public or other agencies access this data

The lack of information about rates of acidification and potential release of metals (and metalloids) the mobilisation and flushing of acidity and associated contaminants (for example metals nutrients) to the water and the impacts of ASS and acidification on the ecology and ecological processes for example risks to species

The need to make more use of the considerable experience from elsewhere when dealing with ASS

The need to study acidity risks and environmental impacts associated with rewetting of wetlands upstream of the temporary weir

The need for information and data on hydraulics relating to flow cessation into Lake Alexandrina and sea water introduction and acidification thresholds

Not enough information on immediate and long-term implications of building the temporary weir (for example medium to low confidence in modelling of tipping point for acidification)

The need for additional modelling of acid and metal release

The need to address remedial actions necessary in the Lakes because of the accelerated decline in water level

Quantification of the risk of acid mobilisation upon re-wetting of River channel wetlands upstream of the weir site in general more consideration is needed to be given to these water bodies and

What are the mitigation measures planned if alkalinity levels reach 25mgL CaCO3

Response

As indicated below independent advice from leading international and Australian ASS scientists has been sought in order to increase knowledge on sulfide oxidation rates generation of contaminants (for example metals and nutrients) transport mechanisms and neutralisation dynamics

In 2008 the South Australian Government commissioned several reports into acidity metal mobilisation and water quality risks for the River Murray and Lower Lakes and it is further

Supplementary EIS for the temporary weir near Pomanda Island -14shy

prioritising investigations to assist with ASS mitigation and management options such as bioremediation

Such investigations can take from several months to years but once more information is available the models underpinning acidity and metal mobilisation impacts for this region can be better refined

Since August 2008 the SA MDB NRMB has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (for example sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (Report 1 March 2009 Available May 2009 wwwepasagovau) The EPA also compiles the raw data in a spreadsheet available to South Australian Government agencies

Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on the potential impact refilling wetlands will have on water quality of the Main River channel and the ecological impact of further acidification of wetlands

The

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes

Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the Murray-Darling Basin Authority Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from a DEH project identifying acidification remediation options for the Lower Lakes

Construction of regulating structures and other on-ground works for remediation at priority wetlands

Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRMB is managing the Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t with a steering c ommittee of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRMB DEH DWLBC MDBA SA Water Corporation EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of +01m AHD An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of the wetlands will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island for example wetlands providing important aquatic refuges

Conclusion

In conclusion it is agreed that the impact to River channel wetlands is an important issue that needs to be managed This is true irrespective of whether a temporary weir is constructed or

Supplementary EIS for the temporary weir near Pomanda Island -15shy

not Measures are already in place to minimise the risk to water quality in the River channel Refilling these wetlands will provide important aquatic refuges

The submissions on acid acidity and ASS support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible and be fed back into the ongoing planning and measures undertaken

In the meantime it is noted that there is extensive experience in dealing with ASS elsewhere Leading international and Australian ASS scientists with industry specialists have been contacted to provide independent advice and an ASS risk workshop involving many of Austra lia s soil and hyd rology sc ientists was rec ently held for the Lower Lakes If a lka linity levels reach 25mgL CaCO3L immediate mitigation measures such as limestone slurry dosing of the water in affected areas are expected to be undertaken

Recent information on ASS bioremediation and dust issues for the Coorong Lower Lakes and Murray Mouth reg ion is ava ilab le from the South Austra lian Government s Environment web page httpwwwenvironmentsagovaucllmmfaqs-acid-sulfate-soilshtml

Water quality

Wind seiche

There were a number of submissions in regard to wind seiche impacting on water quality at the pump intakes Concerns included

Some suggested that the remaining area of the Lake above the temporary weir (weir pool) would still be large enough to allow significant wind seiching to occur Due to low inflows and a large weir pool surface area salinity would increase in the weir pool and these seiching events would still have the capacity to drive the saline water within the weir pool upstream to the pump intakes

It was suggested that the temporary weir will effectively impede if not completely stop the wind seiche effect across Lake Alexandrina and into the River thus stopping the mixing of the water in the River and substantially increasing the risk of algal blooms

It was suggested that the impact of wind seiche in the weir pool is not fully understood and

Concern was expressed about cutting off seiche events into the lower Murray providing nutrients and oxygenated water from Lake Alexandrina Seiching events also allow transport of pollutants to the Murray Mouth and may build up in the weir pool when there are inadequate seiche effects

Response

Wind seiche is believed to be an important part of the ecosystem within the lower reaches of the River Murray It is a transport mechanism for both up and downstream transporting oxygenated nutrient rich water from Lake Alexandrina into the lower reaches of the River and allowing flushing from the channel of excess nutrients and salt Additionally it provides variability in water levels important for the life cycles and habitat of some native species

If the River system and Lower Lakes were experiencing normal flows and water levels then the temporary weir would reduce the effects of seiche events At the proposed trigger level to install the temporary weir (-15 m AHD) the connection of Lake Alexandrina to the River channel will be minimal reducing the effects of wind seiche As indicated in section 443 of the draft EIS this is partly due to the natural bathymetry of the river channel where it connects to Lake Alexandrina

Modellers have incorporated the effects of winds seiche including those modelling scenarios with a temporary weir in place There are also real world examples The draft EIS made a comparison between seiche effects above and below Lock 1 and noted that the effects were less pronounced above the lock Additionally BMT-WBM modelling indicates that by December 2010 under ongoing low flow conditions both scenarios with and without a temporary weir show a marked drop in the effects of wind seiche and there is little difference between the two scenarios

The draft EIS also stated that the effects of wind seiching are expected to be reduced by approximately 50 with the temporary weir This is because the temporary weir will decrease

Supplementary EIS for the temporary weir near Pomanda Island -16shy

the effects of wind seiche within the River channel by disconnecting it from Lake Alexandrina which supplies a large amount of momentum for water seiching up the lower River Murray

Any water from Lake Alexandrina that did manage to travel up channel will also be highly saline acidic and have high concentrations of metals Currently water does not flow over the barrages and out the Murray Mouth and would not at the trigger level of -15m AHD The shoreline of much of Lake Alexandrina would in fact be kilometres north of the barrages by this stage

With a temporary weir in place flows over Lock 1 will continue supplying a constant source of freshwater in the weir pool helping to keep salinity low within that pool Additionally the temporary weir will prevent the transport of saline acidic water from Lake Alexandrina into the River channel These effects along with the reduction in wind seiche will ensure salinity and contaminants at the pump intakes are minimised However the reduction is unlikely to remove all wind seiche effects creating enough movement to reduce the risk of algal blooms and oxygenate the water

Conclusion

The effects of the temporary weir need to be considered in the context of what the situation will be when it is proposed that the temporary weir will be installed that is at a water level of -15 m AHD in Lake Alexandrina While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes Some effects such as blue-green algae formation and potential reduction in oxygen levels upstream of the weir pool (due to reduced flow velocities over the temporary weir itself) whilst undesirable can be managed by the treatment plant whereas other poor water quality (such as metal releases due to acid sulphate soil effects potentially created in the Lakes) would be more difficult to treat Oxygen levels may fall within the weir pool due to the reduction in seiche events and a lack of oxygenated water from Lake Alexandrina however some seiching and wind action will still occur within the wide weir pool reducing the likelihood of anoxic conditions from occurring

Impacts upon Coorong and Lake Albert

A number of submissions raised questions about the impacts on the Coorong and Lake Albert from the temporary weir

Response

These submissions are noted however the proponent contends that the Draft EIS contains sufficient evidence that conditions in Lake Albert and the Coorong will be unaffected by construction of the temporary weir The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170 mm only occurs during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD (including Lake Albert and the Coorong) is not a direct impact of the temporary weir It is therefore beyond the scope of the draft EIS

The draft EIS considered that impacts of the temporary weir on the Coorong and Lake Albert were not considered significant This is because at the time of the weir closure the surface water elevation of Lake Alexandrina will be below sea level preventing any movement of water to Lake Albert and through the barrages to the Coorong The introduction of a temporary weir will not change this situation

Since May 2008 water levels in Lake Albert have been maintained artificially at an approximate height of - 05 m AHD by pumping from Lake Alexandrina Continued low River Murray flows have made this practice unsustainable and funding for pumping ceased on 30 June 2009 as noted by the MDB Ministerial Council on 12 June 2009 The cessation of pumping in June 2009 will lead to a gradual lowering of the level of Lake Albert The introduction of a temporary weir will not change this situation

Supplementary EIS for the temporary weir near Pomanda Island -17shy

Conclusion

At the trigger level for the construction of the temporary weir the Coorong and Lake Albert waters will be disconnected from Lake Alexandrina so changes to soil and water quality are not significantly impacted on by the temporary weir

Dredging of Murray Mouth

The issue of whether the dredge at the mouth of the Murray will remain there if the temporary weir is put in was raised

Response

The Murray Mouth is the only site where water contaminants such as silt salt and nutrients can exit the Murray-Darling Basin There has been no significant release of water from the Lower Lakes via the barrages since November 2005 and connection at the Murray Mouth has been dependent on dredging

The dredging program should only be regarded as a temporary measure Increased environmenta l flows a re the Murray s only solution in the long term if we are to keep the mouth open and maintain the health of the Coorong

Water quality impacts near Narrung Narrows

Submissions suggested that conclusions on water quality impacts from the construction of a blocking bank at the Narrung Narrows need revising in the light of additional monitoring data

Response

The construction of the blocking bank took 16 days to closure after commencing on 16 April 2008 Water quality parameters were monitored before during and after construction but revealed little impact with fluctuating turbidity levels likely due to the effects of wind as shown historically in figure 11-5 of the draft EIS There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid once water levels rose Alkalinity concentrations showed little change during and after the construction

Turbidity

The EPA has undertaken monitoring at locations around Lakes Alexandrina and Albert since the commencement of the construction of the Narrung Narrows blocking bank EPA water quality monitoring reports p repared for the b loc king bank p rojec t s steering c ommittee noted tha t some localised turbidity impacts were observed but this did not translate into widespread impacts in Lake Albert Figure 11-7 (below) shows turbidity readings for five locations and demonstrates that there is little correlation between the installation of the blocking bank the subsequent pumping and turbidity in both Lakes The variability in turbidity is principally related to climatic conditions at the Lakes For example the Lakes are shallow and the area experiences wind events which regularly create turbulence which is able to mobilise sediments thus increasing turbidity The spike at Meningie in December 2008 is not likely to be related to the blocking bank as it is nearly six months after construction

Supplementary EIS for the temporary weir near Pomanda Island -18shy

Turbidity at Monitoring Stations near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - Near narrows 3km NE of Reedy point

Lake Albert - Near water level gauge 11km N of Meningie Lake Alexandrina Poltalloch

Lake Alexandrina - Beacon 90

Figure 11-7 Turbidity (NTU) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Acidity

Water column pH has remained relatively constant with readings predominantly between 86 and 89 (Figure 11-8 of the Draft EIS) There was a pH drop in Lake Albert at the time of completion of the blocking bank with the closest monitoring point recording a pH of 79 These lows were recovered to normal levels within the month after pumping commenced

These results show there may be some localised effects to pH through the exposure of sulfidic sediment However the buffering capacity of the water and the quantity of exposed sulfidic sediment reduce the risk to the effects of pH to the Lake as a whole

pH at Monitoring Stations near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-8 pH at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Supplementary EIS for the temporary weir near Pomanda Island -19shy

Alkalinity

All stations with the exception of the Lake Albert station closest to the blocking bank have had relatively constant alkalinity concentrations The largest decrease in pH did not correlate with a reduction in alkalinity however later reductions in pH in August and November 2008 and January 2009 did Due to the continued exposure of sulfidic sediments over this time it is unlikely the effects are due to the blocking bank construction

Alkalinity at Monitoring Stations Near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-9 Alkalinity (mgL) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Conclusion

Water quality parameters were monitored before during and after the construction of the Narrung Narrows blocking bank and monitoring revealed little impact with fluctuating turbidity levels likely due to the effects of wind There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid Alkalinity concentrations showed little change during and after the construction

Algal blooms

There were many concerns about possible increases in algal blooms within the weir pool through reduction in flows and nutrient fluxes impacting on water quality

Response

The risk of algal blooms in the River is influenced by a number of interacting factors including weather conditions flow and turbulence and nutrient supply It is therefore not possible to precisely predict the extent and intensity of blooms However it is generally accepted that blue-green algae are favoured by waters with reduced turbulence reduced turbidity and increased nutrients A change to turbulence only increases the risk if sufficient nutrients are present to support the bloom The reduced flow in the River as a result of the drought will increase the likelihood of algal blooms The temporary weir will also reduce the flow and turbulence during the weir pool filling period and may therefore also tend to increase the risk of algal blooms Precise prediction of the frequency and intensity of algal blooms is not possible but it could be expected to be similar to the permanent structures upstream

Supplementary EIS for the temporary weir near Pomanda Island -20shy

There is a range of information mainly from studies overseas that lakes and rivers that experience frequent andor prolonged algal blooms display an array of ecosystem properties that may have impacts on water quality biological communities and ecosystem services

Some impacts of algal blooms may be direct including possible effects of toxins on fish invertebrates and other aquatic fauna or indirect including a reduction of submerged plants when plankton biomass becomes very high and changes in fish community structure due to hypolimnetic anoxia In lakes with dense blooms of blue-green algae accumulation of organic material in lake sediments and increased bacterial activity also may lead to anoxic conditions that alter the structure of benthic macro invertebrates Despite numerous case studies and a vast literature on species specific responses community level effects of blue-green algal blooms are not well understood

It must be noted however that these potential changes are associated with highly eutrophic environments that have frequent and persistent and often massive algal blooms These conditions are relatively extreme and unlikely to be encountered for extended periods in the River provided projected flows are maintained

The lower River Murray and other surface water storages within the Murray-Darling Basin regularly experience minor algal blooms due to seasonal stratification and periods of low flow These blooms have not been associated with the types of potential environmental effects that occur in the degraded systems with persistent blooms A case in point is the recent short-lived but highly visible bloom in the River Murray in NSWVictoria downstream of Hume Dam

It is not possible to make a precise prediction of the impact of the temporary weir on the risk of blue-green algal blooms However it is expected that the impacts will not be significant and will be similar to those in the permanent structures up stream

The water treatment plants in South Australia all have the capacity to remove algal cells and the toxins taste and odours that they produce and are able to mitigate any detrimental effects of algal blooms on water supplies

Summary of water quality impacts

One submission highlighted that the summary of water quality impacts in Chapter 11 of the draft EIS did not include all of the impacts to water quality particularly salinity

Response

The construction of the blocking bank at the Narrung Narrows was examined to determine what impacts on water quality if any were identified during and after construction of the blocking bank Using the blocking bank as an example it is expected that the construction of a temporary weir near Pomanda Island may have impacts on water quality both up and down stream

Water quality issues which may result within the weir pool include a reduction in flow velocity an increase in temperature and evaporation and a decrease in dissolved oxygen levels and in the effectiveness of wind seiche events to provide mixing and transport of salt nutrient and contaminants This may lead to temperature and salinity stratification and an increase in blue-green algal blooms in the weir pool It is expected that these impacts will be similar to those relating to the permanent structures that already exist in the River Murray up stream from Lock 1 and that the potential environmental risks will therefore not be significant

The construction of the temporary weir itself will create localised sediment waves as material placed in the River channel displaces sediment This sediment wave is likely to contain sulfidic materials that will oxidise and form acid Based on the experience of the Narrung Narrows blocking bank the provision of mitigation and management measures as outlined in the CEMP is adequate It can be expected that there will be localised impacts to turbidity pH and alkalinity but minimal effect at a distance

Once the weir construction is complete there will be a reduction in inflows to Lake Alexandrina while the weir pool is filled (see page 13 -14) Modelling indicates that during this time there will be a temporary increase in salinity in the waters of Lake Alexandrina However it has indicated that in the long-term the d ifferenc es in sa linity between the weir and no weir op tion under continued low inflows become insignificant

Supplementary EIS for the temporary weir near Pomanda Island -21shy

The reduction of flow during the filling of the weir pool (see page 13-14) predicts the volume of water in the Lake such that a further 5200 ha of sulfidic soils are exposed in Lake Alexandrina under the worst case scenario This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage ASS will need to be implemented across the Lake in this case

When these impacts are compared to the conditions likely to be present when water levels reach triggers for the temporary weir to be installed at viz 15 m AHD it is likely that the impacts of the temporary weir on water quality in Lake Alexandrina will be an increase in salinity for up to 3 months and bringing forward a potentially rapid pH reduction in Lake Alexandrina by 2 to 3 months For a detailed discussion of likelihood of Lake Alexandrina acidifying during the no flow period refer to Appendix 1 Question 7

For a detailed discussion of reasons underlying the 25 to 3 month disconnect of Lake Alexandrina refer to Appendix 1 Question 9

Connectivity of Surface and Ground Waters

Surface Waters

A few submissions questioned what the tributaries of Lake Alexandrina were and when they would disconnect

One submission was received stating that the drop in water level predicted to occur as a result of building the temporary weir should not have been expressed as an average but as a range

Response

There are four tributaries from the Eastern Mount Lofty Ranges (EMLR) to Lake Alexandrina namely

Angas River

Bremer River

Currency Creek

Finniss River

The surface waters of these tributaries will be disconnected at -15m AHD from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into the Lake and were the first to disconnect at a water level between +01 m and + 03 m AHD The Angas and Bremer have been disconnected since 2007

At times of medium to high outflow from these tributaries there is likely to be some reconnection of surface water with or without the temporary weir

The South Australian Government commenced construction of a temporary environmental flow regulator at Clayton in June 2009 The Goolwa Channel (and Currency Creek and the Finniss River tributaries) will be disconnected from Lake Alexandrina during construction of this regulator (EPBC Reference No 20094833)

The figures in Chapter 10 of the draft EIS show a selection of graphs of predicted water level impacts of the temporary weir From these the greatest reduction in water level during the weir pool filling phase in the first year is shown to be approximately 210 mm near the tributaries (points 63 and 64 Figures 10-13 and 10-14)

Conclusion

All tributaries except the Goolwa Channel are now disconnected from Lake Alexandrina and will remain so with or without a temporary weir

The construction of an environmental low flow regulator at Clayton will disconnect Currency Creek and Finniss River from Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -22shy

Reconnection of surface water in Angas and Bremer Rivers with Lake Alexandrina is likely at times of medium to high outflow from these tributaries This situation is unlikely to change with the construction of the temporary weir

Groundwater

A few submissions questioned the detail on surface waters and groundwater interactions

Response

In terms of groundwater connection it is assumed that the sediments in the tributaries and Lake Alexandrina will have some hydration from groundwater even at water levels of less than -28 m AHD

During development of the EIS DWLBC hydrogeologists were consulted on whether the p red ic ted dec rease in Lake Alexandrina s water level of 210 mm near the tributa ries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the drought induced water level drop which has already occurred

Conclusion

Tributaries are likely to remain connected to Lake Alexandrina through groundwater at levels less than -28 m AHD and the 210 mm difference in water level induced by the construction of a temporary weir is unlikely to have a significant impact on groundwater flux

Supplementary EIS for the temporary weir near Pomanda Island -23shy

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels

Introduction

Submissions discussed in this Section relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir as outlined below The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

Another issue of concern raised by many submissions and respondents is the potential impact of increased salinity within the Lower Lakes upon aquatic biota The following discussion adds considerable detail relating to predicted salinity changes and the likely biotic response endeavouring to provide greater breadth and clarity around this issue

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Upstream impacts

Impacts of altered water regime in weir pool

Several submissions argued that conditions in the weir pool created upstream of the temporary weir would favour exotic species such as Common Carp and disadvantage native species including EPBC Act-listed species such as Murray Cod Such an impact would be contrary to the goa ls of the MDBA s Native Fish Stra tegy

There was also a concern that flora species such as the common reed cumbungi and willows (an introduced species) in the riparianlittoral zones might respond in a way that could impact on matters of NES

Response

aspec ts of the p roposed temporary weir tha t interac t with ray-finned fishes of NES (page 15-13) should be expanded to include The list of

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

The list of potential impacts of the temporary weir upon aquatic fauna (Section 15415 pages 15-24) should be expanded to include

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

Advice from the South Australian Research and Development Institute (SARDI) Aquatic Sciences is that mitigation of improved spawning conditions for Common Carp in the Pomanda Island weir pool is not practical due to the scale of the issue Similarly measures to promote spawning of Murray Cod in the weir pool are not practical The potential impacts of the temporary weir upon EPBC Act-listed fishes in the River Murray channel upstream of the

Supplementary EIS for the temporary weir near Pomanda Island -24shy

temporary weir due to altered hydrology and increased exotic fish abundance appear to be unavoidable

The following aspec ts of the temporary weir tha t interac t with ripa rian flora such as Phragmites (common reed) Typha (cumbungi) and willow (introduced species) in the upstream wetlands and consequent effects on matters of NES (fauna) should be taken into consideration

The vegetation type and distribution in the upstream wetlands is expected to change due to the change in water level from (historic) +05m AHD - +08m AHD to a new level of +01m AHD and reduced wind seiche noting that current water levels are substantially lower than this

The change to a shallower wetland regime is expected to favour Phragmites and Typha which are invasive

The impact of changed vegetation pattern on matters of NES (EPBC-listed fish and birds) is expected to be negligible considering their preferred habitat

The impact of changed vegetation pattern on the EPBC-listed Southern Bell Frog is expected to be either to maintain or improve the preferred habitat for breeding

Impacts to Pelican Lagoon and Nalpa Station

Several submissions raised concerns regarding Pelican Lagoon and wetland habitats on Nalpa Station Pelican Lagoon is a large fringing wetland located directly upstream from the temporary weir site Previous surveys at the wetland and the Nalpa property have determined the area to be a biodiversity hot-spot hosting significant species such as the southern bell frog southern pygmy perch white-bellied sea eagle golden-headed c istic ola Lewin s ra il Australasian shoveler and various aquatic plant species As the wetland has been dry since early 2007 there is an inherent assumption that these species are lost therefore the impact of the temporary weir can be negated However further impacts upon these species are possible

Response

It would be desirable to resurvey the area particularly the small inundated area from which stock and domestic water are accessed to determine which species of significance remain and what measures can be taken to protect them

The local landholders have also shown an interest in undertaking management actions for the betterment of the wetland environment Support could be provided in the form of a wetland management plan for the site to determine the most effective way to manage the wetland

Weir Footprint Impacts

Impacts of Habitat LossDegradation

Several submissions argued that potential impacts to flora and fauna due to the clearance or disturbance of vegetation at the weir construction site were understated or unclear These flora and fauna included EPBC Act-listed species Among the fauna of concern were the Southern Bell Frog Orange-bellied Parrot La tham s Snipe (Gallinago hardwickii) White Bellied Sea Eagle and Great Egret Flora of concern included Phragmites australis Typha domingensis Senecio longicollaris Shrubby Groundsel (Senecio cunninghamii var cunninghamii) purple Loosestrife (Lythrum salicaria) and a range of samphire species

Response

A native fauna and flora survey of the approach works footprint and the subaqueous weir footprint was conducted by ecological consultants in SeptemberOctober 2008 (Ecological Associates 2008) Habitat impacts in the immediate weir footprint area were identified to be minimal

It is highly likely that the temporary weir will cause the loss of some of the reed beds at or near the construction site through physical disturbance

Supplementary EIS for the temporary weir near Pomanda Island -25shy

Impacts of mud disturbance upon salinity

One submission claimed that mud disturbance around the temporary weir site during construction would turn the water saline and impact on all fish species

Response

There is no available data which suggest that disturbance of submerged sediments can lead to an increase in the salinity of surface water

Impacts upon fish migration

A significant number of submissions argued that the temporary weir may impede upstream and downstream movement of juvenile and adult fish including EPBC Act - listed species and that this is an unacceptable impact upon upstream and downstream ecosystems and commercial fishing activities

Response

Due to concerns raised in submissions about the lack of a fishway (fish passage) a process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species

SARDI has indicated that it has sufficient knowledge to be able to design a fishway without the need for further site survey work SA Water Corporation is working with SARDI to design a suitable fishway into the temporary weir

SA Water Corporation is progressing a concept design for a fishway in the temporary weir with URS Australia

The concept design for the fishway is expected to be completed in July 2009 and a draft Concept Design Report should be available before the end July 2009 The report will include sketches of the concept and will also show the impact on the temporary weir design

The concept (although still to be finalised and confirmed) is for a rock ramp fishway in the centre of the temporary weir at the western end of the spillway This position places the fishway as close as possible to the deep channel to the west near Pomanda Island The rock ramp would be around 50 metres wide and slope downstream on a 130 gradient The deep centre section would be a metre deep (at full pool level) and the sides of the ramp would slope upwards to provide shallower and slower paths for smaller fish Stop logs at the top of the ramp will allow dewatering of the fish passage

Although the impacts on the temporary weir design will not be certain until the concept design is finalised the indicative impacts of such a concept include the following

The fishway hydraulic design will maintain an upper weir pool water level of 00m AHD with a flow of 600 MLday

A small auxiliary spillway is needed adjacent to the fishway to provide an attraction flow and this will pass 360 MLday the remainder of the average daily flow of 960 MLday (350 GLyear)

At a flow of 960 MLday the upper weir pool will be +01 m AHD with the fishway open (ie identical to the no fish passage design)

At a flow of 1200 MLday the upper weir pool will be +017 m AHD with the fishway open

For automatic operation the bottom of the auxiliary spillway will be inclined from +01 m AHD to +02 m AHD between the fishway and the main spillway

The main spillway crest will be raised to +02 m AHD to ensure that average daily flows remain confined to the fishway and auxiliary spillway Initially a spillway level of +01 m AHD had been established as the upper pool level to be retained by the weir

Supplementary EIS for the temporary weir near Pomanda Island -26shy

However the desire to have a ll flow pass through the fishway during norma l river flow that is 960 Mlday with the upper pool level maintained at +01 m AHD necessitates a reconfiguration of the main spillway of the temporary weir

The main spillway will be slightly shorter (around 1150m wide instead of 1200m wide) so that the fishway can be constructed on the western edge of the better foundation material

To ensure that water entering the downstream pool from either the fishway auxiliary spillway or main spillway remains continuous and provides an attraction path to the fishway the centreline of the auxiliary spillway and main spillway will be moved slightly downstream between the fishway and the eastern abutment

The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Impacts of noise upon wetland birds

One respondent sought clarification on the level of noise the weir construction is anticipated to create given that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB as stated in the Draft EIS

Response

There are no wetlands on the eastern side near the abutment It is anticipated that any areas around Low Point populated by birds will receive noise levels similar to that from a busy highway The same will apply to the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels which would presumably cause them to move further north into the wetland area

Monitoring during constructiondecommissioning

A number of submissions questioned how the Monitoring of EPBC-listed spec ies referred to on page 15-24 of the Draft EIS will ensure that construction operation and decommissioning activities do not impact on EPBC-listed species More information was sought on the fauna inspection to be carried out in the construction area before any vegetation clearance (Table 15-9 on pp 15-2526 of the Draft EIS)

Response

Monitoring during operation of the temporary weir will be coordinated as part of the SA MDB NRMB s na tura l resource condition monitoring program It will include additional monitoring efforts as per expert advice

of the EPBC-listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life and breeding cycles The monitoring focus will be of an observational nature in regards to compliance monitoring This is to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by the Commonwealth and the South Australian Native Vegetation Council) and that the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora and fauna expert advice if warranted In addition the Contrac tor s EMP will identify based on a risk assessment whic h spec ific mitiga tion and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations needs to be recorded

It is rec ognised tha t the monitoring

A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water Corporation and DEH (Ecological Associates 2008) This knowledge has been considered by the Commonwealth More specific instructions on how this can be used will be included in the CEMP The project will ensure that expert advice is available throughout the duration of the construction phase

Supplementary EIS for the temporary weir near Pomanda Island -27shy

Timing of construction and presence of migratory species

One respondent commented that the Draft EIS did not appear to consider the interaction between the timing of construction and the presence of migratory species eg Orange-bellied Parrot potentially present from March to early November

Response

The Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to help protect Orange-bellied Parrots might however impact on other species Migratory shorebirds for example return in late August and spend the entire summer at the site

Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coorong_S urvey_lowpdf

Downstream impacts

Impacts of water level changes upon aquatic vegetation

A respondent noted that in Section 1246 on page 12-11 of the Draft EIS under the heading Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion are

considered insignificant as many of these species reproduce sexually and through wind or bird-d riven seed d ispersa l This is only a c onsidera tion of impac ts upon rep roduc tion not a consideration of whether the plants will even survive to reproduce

Response

Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately +035 m AHD At a water level of -15 m AHD (when the temporary weir would close) this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the water body and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long-term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the Lake be refilled with freshwater to its pre-drought level (+05 to +08 m AHD) while the below-ground storage organs remain viable

Impacts of temporary increase in salinity upon aquatic biota

A significant number of submissions raised concerns regarding the impact of the temporary weir upon salinity in the Lower Lakes and consequent impacts upon biota There were also concerns that not all Matters of NES potentially impacted by the temporary salinity increase caused by the temporary weir had been adequately addressed One submission predicted the salinity increase would cause a mass die-off of Common Carp which would lead to poor water quality in Lake Alexandrina

Response

The scope of the EIS dictates that it consider the impacts of the temporary weir upon biota that are listed as threatened under the EPBC Act or that contribute to the ecological character of the Coorong Lakes Alexandrina and Albert Ramsar site These include all of the freshwater diadromous and estuarine fish species of the freshwater units (Lower Lakes) as well as a large number of bird taxa many of which are piscivorous (Phillips and Muller 2006) Taxa other than fish and birds need only be considered by the EIS if impacts upon them are likely to be transferred into a significant impact upon fish or bird communities

Supplementary EIS for the temporary weir near Pomanda Island -28shy

The impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake (Fig 10-5 in the Draft EIS) The salinity of Lake Alexandrina is predicted to be higher than both the limits of acceptable change (700 EC (Phillips and Muller 2006)) and the typical seasonal maximum (1500 EC) from January 2010 onwards at all loc a tions under both the weir and no weir sc enarios Modelling shows tha t the d ifferenc e in salinity in Lake Alexandrina (modelling assuming continued pumping to Lake Albert however on 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009) under the weir and no weir sc enarios va ries with location At all sites modelled salinity is similar in early 2011 one year after weir construction under both the weir and no weir sc enarios (Sec tion 10) However immediately following weir construction a temporary increase in salinity three to five months in duration is predicted at most sites The magnitude of the salinity increase varies between sites but is pronounced at several sites

A salinity threshold that is important in terms of the maintenance of ecological character is the salinity tolerance of the resident native freshwater fish species of the Lower Lakes Salinity tolerance varies between species but for the temporary weir to have no significant impact upon native fish species its construction should not cause salinity to exceed the tolerance of the most salinity-sensitive species

Several species of rare or threatened small-bodied native freshwater fish that are resident in the Lower Lakes under pre-drought water levels (+04 to +08 m AHD) are unlikely to be present in Lake Alexandrina at a water level of 15 m AHD Yarra Pygmy Perch have probably become locally extinct in the CLLMM as a consequence of the current low water levels (Bice and Ye 2009) Mountain Galaxias Murray Rainbowfish and Southern Purple-spotted Gudgeon are all very rare possibly extinct from the CLLMM with no records for a number of years (Bice and Ye 2009) All of these small-bodied species are associated with fringing aquatic vegetation They are unlikely to be present in Lake Alexandrina when water levels have declined to the extent that all fringing aquatic vegetation has become disconnected from the water body

Prior to the drought the only part of the Coorong Lower Lakes and Murray Mouth where River Blackfish had been recorded were the upper reaches of the Eastern Mt Lofty Ranges tributaries that enter Lake Alexandrina (Bice and Ye 2009) The species prefers permanently flowing freshwater streams with cool clear water where it is strongly associated with the in-stream cover habitats provided by undercut banks and boulders (Khan et al 2004) It is unlikely to be present in the open water habitat of Lake Alexandrina that is disconnected from fringing aquatic vegetation and other forms of cover

A number of short-lived (lifespan generally 3 years or less) small-bodied native freshwater fish species could potentially be present in Lake Alexandrina when the water level reaches

15 m AHD These species are dependent upon fringing or benthic aquatic vegetation during part of their lifecycle particularly egg and larval stages (Lintermans 2007) with the exception of Australian Smelt which is a more pelagic species Therefore conditions in Lake Alexandrina are likely to be unfavourable for their persistence due to the disconnection of fringing vegetation and the water body Although unlikely it is possible that these species may persist providing important remnant populations that could potentially increase in abundance and repopulate the Lake when water levels return to pre-drought levels Due to their brief lifespans the salinity tolerances of all stages of the life cycle are relevant to the potential impacts of the temporary weir upon them Egg and larval stages typically have the lowest salinity tolerance (Bice and Ye 2009) Because breeding occurs in spring and summer for most of these species (Lintermans 2007) the summer-autumn timing of the short-term increase in salinity levels caused by weir construction could have implications for breeding success and thus persistence of these short-lived species in the Lower Lakes The species and salinity tolerances of their most salinity-sensitive lifestage are Southern Pygmy Perch (15500 EC (adult tolerance - egg and larval tolerance not known)) Murray Hardyhead (80000 EC (low confidence)) Carp Gudgeon complex (9800 EC) Flat-headed Gudgeon (19200 EC) Dwarf Flat-headed Gudgeon (10800 EC) Australian Smelt (92200 EC (adult tolerance - egg and larval tolerance not known)) and Unspecked Hardyhead (68300 EC (adult tolerance - egg and larval tolerance not known)) (Bice and Ye 2009)

The large-bodied native freshwater fish of Lake Alexandrina all have a lifespan of at least several years Thus a short-term (three to five month) increase in salinity that exceeds the tolerance of eggs or larvae does not represent a significant impact to the species if adults are unaffected and can subsequently successfully reproduce when salinities return to tolerable

Supplementary EIS for the temporary weir near Pomanda Island -29shy

levels for sub-adult life stages Large-bodied native freshwater fish species potentially present in the Lake Alexandrina at a water level of 15 m AHD and their respective adult salinity tolerances are Murray Cod (24 500 EC) Silver Perch (25 000 EC) Eel-tailed Catfish (28 000 EC) Golden Perch (Callop) (51 500 EC) and Bony Herring (54 500 EC) (Bice and Ye 2009)

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9) Thus construction of the temporary weir causes salinity to shift from tolerable to intolerable for the eggs or larvae of Carp Gudgeon complex Dwarf Flat-headed Gudgeon and possibly Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead Although the period of intolerable salinity is temporary it will lead to declines in their abundance in the Lower Lakes There are no modelled sites at which salinities will shift from tolerable to intolerable for large-bodied species

Carp Gudgeon complex Dwarf Flat-headed Gudgeon Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead

Declines or complete loss of small-bodied native freshwater fish

from Lake Alexandrina if this occurs is anticipated to be temporary All of these species occur in the River Murray channel and their downstream migration past the temporary weir (which is to feature a fishway) into the Lower Lakes is anticipated to recommence following the period of reduced flow (see page 13) during weir construction Therefore any declines in abundance due to the short-term increase in salinity levels associated with weir construction are likely to be temporary

Adult Common Carp have a salinity tolerance of ~23 500 EC (Bice and Ye 2009) Modelling indicates that the temporary increase in salinity levels caused by weir construction will not cause salinity to increase from tolerable to intolerable for adult Common Carp at any site Most of Lake Alexandrina will remain below the salinity threshold for this species Therefore the temporary increase in salinity caused by the temporary weir is not anticipated to cause a mass die-off of Common Carp or associated water pollution

Recently collected data puts the above discussion into context Fish surveys conducted during weeks 13 17 April 2009 in the Goolwa channel (between Clayton and Goolwa barrages) indicated the obligate freshwater fish community of this area of the Lower Lakes was composed primarily of three species Australian Smelt Flat-headed Gudgeon and Bony Herring (SARDI unpublished data) Salinities at Clayton during the same period ranged from ~18000 to ~24000 EC (DWLBC 2009) These three species are clearly able to persist in the Lower Lakes despite loss of connectivity with fringing aquatic vegetation and elevated salinity Their persistence indicates that both their habitat and feeding requirements are met When the water level in the main body of Lake Alexandrina falls to 15 m AHD triggering weir construction it is likely that the obligate freshwater fish community will be comprised primarily of these three species The temporary increase in salinity levels anticipated will not lead to salinities in excess of those that these species are currently experiencing in the Goolwa channel

The above discussion illustrates that the temporary increase in salinity levels caused by the construction of a temporary weir near Pomanda Island is unlikely to have a significant impact upon the resident native freshwater fish species of the Lower Lakes The temporary increase in salinity levels will cause salinity in Lake Alexandrina to shift from tolerable to intolerable for a small number of short-lived small-bodied native freshwater fish species However at the time of weir construction these species are likely to be in decline or absent due to other factors primarily the loss of fringing aquatic vegetation habitat unrelated to weir construction Additionally the unfavourable salinities caused by weir construction are predicted to be temporary and repopulation of the Lower Lakes via downstream migration from the River Murray channel is anticipated to occur following weir construction Ongoing fish monitoring of the lower lakes will provide further information regarding impacts to native freshwater fish

The above discussion has focussed primarily upon obligate freshwater fish of the Lower Lakes However a number of diadromous and estuarine species are also common in the Lower Lakes (Phillips and Muller 2006) The salinity tolerances of these species are much higher than those for obligate freshwater fish species (Bice and Ye 2009) and the temporary increase in salinity levels due to weir construction is not anticipated to have a significant impact upon diadromous or estuarine species

Supplementary EIS for the temporary weir near Pomanda Island -30shy

It is likely that the impacts of the temporary weir upon fish in the Lower Lakes will be transferred to piscivorous birds Given that the temporary weir is unlikely to have a significant impact upon obligate freshwater diadromous or estuarine native fish species a significant impact upon piscivorous birds due to declines in native fish abundance is also unlikely Therefore piscivorous birds are not anticipated to be significantly impacted by weir construction

The impact of the temporary increase in salinity levels upon the invasive polychaete tubeworm Ficopomatus enigmaticus should be examined in the light of the research being undertaken by Dr Sabine Dittmann for the SA MDB NRMB The tubeworm itself has not been identified as a Matter of NES however changes to its abundance may impact upon Matters of NES

The Long-necked Tortoise is not listed as threatened under the EPBC Act nor is it considered a Ramsar-significant species or a primary determinant of ecological character for the CLLMM (Phillips and Muller 2006) The Long-necked Tortoise population of the CLLMM is therefore not a matter of national environmental significance and the impact of the temporary weir upon it is outside the scope of the EIS

Impacts upon tributary wetlands

A number of submissions were received regarding the impacts upon the ecosystems of the tributary wetlands of disconnection of surface waters and groundwater interactions caused by construction of the temporary weir

Response

The Swamps of the Fleurieu Peninsulas geographic distribution include swamps fringing Currency Creek Finniss River Goolwa Channel and Lake Alexandrina near Milang These swamps have already disconnected from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into Lake Alexandrina and were the first to disconnect at a water level of approximately +03 m AHD

The Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton (EPBC Reference No 20094833) The South Australian Government commenced construction of the regulator in June 2009 This regulator is expected to be completed in August 2009 and will result in the Goolwa Channel Currency Creek and Finniss River being disconnected from Lake Alexandrina

The Hindmarsh Island channels disconnected at approximately +01 m AHD These well-vegetated water bodies were significant habitat for the EPBC-listed Yarra Pygmy Perch and thus a captured breeding and recovery program has been implemented to ensure that the populations survive the current drawdown and can be released once water levels and habitat conditions improve

In terms of groundwater connection it is assumed that the tributaries and Lake Alexandrina will remain connected through groundwater at water levels less than -28 m AHD and thus could potentially be impacted upon by construction of the temporary weir During development of the EIS DWLBC staff were consulted on whether the predicted decrease in the Lake Alexandrina level of 210 mm near the tributaries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the water level drop caused by drought and over-allocation already experienced

Impacts upon the Milang Snipe sanctuary

One submission argued that the Draft EIS had not adequately addressed impacts upon the Milang Snipe Sanctuary

Response

The Milang Snipe sanc tuary is a very signific ant refuge for Japanese (La tham s) Snipe a recognised migratory species under the EPBC legislation and a listed species under the China Australia Migratory Bird Agreement (CAMBA) Japan Australia Migratory Bird Agreement (JAMBA) and the Republic of Korea Australia Migratory Bird Agreement (ROKAMBA) In

Supplementary EIS for the temporary weir near Pomanda Island -31shy

addition the presence of mature aquatic vegetation and the mosaic of ponds have provided excellent habitat for a suite of other waterbird species

The Japanese Snipe requires freshwater wetlands and vegetated meadows and preferably seasonal or semi permanent freshwater swamps Under a different hydrological regime the inundation frequency of the wetlands will change and the habitat will no longer remain optimal This site is a very good example of a wetland that may become compromised by altered hydrology

The Milang Snipe sanctuary is inundated when water levels in the Lower Lakes are high The site is currently dry The temporary weir is not anticipated to impact upon the water regime at the Milang Snipe sanctuary and therefore no significant impact upon the ecosystem of this site is predicted as a consequence of weir construction and operation

Impacts upon primary determinants of ecological character

One respondent noted that the summary of ecological impacts upon the primary determinants of ecological character (pg 12-20 section 126) appears to relate more to current drought-related ecological impacts and not specifically to the additional (likely to be small in comparison) ecological impacts of temporarily reducing flow to Lake Alexandrina

Response

This is agreed Additional comment is as follows Section 12-6 of the Draft EIS summarises the predicted impacts of the temporary weir upon the primary determinants of ecological character of the CLLMM Ramsar site It covers impacts to two primary determinants keystone aquatic plant species and habitat availability However it does not address the other four primary determinants outlined in the ECD It also fails to clarify the difference between drought impacts and weir impacts upon the primary determinants The following changes are proposed

In Section 12-6 pages 12-20 under the dot point Hab ita t ava ilab ility add the following four dot points

Salinity assigned a red light highlighting that conditions in 2006 were leading to loss of species (including keystones) and that salinities in the saline-estuarine units needed to be reduced urgently in order to maintain ecological character

Turbidity and sedimentation patterns assigned an orange light assessment highlighting that knowledge was poor and improved flows were required in 2006

Water levels assigned an orange light assessment highlighting that the regime in 2006 was counter-seasonal to the natural one and too static to support the full complement of the Lakes b iota and

Water regime particularly flow patterns in relation to inflows from the River Murray assigned a red light assessment highlighting that change to the ecological character of the site is largely a consequence of reduced flows from the River Murray

Additionally the first paragraph on page 1221 of the Draft EIS should be replaced by the expanded discussion under the six sub-headings which follow

Impact upon keystone species

Keystone aquatic plant species and assemblages in the Lower Lakes and tributary wetlands have become disconnected from the water body threatening their ongoing persistence Disconnection occurs at water levels below approximately +035 m AHD and is a consequence of the drought and upstream diversions Modelling indicates that disconnection will continue indefinitely under anticipated low flow conditions (see Section 10) with or without the weir in place The temporary weir will not alter the duration of disconnection between the keystone aquatic plant species and the water body The impact of the temporary weir upon this primary determinant of ecological character is therefore considered insignificant

Impact upon habitat availability

Habitat availability (particularly spatial and temporal connectivity) has been dramatically reduced by the drought due to the disconnection between the various parts of the system Key water levels for disconnection include

Supplementary EIS for the temporary weir near Pomanda Island -32shy

+05 m AHD disconnection between the freshwater and saline-estuarine units occurs (permanent barrage closure is required to prevent seawater incursion into the Lower Lakes)

+035 m AHD disconnection between fringing aquatic vegetation of the Lower Lakes and the water body

03 m AHD disconnection between Lake Alexandrina and Lake Albert occurs and

12 m AHD disconnection between the Goolwa channel (and associated tributary wetlands) and Lake Alexandrina occurs

Water levels of lt 15 m AHD will persist for the 2010-2012 period (the nominal lifespan of the temporary weir) should low flows continue (896 GLyr at the SAVic border) whether the temporary weir is built or not (Section 10) Thus the temporary weir will have no impact upon connectivity within the Ramsar site connectivity having already been lost due to the drought However the temporary weir will have an impact upon connectivity between the River Murray channel upstream and the Coorong Lakes Alexandrina and Albert Ramsar site downstream The impact upon this loss of connectivity upon fish and potential mitigation measures is discussed in Section 1353 of the draft EIS

Impact upon salinity

As discussed on page 31 the impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9)

Impact upon turbidity and sedimentation patterns

The turbidity and sedimentation patterns in the Ramsar site are not predicted to be significantly impacted by the temporary weir The impact of current and ongoing low water levels upon this primary determinant of ecological character is anticipated to overwhelm any additional impact caused by the temporary weir The potential for temporary increases in turbidity during the construction phase of the temporary weir will be addressed by mitigation measures discussed in Sections 114 and 115 of the draft EIS

Impact upon water levels

The impact of the temporary weir upon water levels is discussed extensively in Section 10 of the d ra ft EIS Under both weir and no weir sc enarios wa ter levels in the Lower Lakes will be well outside those recommended by Phillips and Muller (2006) ie +01 to +08 m AHD Modelling shows that the temporary weir leads to lower water levels in Lake Alexandrina than would occur if it were not constructed but that the effect is reduced as time post construction increases (Table 10-7) Of particular note is the impact of weir construction upon the timing of exposure of sulfidic sediments in Lake Alexandrina Construction of the temporary weir is anticipated to lead to the critical water level of 15 m AHD which is expected to lead to acidification of the Lake being reached earlier than would occur if it were not constructed However modelling indicates that such water levels will be reached irrespective of a temporary weir being constructed should low flows continue Measures to avoid acidification are discussed in Sections 1126 and 15412 of the draft EIS

Impact upon water regime

The impact of the temporary weir upon water regime particularly flow patterns is considered insignificant

As indicated on page 32 the Angas and Bremer have been disconnected since 2007 and the Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton

Lake Albert was disconnected with the cessation of pumping from Lake Alexandrina on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -33shy

By mid to late 2010 the water level in Lake Alexandrina will be at approximately 15 m AHD Thus the Lake will be disconnected from all other parts of the Ramsar site (ie the Coorong)

Thus any impact of the temporary weir upon water regime affects only Lake Alexandrina and the small area of the Ramsar site located upstream of the weir site The impact upon Lake Alexandrina is a temporarily increased rate of water level decline with various consequences discussed above The impact of increased water level upon the area of the Ramsar site upstream of the temporary weir and upon the River Murray channel upstream of the Ramsar site is considered to be positive provided acidification can be avoided or mitigated

Impacts upon migratory shorebirds

A number of submissions argued that the potential impacts of the temporary weir upon migratory shorebirds had not been adequately addressed Additionally several submissions expressed concern that by limiting the discussion of impacts to regularly recorded migratory shorebirds important impacts could be overlooked It was argued that species recorded infrequently and in low numbers should be a priority for protection as it is likely that they are more susceptible to localised impacts

Response

The temporary weir is unlikely to impact negatively upon the abundance of migratory shorebirds using Lake Alexandrina Under previous management arrangements the Lake was surcharged with water each year and only small areas of exposed mudflat were useable by shorebirds Over the past 18 months the wa ter line has rec eded and the Lake s edges have a t times been used preferentially (compared with the Coorong) for foraging purposes (Wainwright and Christie (in press))

Section 14 of the Draft EIS examines the likely interactions should the temporary weir proceed All migratory shorebirds are listed as matters of NES under the EPBC legislation The separation of seven spec ies into a group desc ribed as regula rly rec orded rela tes to the abundanc e of these species in comparison with any other migratory shorebird and tern species that have been observed a t Lake Alexandrina The regula rly rec orded group a re a t least two orders of magnitude more common Waterbird data collected monthly from 16 sites (2003 to current) around Lake Alexandrina informs this thinking

Impacts upon Australian Painted Snipe

A number of submissions argued that the Draft EIS should have addressed impacts upon the Australian Painted Snipe

Response

The Australian Painted Snipe is nomadic and adopts wetlands opportunistically It requires freshwater and well vegetated wetlands with internal complexity Recent records from Lake Alexandrina are scarce (Letch 2007) presumably because the recent drought has eliminated all suitable habitats However historic records suggest that the fringing habitats around Lake Alexandrina when intermittently favourable have been frequented by the species Recent information suggests that the Australian Painted Snipe may be present close to the site of the temporary weir

Low water levels in the Lower Lakes appear to have led to a significant loss of habitat for the Australian Painted Snipe However given the suggestion that it may be present in the vicinity of the temporary weir construction area it should be considered in the EMP to be prepared for weir construction

Impacts upon Orange-bellied Parrot

One respondent noted that discussion of the Orange-bellied Parrot did not mention the importance of samphire habitat to this species One submission argued that potential impacts upon the Orange-bellied Parrot had not been properly addressed in the Draft EIS

Response

Within South Australia the Orange-bellied Parrot appears to be less dependent than previously suspected on samphire vegetation Recent observations in South Australia suggest that the

Supplementary EIS for the temporary weir near Pomanda Island -34shy

species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

The Orange-bellied Parrot is critically endangered and interactions with proposed weir operations are considered possible The species is known to use a range of habitats including highly disturbed areas Accordingly it is a subject discussed in Chapter 13 of the draft EIS

Impacts upon Great Egret Cattle Egret and Caspian Tern

One respondent expressed concern that the Great Egret Cattle Egret and Caspian Tern are not dealt with satisfactorily One submission noted problems with the nomenclature concerning egrets

Response

The two Egret species being discussed in Section 761 are the Great Egret Egretta (Ardea) Alba and the Cattle Egret Ardea ibis Both species are listed migratory species under the EPBC legislation The Cattle Egret is listed as a migratory species using the binomial Ardeola ibis The reference in Section 77 to the White Egret for consistency should read Great Egret Both are recognised English names for the species Egretta (Ardea) Alba

The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in south-eastern Queensland and north-eastern New South Wales (Marchant and Higgins 1993)

The movements of Caspian Tern are poorly understood they are partly resident partly dispersive and possibly partly migratory (Marchant and Higgins 1993) The species is commonly observed on fresh and marine waters foraging on the wing for fish

Impacts upon pelagic birds

One submission argued that potential impacts upon pelagic bird species had not been properly addressed in the Draft EIS

Response

Pelagic bird species listed in the draft EIS (including all listed Albatross species Blue Petrel Giant Petrels and the Soft-plumaged Petrel) are all oceanic species that have no dependence on Lake Alexandrina for food or habitat Their presence at the site is fortuitous Records are mostly of ocean beach-washed specimens or live animals temporarily blown inland during storm events The weir construction has no effect on their endurance

Impacts upon bush birds

One submission argued that potential impacts upon bush bird species had not been properly addressed in the Draft EIS

Response

The Black-eared Miner Red-Lored Whistler Malleefowl and Regent Parrot are all species that require mallee or woodland habitats that are now largely absent from the edges of Lake Alexandrina These bird species are now locally extinct from the Lakes area because of landscape scale changes to adjacent woodland and mallee habitats Recent observations of these spec ies in the reg ion (as c ited in The Natura l History of Stra tha lbyn and Goolwa Distric ts 2000) are from locations that support very different habitats to those immediately adjacent to

Supplementary EIS for the temporary weir near Pomanda Island -35shy

the Lakes It is highly unlikely that any of these species would be affected by the temporary weir

The Spotted Quail-Thrush is now considered extinct in the Mount Lofty Ranges and Fleurieu Peninsula

Impacts upon Mt Lofty Ranges Southern Emu Wren

Several submissions argued that potential impacts upon the Mt Lofty Ranges Southern Emu Wren had not been adequately addressed in the Draft EIS

Response

The Mount Lofty Ranges Southern Emu-Wren is recognised as an endangered species that inhabits fragmented wet and dry heath in the vicinity of the proposed weir site The nearest known rec ords of the spec ies (sourc e Biolog ic a l Da tabases of SA ) determined by extensive surveys are 35 kilometres from the temporary weir site at the top of the Finniss estuary It most unlikely that the temporary weir proposal would impact negatively on the species however it has been considered in the discussion about impacts in Chapter 13 of the Draft EIS

Impacts upon White-bellied Sea Eagle

One submission argued that potential impacts upon the White-bellied Sea Eagle had not been properly addressed in the Draft EIS

Response

The White-bellied Sea Eagle is regularly observed but not so commonly recorded in the Lower Lakes and Coorong area The species exploits the protected waters at both sites for fishing A recent sighting of a juvenile bird suggests that local breeding also occurs The implications of the temporary weir on this species are outlined in Chapter 14 of the draft EIS

Issues of scope adequacy and definition

Adequacy of species and communities examined

There were a significant number of submissions on this issue and one respondent who argued that the Draft EIS was inadequate in its assessment of ecological impact because the range of species and communities examined was too limited The Draft EIS assessment was constrained to the Matters of NES listed in the EPBC referral documents Submissions raise the criticism that all components of the Ramsar site should be assessed not just nominated Matters of NES because they are interconnected and interdependent

Response

This statement is true in terms of defining changes to ecological character of the Ramsar site And if the temporary weir were to be built under normal operating conditions all ecological components would have been assessed However the impacts of the temporary weir per se were restricted to those ecological components that would occupy the Ramsar Type O (permanent freshwater lakes) wetlands at a water level of -15 m AHD because this will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir

It is also assumed that at -15 m AHD there will be little or no aquatic vegetation in the Type O wetland because historical high turbidity and static water levels have precluded growth of plants that far out into the Lakes The water body that remains would generally be several kilometres from the existing aquatic plant seedbank and would remain very high in turbidity and experience high energy water movement Thus it is not predicted that keystone aquatic plant species will colonise this area before construction of the temporary weir The benthos was not assessed specifically and further research into the species and distribution of benthic fauna at very low lake levels would improve this draft EIS particularly given the dependence of EPBC-listed fish and bird species on benthic fauna

Impacts on other Ramsar Wetland Types (that is the rest of the Ramsar site) were not considered because the impacts of the drought and over allocation were considered to be the primary determinants of change in ecological character for those wetlands

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Current status of waterbirds

One submission noted that the current status of waterbirds and migratory shorebirds at the CLLMM had not been adequately stated and that recent research (Kingsford 2009) had not been referred to

Response

Most waterbird species are migratory to some degree Some species have predictable movements but most species respond opportunistically to climatic events that bring about favourable changes in habitat quality or food resources Local and continental rainfall patterns have a strong influence on the abundance of waterbirds using the Lower Lakes At the continental scale there were significant changes in the amount of rainfall (and subsequent change in area of wetland habitat) between November 2007 and early 2009 In late 2007 the Murray-Darling and Lake Eyre Basins were both drought affected During 2008 South-eastern Queensland and northern New South Wales received record rainfall and a 1-10 year flood occurred in the Lake Eyre Basin The entire populations of some species (Pink-eared Duck for example) respond to these events adopting the most favourable habitat available The large amount of variability in waterbird numbers is expected and it is a strategy waterbirds use to survive the natural variability in the Australian climate

Regular bird survey work at 23 sites around Lake Alexandrina during the last 12 months suggests that there are no detectable changes in the species richness of waterbirds using the Lower Lakes There are more obvious changes in abundance and as a generalisation waterfowl numbers have decreased while shorebird abundance has increased

Adequacy of EPBC Act threatened species and communities lists

One submission argued that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the Murray-Darling Basin including the CLLMM region are currently being evaluated for EPBC listing

Response

The scope of the EIS is confined to Matters of NES Only nationally listed threatened species or nationally listed migratory species or those that contribute to the ecological character of a Ramsar site are matters of NES Species and communities that are under evaluation for listing as threatened but not yet listed are not matters of NES

Adequacy of discussion of EPBC Act-listed species

One submission argued that the discussion of EPBC Act-listed species in the EIS is incomplete and superficial

Response

Additional detail regarding potential impacts to EPBC Act-listed species is provided in several chapters of this supplementary EIS

Omitted flora and fauna records

Natura l History of Stra tha lbyn and Goolwa Distric ts (2000) (Stra tha lbyn Natura lists Club Inc ) and the Tolderol Wetland Management Plan Severa l submissions mentioned tha t the

c onta in information on a number of EPBC Act-listed species that have been recorded in fringing wetlands of the Lower Lakes but were not discussed in the EIS

Response

Natural History of Strathalbyn and Goolwa Distric ts (2000) and the Tolderol Wetland Management Plan may revea l EPBC Act-listed species that have been recorded in the CLLMM in addition to those mentioned in the draft EIS However given the current disconnection of the wetland habitats of the area and the predicted absence of any impact of the temporary weir upon their water regime the temporary weir is not anticipated to cause a significant impact upon the wetland-dependent species of the fringing wetlands of the Lower Lakes

A more thorough examina tion of the litera ture foc ussing on the

Supplementary EIS for the temporary weir near Pomanda Island -37shy

Definition of keystone species

Severa l submissions a rgued tha t the term keystone spec ies had been misused in the Dra ft EIS It was argued that all species that are critical to food chain processes in the Lower Lakes (ie keystone species) should be identified and discussed and that conceptual models detailing the importance of these key biota would help the reader to understand the processes

Response

The Ecological Character Description (ECD) for the site (Phillips and Muller 2006) describes the keystone species of the CLLMM The draft EIS uses the same language and examples of keystone species as does the ECD Correcting an incorrect ECD is beyond the scope of the EIS

Species considered of particular significance

One submission argued that Murray Hardyhead Yarra Pygmy Perch and Murray Cod should be on the partic ula r signific anc e list

Response

list (Section 7-5 of the Draft EIS) The impact of the temporary weir upon these species is examined in Chapter 13 of the Draft EIS

Murray Hardyhead Yarra Pygmy Perc h and Murray Cod a re on the partic ula r signific anc e

Adequacy of description of different wetland types

A number of submissions argued that the ecological information regarding each of the 15 wetland types of the CLLMM was inadequate to assess impacts of the temporary weir upon them

Response

The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170mm occurs only during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD is not a direct impact of the temporary weir and thus is beyond the scope of the draft EIS

Regional importance of the Coorong Lower Lakes and Murray Mouth

It was noted in several submissions that the Chowilla Ramsar wetland has been disregarded as it is greater than 200km from the Lower Lakes and Coorong The EIS needs to consider the regional implications of a degraded Lakes and Coorong and the use of aquatic habitats by migratory bird species If environmental water is not being delivered to the Lower Lakes and Coorong provision for suitable aquatic habitat needs to be made in other areas of the state as a minimum

Response

The proponent notes that both the CLLMM and Chowilla Ramsar sites are regionally significant and that adequate inflows to maintain the ecological character of both are required This issue is outside the scope of the Draft EIS

Australia s Ramsar obligations

A number of submissions raised the issue that Australia does not appear to be committed to wise use of the Coorong and Lakes Alexandrina and Albert Ramsar site and its obligations

under the Ramsar Convention in terms of proposing that this temporary weir be built

Response

The principal factor impacting on the Ramsar site is the low flow of freshwater to the site particularly over the last few years of drought and over-allocation across the Murray-Darling Basin ra ther than a lac k of c ommitment to wise use

Supplementary EIS for the temporary weir near Pomanda Island -38shy

6 Notes on significant issues outside the scope of the draft EIS

For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities

Notes on social and economic issues raised in submissions

In this section a number of significant concerns and ideas detailed in submissions by individuals organizations and local government are canvassed

These concerns and ideas do not focus on Matters of NES protected under Part 3 of the EPBC Ac t and as suc h a re outside the sc ope of Guidelines for the Content of a Dra ft Environmenta l Impact Statement on the Proposed Temporary Weir at Pomanda Island near Wellington South Australia Environment Protection and Biodiversity Conservation Act 1999 (Reference Number 2007 3484) da ted 30 August 2007

However they are registered here because they reflect strong community positions

These concerns and ideas will be taken into consideration during the development of the long term plan for the Coorong Lower Lakes and Murray Mouth region The first step in developing the long-term plan was the release of the Directions for a healthy future document for public c omment during May 2009

Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

One submission raised concern that Ngarrindjeri People has to compete for attention in the consultation process

An additional concern is that the Ngarrindjeri People is not recognised as Traditional Owners

The Coorong District Council emphasized that the Coorong and Lower Lakes have particular significance to the Ngarrindjeri and

Another submission (supported by the River Lakes and Coorong Action Group) stated tha t the Dra ft EIS d isp lays little or no understand ing of the importanc e of c ultura l flows to the Ngarrindjeri

Social and economic issues

A number of submissions noted the lack of content in the Draft EIS on social and economic measures associated with the temporary weir

Generally submissions from individuals organizations and local government indicate that the current social and economic conditions in the Coorong Lower Lakes and Murray Mouth area (as a result of drought lack of fresh water River flows and over allocation of water resources across the Murray-Darling Basin) are very negative When putting forward these concerns submission writers did not usually make clear how the construction of the temporary weir will further contribute to enhancing negative social or economic trends

A submission from the Southern Alexandrina Business Association Inc claims that the boating industry in the region under current conditions is losing $200 million per annum

A detailed submission from the Boating Industry Association of SA Inc claims that business of the leisure tourism and recreational sector and those that support them are suffering enormously from the existing droughtover allocation conditions The

Supplementary EIS for the temporary weir near Pomanda Island -39shy

submission proposes that we need to replenish water stocks including water for the environment Water for the Community and water for the EconomyTertiary Sector

The Rural City of Murray Bridge is concerned that professional fishermen can move up and down the River

The Coorong District Council notes that the dairy industry irrigated horticulture fodder production and beef cattle production have been negatively impacted by lack of access to water Property values have declined by 50 per cent in some cases and most of the 17 dairies in the Coorong District have closed or relocated Council rate revenue is down and

One submission (endorsed by other submission writers) provides a researched and extensive argument about the predominance of contemporary social and economic ideas which favour growth for example of expansionary plantings of a variety of unsustainable crops and growth of human populations and notes the South Australian population expansion in the South Australia Strategic Plan The writer suggests that new ideas about limitations and replenishments are required as well as a move towards adoption of tools like the Genuine Progress Indicator rather than reliance on indicators like Gross Domestic Product

Climate change

One submission asked for a rethink of the Draft EIS based on additional scenarios to the d rought sc enario whic h preva ils in the d ra ft EIS This sc enario is based is the worst

case climate scenario to date

Dust and health

A number of submissions raise concerns about current health problems caused by excess dust being blown from the dry lake bed

Other themes

A number of submissions a rgued tha t the temporary would nec essarily bec ome permanent and some of these argued that a navigable Lock with fish passages would therefore be preferable

A number of submissions argued for a seawater solution rather than a limited inflow to control the possible risks associated with ASS

Some submissions especially from government agencies or Non Government Organisa tions (NGO s) pointed out tha t further approva ls will be required in add ition to those cited in the Draft EIS The MDBA advised that it will require at least six weeks to undertake its approval processes from the time that the additional details are provided On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

Supplementary EIS for the temporary weir near Pomanda Island -40shy

7 Suggested text changes errata additions clarifications and

references

Page Issue raised by submission(s)respondent(s)

Recommended changes

vi Page vi acid sulfate soils box last sentence should read See Chap ters 6 8 11 and 15 for d eta ils

Make suggested changes

115 Pg 1-16 section 152 Environment Protection Act 1993 The Environment Protection (Air quality) Policy could also be included in this section as it applies to potential dust and noise impacts

Reword sentence 1 paragraph 1 section 152 page 115 to read

The Environment Protection Act 1993 (the Environment Protection Act) and the Environment Protection (Air quality) Policy provide legislation for the protection of the environment and the establishment and definition of the powers and functions of the Environment Protec tion Authority (EPA) in South Austra lia

116

12

27

Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

Apparent inconsistency in water usage figures between Table 1-1 and pages 2-4 and 2-12

Pg 2-7 section 24 Red uc ed ra infa ll and

dec rea sed evapora tion should be increased evaporation (many of these inconsistencies throughout document)

Reference to Section 1554 should be changed to Section 15412 Acid Sulphate Soils Safeguards and Mitigation Measures and Table 15-6 titled Potential mitigation measures to manage acid sulphate soils

Appendix 1 question 91 provides clarification

Page 27 rep lac e text Red uc ed ra infa ll and d ec rea sed evapora tion with text Red uc ed ra infa ll and inc reased eva p ora tion

Supplementary EIS for the temporary weir near Pomanda Island -41shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

27 Issues raised concerning the accuracy of the data in Table 23 page 27

Update Table 2-3 to include the following

200607 Inflows

Total flow at the SA Border 1436 GL

Eastern Mount Lofty Ranges estimated inflow 39 GL

200607 Use and Loss

Net Loss(1) 1262 GL

SA Water pumped extraction(2) 245 GL

Irrigation Extraction(3) 377 GL

Total System Deficit -448 GL (4)

(1) Net loss is inclusive of evaporation seepage rainfall EMLR inflows unmetered diversions

(2) SA Water pumping from the River Murray includes 60 GL of water pumped to the MLR reservoirs for use in 200708

(3) note as in document

(4) Deficit is defined as Inflow at SA Border - losses - SA Water pumping - irrigation extraction and corresponds with the fall in water level in Lakes Alexandrina and Albert

2-13

213 219

215

References to 696 GLyr of dilution flow should be clarified

2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Pg 2-15 section 26 Current water level statement (-05m AHD) was incorrect at the time of EIS publication and should be updated and referenced

Appendix 1 questions 9 and 88 provide clarification

Reference to 940 GL on pages 213 and 219 should be changed to 896 GL

The water level in Lake Alexandrina is now at a new record low of -095 m AHD (reference Murray Darling Basin Authority Murray River System Drought update issue 18 APRIL 2009)

The MDBA drought upd a te sta tes tha t During winter in the absence of significant inflows reduced evaporative losses should allow the water level to remain fairly steady and even under a worst case scenario Lake Alexandrina is unlikely to reach the estimated acidification trigger of -15 m AHD prior to February 2010

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Page Issue raised by submission(s)respondent(s)

Recommended changes

215 The salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences

Delete Table 2-4 from the document It is not referred to in the text and therefore serves no purpose Add following text to section 26 para 3

Historic a lly Lake Alexand rina wa s a p red omina tely freshwater system with only brief periods of seawater intrusion during low outflow periods that did not extend beyond Point Sturt (Sim and Muller 2004) DEH is in process of contracting more work to The University of Adelaide to verify this understanding of the pre-European salinity regime of both Lakes Alexandrina and Albert by studying diatom species distribution in dated cores It is predicted that by May 2009 water in the Lake is expected to be at ~6000 EC (Figure 2-11) which is considered to be saline in terms of ecological func tiona lity (Williams 1986)

2-16 11-9 Section 1554 does not exist

The reference to section 1554 should read section 15412 Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant

334 Pg 3-34 Environment Protection (Water Quality) Policy 2003 The Environment Protection (Water Quality) Policy 2003 should be listed under legislation rather than policy section of this table

337 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

337 Pg 3-37 Table 3-5 The National Water Quality Management Strategy should be included in Table 3-5 as this is tool that is being utilised in this region for integrated catchment management to achieve improved water quality outcomes

349 Pg 3-49 Table 3-9 ASS and water quality the Centre for Water Research model should be grouped under this section together with EPACSIRO

4-4 Details and status of SA Water Corporation pump station upgrades

Update Table 3-4 beginning page 331 such that Environment Protection (Water Quality) Policy 2003 is listed under South Austra lian Leg isla tion instea d of und er Sta te Polic y and Pla nning Frameworks

In Table 3-5 Page 337 and anywhere else in the doc ument it is mentioned d elete referenc e to Na tiona l Ac tion Plan (NAP) and rep lac e with Caring for our Country (CFC)

Include National Water Quality Management Strategy in Table 3-5

In Table 3-9 inc lud e Centre for Wa ter Researc h a long with EPA CSIRO in row 3 c olumn 3

Upd a ted sta tus d eta ils of SA Wa ter Corp ora tion s pump station upgrades are provided in Appendix 1 question 14

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Page Issue raised by

submission(s)respondent(s) Recommended changes

442

5-8

510

517

61

Page 4-8 sta tes Costs for undertaking a similar ac tion for Ad ela id e s off takes from the Lower Murray are expected to be very significant (see table 4 3) and the implementation period would be approximately 3 yea rs from initia tion

58 states that once the water level exceeds +01m AHD the temporary weir will cease to serve any useful function

The last paragraph in section 542 should be rep la c ed with The fina l most viable solution may involve multiple rock types from multiple sources to achieve the optimum construction cost within the limited time frame Rock sources with clays fine silts and sands while suitably geotechnically may not be utilised to reduce the potential for environmental impact through turbidity and sedimentation

Insert the following for Section 563 Section 563 of the draft EIS only partially refers to the environmental safeguards and mitigation measures Section 563 should be ignored and Chapter 15 be referred to for safeguards and mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Management Plan (EMP)

Paragraph 1 page 6-1 needs to include rainfall on the Lakes as an input to the system

Delete reference to Table 4 3 from the document

Appendix 1 question 52 provides clarification

Page 510 make suggested changes

At the end of section 563 page 517 add the sentence

Chap ter 15 should b e referred to for sa feguard s a nd mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Ma nagement Pla n (EMP)

Reword sentence 2 paragraph 1 page 61 to read

Freshwa ter from the River Murray the Eastern Mount Lofty Ranges (EMLR) catchments Upper South East (USE) drainage scheme direct rainfall onto the lakes and from groundwater as well as salt water from the Southern Oc ea n a ll input to the Coorong a nd Lower Lakes site

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Page Issue raised by

submission(s)respondent(s) Recommended changes

61 Last paragraph of 61 needs to include a further condition in the list - that of the MDB before the advent of white people as that is the condition that has determined which species live amp belong here

For the sc ope of the d ra ft EIS the baseline c ond itions of the CLLMM are those that existed when the site was listed as a wetland of international significance under the Ramsar convention These conditions are discussed in the Ecological Character Description (ECD) for the site (Phillips and Muller 2006) The draft EIS correctly uses the ECD as a baseline regarding condition It should be noted that many parameters that describe the conditions of the CLLMM are currently beyond the acceptable limits of change as outlined by the ECD due to drought and over-allocation of water

63 Issue raised concerning wording of paragraph 4 page 63

63

65

Issue raised concerning impact of static water levels page 63

Issue raised concerning Barra ge Opera tion Page

65

Change text in paragraph 4 p 6-3 to read

Aquatic vegeta tion has sinc e declined due to static water levels such that only a fringing band of vegetation around the +03 to +06 m AHD water marks remains of the extensive submerged and emergent beds that extended several kilometres into the Lakes pre-European settlement (Sim and Muller 2004)

Remove first bullet point under Figure 6-1 d egra d ed shorelines in sheltered a rea s

Add text below as a new fourth and fifth paragraph under barrage operation (p 6-5)

The b a rrages impede ec o log ic a l c onnec tivity between the fresh estuarine and more saline parts of the Ramsar Of particular concern are the adverse impacts on fish migration and transfer of recruits from one part of the system to another Fish passages have been installed on some gates to facilitate fish movement during periods of barrage opening and the Barrage Operating Strategy seeks to optimise ecological outcomes with each barrage release

The Lower Lakes barrages have not been opened since October 2006 thus there has been no hydrological connectivity between the fresh and estuarinesaline a rea s of the Ramsar site sinc e then

66 Issue raised concerning Ripa ria n La nd

Ma nagement page 66

Add text below as second paragraph under Riparian land management (p6-6)

Inva sion of pest p la nts a nd a nima ls into the wetland s is also a major issue particularly given the close proximity of the agricultural land and the large expanses for wind and water borne weed s to b e d ispersed

69 Issue raised concerning keystone species listed on page 69

Change text in second bullet point under the keystone species for freshwater lakes include (p 6-9) to read

Assemb lages of emergent p la nts (eg Sc hoenop lec tus sp Baumea sp Phragmites australis) along the fringes of the lake and EMLR tributa ries

Supplementary EIS for the temporary weir near Pomanda Island -45shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

610 Issue raised concerning list of factors that influence aquatic plants bottom of page 610

Reword the statement at the bottom of page 6-10 of the Draft EIS with the following

Ganf (2000) identified four issues influenc ing the productivity distribution and community composition of macrophytes

salinity

turbidity

water regime and

wind and wave action

These factors combined mean that submerged aquatic plant growth is restricted to the littoral zone of the mod ern lake environment (Phillip s and Muller 2006)

612 Issue raised concerning wording of caption for Figure 66 page 612

612 Issue raised concerning section 63 page 612

614 A Respondent questioned page 6-14 section 65 of the Draft EIS determinants or drivers

72 73 Bool amp Hacks Lagoons are not upstream of this temporary weir as is implied in the text

74 Page 7-4 section 733 An error messages appears

75 736 Type M permanent rivers streams amp creeks -Lake Alexandrina also takes the flow from the Rivers Angas amp Bremer amp Mosquito Creek between Milang amp Langhorne Creek

Pg 6-12 Figure 66 c ap tion should rea d d rivers a nd levers (not d rivers and levels )

Section 63 shy Pg 6-12 Include the following text as sentence 2 of paragraph 3

Direc t ra infa ll on the lakes a nd evapora tive losses a re key components of local climate that have the potential to impact greatly on the resultant water reg ime of the site

Sec tion 65 first p a ra graph rep lac e The p rima ry d rivers for ecological character includ e with The p rima ry determinants of ecological character are (Phillips and Muller 2006)

Reword sentence 1 paragraph 2 section 73 page 72 as follows

Banroc k Sta tion Wetla nd Complex Riverland wetla nd s and Hattah-Kulkyne Lakes are located more than 200 km (minimum) upstream of Pomanda Island and are unlikely to be a ffec ted by the temporary weir

Following sentence 1 add additional sentence

Bool and Hacks Lagoons are located outside of the MDB and over 200 km from Pomanda Island and will therefore b e una ffec ted b y the temp ora ry weir

Rep la c e text Error Referenc e sourc e not found With text Figure 7-2

The Rivers Angus and Bremer and Mosquito Creek are classified as wetland Type N -seasonalintermittentirregular riversstreams and creeks These tributaries should be referred to in Section 737 of the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -46shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

731 756 Plant associations in close proximity to the temporary weir Only one of the 11 dot points is actually a plant association

Reword the sentenc e The p lant a ssoc ia tions in c lose p roximity to the temp ora ry weir site inc lud e to read

The d ominant or c o-dominant plant species in close proximity to the temp ora ry weir site inc lud e

Replace dot point Muehlenbeckia florulenta tall open shrub land with Phra gmites a ustra lis with two d ot points

Muehlenbec kia florulenta

Phra gmites austra lis

732 Page 205 - Table 7-6 should be checked for accuracy Cattle Egret is not EPBC listed migratory species

According to the EPBC Act website Cattle Egret is a listed migratory species therefore its listing in Table 7-6 is correct See

httpwwwenvironmentgovaucgishybinspratpublicpublicspeciespltaxon_id=59542`

Chapters 4 and 9

101

102

102

Text in the executive summary chapters 4 and 9 erroneously includes the use of toxins when the intended meaning is in fact toxicants Toxins are substances produced by living cells such as algal toxins etc whereas toxicants are a broader range of chemicals that produce a toxic response in living organisms

Correct the assertion in 102 Existing drought conditions that the dropping of Mungkuli (Lake Alexandrina) to below sea level for the first time in 7500 years is due to drought

Chapter 10 - Figure 10-1 -Lake Alexandrina water level 1962-2008 Full supply level = +075m AHD - EIS is incorrect

Tookayerta Creek is a tributary of the Finniss River and not Lake Alexandrina as stated Further the Finniss River and Currency Creek flow into the Lower Murray not into Lake Alexandrina

Delete the word toxins from c ha p ters 4 a nd 9 and rep la c e with the word toxic a nts

Change sentence to read

In rec ent times the wa ter level in the River Murray Coorong and Lower Lakes has been significantly lowered by the existing drought conditions and over-allocation of water associated with the entire MDB (Table 10 1)

It is the proponents understanding that +075 m AHD is referred to as full sup p ly level and tha t wa ter levels above this a re referred to as a surc ha rge

Reword sentenc e The EMLR tributa ries tha t d isc harge into Lake Alexand rina a re to read The EMLR tributaries that discharge into Lake Alexandrina and the Lower Murray a re

Delete d ot point Tooka yerta Creek from the bottom of page 10-2

Reword d ot point Finniss River to rea d Finniss River (inc lud ing Tookayerta Creek)

Supplementary EIS for the temporary weir near Pomanda Island -47shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

104

1013

1030

1030

Figure 10-3 Goolwa amp Lake Alexandrina Salinity Survey results - September 2008 EIS in error re the salinity level of Lake Albert This figure 10-3 states that 7300EC (which is approx

sea wa ter) is semi-saline

1035 - Predicted water level in Lake Alexandrina -water levels are also affected by rainfall which is not mentioned

To say that potable water supply is less than 2500EC is pushing the boundaries PIRSA documents state a salinity of 1000mgL (1666EC) is generally palatable to most tastes but up to 1500mgL (2500EC) can be acceptable in areas where better quality water is not available

The tolerable salinity limits for freshwater species needs to take into account peak levels not average levels

The d efinition of semi-sa line is p rovid ed in Tab le 2-4 of the draft EIS and refers to salinities between 5001 and 11666 EC Thus the document is consistent

Reword first sentence of Section 1035 as follows

Historic a lly wa ter levels in La ke Alexand rina have varied on a seasonal basis with water rising in winter through increased winter inflows direct rainfall and decreased evaporation and falling in summer through red uc ed inflows a nd inc reased eva p ora tion

This point is noted however it has no bearing upon the temporary weir since salinities in Lake Alexandrina are predicted to reach gt2500 EC throughout the lake during 2009 with or without the temporary weir

In Section 1043 (page 10-30) delete paragraph 3 since it has no biological or ecological relevance Revise paragraph 4 to read

Pea k or maximum sa linities a re most important ecologically because all aquatic species have salinity tolerances that if exceeded even briefly can be fatal Table 10-9 presents modelled peak salinities at points in Lake Alexand rina und er without weir and with weir scenarios during the first year of weir operation For all points modelled peak salinity in the first year is higher und er the with weir sc ena rio

10-32 Reference to 685 GL as extra water available is misleading

Agreed Clarified in Appendix 1 question 32

Supplementary EIS for the temporary weir near Pomanda Island -48shy

a ns

Page Issue raised by

submission(s)respondent(s) Recommended changes

1113 Pg 11-13 Figure 11-5 This graph could be updated to 2009 using current EPA data

Update Figure 11-5 on page 11-13 with the following which includes the most recent data

Turbidity Lake Alexandrina - Poltalloch Plains

20

40

60

80

100

120

140

160

180

200

24-Jul-98 6-Dec-99 19-Apr-01 1-Sep-02 14-Jan-04 28-May-05 10-Oct-06 22-Feb-08 6-Jul-09

Date T

u rb

id it

y (N

T U

)

Lake Alexandrina - Poltalloch pl i Ecosystem protection guideline (ANZECC)

0

121 Section 121 It is certain that the temporary weir will interact with ecological values of lower river amp lakes

121 Pg 12-1 section 122 Bottom of page 12-1 In general temporary wetlands have few animal species than permanent ones is this referring to abundance or richness or what Too general and incorrect in some circumstances

122 Chapter 123 - Ramsar listed wetland upstream of expected weir site near Pomanda Island - EIS incorrect amp needs amendment

Delete the word may from sentenc e 1 p a ra grap h 3 section 121 page 121

Bottom of page 12-1 delete the following sentenc e In general temporary wetlands have fewer animal species than p ermanent ones

On pg 12-2 rep lac e the text There a re no Ra msar-listed wetla nd s between Loc k 1 a nd the temp ora ry weir site with the following There a re no Ramsa r-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ra msar site

Supplementary EIS for the temporary weir near Pomanda Island -49shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

125 Issues raised concerning wording of Table 123 commencing page 125

In Table 12-3 make the following changes

For Cla ss M ad d text to sixth c olumn Inc reased hea d pressure may result in increased drainage to the lakes and reduced groundwater baseflow in groundwater depend ent ec osystems

For Class M seventh column change existing sentence to read there is no interac tion of the weir with the surfa c e wa ter in these wetlands

For Class M add sentence to third column that reads Inc reased head p ressure of up to 21 c m may result in

c hang e in ground wa ter b a seflow

For Cla ss 4 und er Imp a c t of p roposed tempora ry weir within Ramsar wetla nd s to existing text ad d whic h oc c urs a t wa ter levels gt 087 m AHD

For Cla ss Xf und er Existing c ond ition (a p p roxima tely shy05 m AHD) rep la c e No rec ord ed c ha nge with Not connected to the main body of the lake Will only be a ffec ted b y ongoing d rought

For Cla ss Tp c hange text in sixth c olumn to read Most disconnected but some reconnection and marginal improvement from winter ra infa ll and tributa ry inflows

Formatting issue in title of sixth column the negative is there in the column heading but there has been line split between it and 15 so it looks like +15 m AHD not -15 m AHD (should be latter)

1215 Issue raised concerning wording of Section 125 page 1215

Reword Section 125 (pg 12-15) in its entirety to read

As d eta iled in Sec tion 1241 a ll wetland hab ita ts downstream of the proposed temporary weir location are expected to be affected by the drought and by 2012 only Ramsar-wetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flows as described on page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

1216 Issue raised concerning potential positive impact of rewetting of acid sulphate soils

Section 1251 page 1216 remove reference to re-wetting of acid sulfate soils and pH drop to 2 (last dot point) from positive impacts list

Supplementary EIS for the temporary weir near Pomanda Island -50shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

12-20 Table 12-4 only lists predicted changes for 2 out of 6 primary determinants of ecological character

Update Table 12-4 to include the following

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts

(2010 2012)

Salinity Discussed extensively in Section 10

Water Level Discussed extensively in Section 10

Water Regime Discussed extensively in Section 10

Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

1310 Issue raised concerning comprehensiveness of Table 133 page 1310

To Table 13-3 insert two additional rows

1st c olumn Intera c tion 2nd c olumn Disrup t d ispersa l of tadp oles

1st c olumn Spec ies p referenc e 2nd c olumn Present upstream and downstream of site but dispersal requirements of d ifferent p op ula tions a re unknown

141 Section 141 What is the definition of regularly recorded amp by whom were they recorded

In sec tion 141 p a ge 141 p a ragraph 4 rep lac e (see Chapter 7) with (Letc h 2007)

1519 pg 15-19 section 15412 Performance criteria The acid sulfate soil trigger levels are given in Table 15shy6 not Table 15-5 as stated in the document

In d ot p oint a t bottom of page 1519 rep lac e Tab le 15shy5 with Tab le 15-6

1519 Remove Table 15-5 There are no cross-references to the table

Table 15-5 is referred to on page 1519 and should be retained in the document

162 The summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Additional comment o be inserted in Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir) after text

The ECD of the Coorong and Lakes Alexa nd rina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Nationally listed threatened and migratory species are addressed elsewhere in this table Other species are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetla nd s will persist

Supplementary EIS for the temporary weir near Pomanda Island -51shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

Throughout document

Throughout document

Throughout document

Australia operates on SI system of measurements amp this includes the millimetre metre units of measurement amp does not include centimetres

Convert centimetres to millimetres or meters as appropriate throughout the document

Correct injustice throughout draft EIS of identifying Ngarrindjeri merely as custodians community or people (112 164 165 171 1522)

Cha nge Ngarrind jeri c ustod ians and Nga rrind jeri c ommunity to Ngarrind jeri Peop le as ap p ropria te

throughout the document (as per submission PTW00046)

Text in the executive summary and throughout the document (chapters 1 2 4 8 11 12 13 15 and 16) refers to the use of the wording heavy metals when in fact this is misleading and should simply be referred to as metals

Rep la c e a ll referenc es to hea vy meta ls with meta ls

Supplementary EIS for the temporary weir near Pomanda Island -52shy

References

Bice C and Ye Q (2009) Draft Report - Risk assessment of proposed management scenarios for Lake Alexandrina on the resident fish community South Australian Research and Development Institute (Aquatic Sciences) Adelaide South Australia

DWLBC (2009) River Murray Data Department of Water Land and Biodiversity Conservation Adelaide South Australia httpdatarivermurraysagovau

Wellington Weir Site Flora and Fauna Assessment (South Australian Water Corporation Adelaide South Australia) Ecological Associates (2008) Draft Report

Ganf G G (2000) Aqua tic and ripa rian vegeta tion in A Jensen M Good P Harvey P Tuc ker amp M Long (eds) River Murray Barrages Environmental Flows An evaluation of environmental flow needs in the Lower Lakes and Coorong report to MDBC pp 30 34

Khan M T Khan T A and Wilson M E (2004) Habitat use and movement of river blackfish (Gadopsis marmoratus R) in a highly modified Victorian stream Australia Ecology of Freshwater Fish 13(4) 285-293

Lintermans M (2007) Fishes of the Murray-Darling Basin An introductory guide Murray-Darling Basin Commission Canberra ACT

Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks (Oxford University Press Melbourne)

Williams WD (1986) Conductivity and salinity of Australian Salt Lakes in Australian Journal of Marine and Freshwater Research 37177-182

Supplementary EIS for the temporary weir near Pomanda Island -53shy

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA)

General comments

1 Lots of inconsistencies particularly in figures Several of these are the result of some sections of the EIS having been updated to reflect the current environmental conditions but not others however some are just contradictions

Response Inconsistencies are corrected in the Supplementary EIS

2 In general at -15m AHD many wetland types will have already disconnected so the weir will not cause further impacts but it will slow down any potential recovery from drought impacts Please discuss and quantify these implications

Response The temporary weir will cause a 17cm drop in Lake Alexandrina water levels during the weir pool filling period under modelled worst-c ase sc enario however in the longer term there is little difference in the water levels and salinity values between weir and no weir sc enarios Quantific a tion of the amount of wa ter tha t would be

needed to refill desiccated Acid Sulfate Soils remains a knowledge gap that could be filled through field trials

3 There is a general lack of detail on what measures will be used to mitigate impacts on species (eg on pg 13-6 it says measures should be taken to ensure the wetland vegeta tion and assoc ia ted c ommunities a re not c ompromised without going into any further detail) Please review any proposed measures and provide details and commitments to undertake measurable actions

Response Detailed measures will be written in the CEMP OEMP and DEMP by SA Water The d ra ft EIS EMF and EMP outline wha t SA Water s EMP s should add ress

expec ted etc Please clearly state where you are committing to do something A table showing actual commitments would be useful

4 Vague and uncommitted language throughout the whole document

Response The South Australian Government is committed to the following actions in relation to the weir near Pomanda Island

Development of a CEMP OEMP and DEMP and submission of the EMP to relevant authorities including the SA EPA prior to any works being undertaken Incorporation of a fishway to suit large and small species A detailed submission to the MDBA for approval under the Water Act 2007 (Cwth) On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure Mitigation strategies and monitoring program as detailed in the EMP and in the amended Table 15-3 (see question 5 below) o The CEMP will be based on a risk management framework and an

environmental impact assessment (EIA) o Monitoring of water quality will be included in a water quality report to be

made available through the SA EPA

Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth

A summary of all projects follows Projects highlighted in green are completed or currently underway Orange highlighted projects are those currently being investigated and are likely but not certain to be undertaken Pink highlighted projects are those either in the early stages of planning and may be difficult to implement or are considered only a last resort solution due to other undesirable implications

Supplementary EIS for the temporary weir near Pomanda Island -54shy

Project StatusTiming Completed or Underway

Pipelines Potable Lower Lakes districts Irrigation Langhorne amp Currency Creeks

Potable construction completed January 2009 Irrigation EPBC referral (20094743) not controlled action if undertaken in particular manner due for completion October 2009

Feasibility study Long term management plan for adaptive management

30 March 2009 - Version 1 - under review prior to public consultation May 2009 Public Consultation on Version 1 30 June 2009 - Version 2 August - public consultation on Version 2 30 September 2009 - Final

Lake Albert Blocking bank in Narrung Narrows Pumping from Lake Alexandrina Lake Albert Future paper Pumping ceases 30 June 2009 Bioremediation

Blocking bank completed in May 2008 Pumping began 02 May 2008 Expert workshop held 8 April 2009 Paper prepared On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from the end of June 2009 and that a bioremediation program will be instituted

Dredging Murray Mouth Ongoing almost continuous operation since October 2002

The Living Murray (TLM) Icon Site management Icon Site condition monitoring Modelling Indigenous partnership Communications and consultation Water bids

Coorong planning document completed TLM progress report sea level impact assessment and alternatives to keep Murray Mouth open underway Condition monitoring ongoing Monitoring methodology plan completed sent to MDBA Modelling Stages 1 2A completed 2B December 2009 Interim modelling results for LLCMM due June 2009 Indigenous partnership program ongoing

Regulators Goolwa Channel Mouth of Finniss River Mouth of Currency Creek

EPBC referral submitted for public notice on 6 April 2009 Initial closure of the regulators 17 July 2009 Commencement of pumping water from Lake Alexandrina to Goolwa Channel 17 July 2009 Practical completion of the regulator within the Goolwa Channel 17 Sept 2009

Assessment of acid sulfate soils Rapid Risk Assessment Lock 1 to Wellington

Fieldwork for both completed Laboratory analysis underway completed for 24 priority wetlands below Lock 1 Survey work and modelling undertaken on inlets to 24 priority wetlands below Lock 1 Identification of priority sites creation of an action plan and application for funding underway

Lower Murray Reclaimed Irrigation Areas (LMRIA) Program

Completion of Program by June 2009 Completion of all mandatory works achieved 2008 Non-mandatory works nearing completion Post-program review to be instigated in near future

Upgrade of Pomanda Peninsula Causeway

EPBC Referra l not a c ontrolled ac tion 23 January 2009 Works currently underway in preparation should it be necessary to construct the temporary weir

Currently Being Investigated

Mitigation of acid sulfate soils using Mulch Revegetation Liming

Trials for all three currently underway Large scale application dependent on trial results and acidification time of the lower lakes

Supplementary EIS for the temporary weir near Pomanda Island -55shy

Project StatusTiming Increase inflows to Coorong South Lagoon REFLOWS Upper South East Drainage scheme (USED) water via Salt Creek Fairview Drain link

REFLOWS funding available REFLOWS cultural heritage underway REFLOWS native vegetation assessment almost complete REFLOWS landholder consultation complete REFLOWS community perceptions survey complete USED second stage feasibility study due 30 June 2009 USED 3 to 4 years to investigate and then implement Fairview initial landholder engagement commenced on hold until Reflows and Bald Hill decision made

Temporary Weir near Pomanda Island Draft EIS released for public consultation Supplementary EIS in progress Construction works to begin if Lake Alexandrina levels drop to -15 m AHD Could be avoided if sufficient freshwater flows obtained Early Planning Stages

Salinity build up in Coorong South Lagoon Dredging between north south lagoons Pump hyper-saline water to ocean

Both under preliminary investigation Pumping could only be done during autumnwinter to allow flows to replace pumped out water hence may not happen till 2010

Seawater intrusion into the lower lakes As a last resort to mitigate acid sulfate soils

EPBC referra l (EPBC 2008 4618) c ontrolled ac tion requiring EIS The final guidelines for the EIS released 13 March 2009 EIS targeted September October 2009

The projects can be divided into three categories

1 Long term plans looking to address the bigger picture with sustainable solutions Projects such as

Potable pipelines around lower lakes districts Irrigation pipelines Langhorne and Currency creeks Feasibility StudyLong Term Plan for Adaptive Management for CLLMM Lake Albert Future paper The Living Murray (TLM) programs Lower Murray Reclaimed Irrigation Areas (LMRIA) Program REFLOWS Upper South East Drainage scheme (USED) water into the Coorong via Salt Creek and Fairview Drain to Coorong link

2 Emergency measures designed to mitigate urgent issues with severe impacts Most are not long term and are designed to address a specific issue

Blocking bank in Narrung Pumping from Lake Alexandrina to Lake Albert2 Dredging Murray Mouth Goolwa Channel regulator Finniss River low level regulator Currency Creek low level regulator Pump water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel Rapid Risk Assessment of acid sulfate soils Assessment of acid sulfate soils from Lock 1 to Wellington Mitigation of acid sulfate soils

2 On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -56shy

o Bioremediation using mulch o Bioremediation using revegetation o Liming of exposed lake beds and o Liming of inflows

Salinity build up in Coorong South Lagoon o Dredging between north south lagoons and o Pump hyper-saline water to ocean

3 Last resort emergency measures only to be undertaken at critical trigger points when all other alternatives have been exhausted

Temporary weir near Pomanda Island Seawater intrusion into the Lower Lakes

Further details on each project are available if required

5 In several places throughout Chapter 15 monitoring is proposed as a mitigation measure by itself monitoring does not mitigate an impact it can only help inform when to implement a mitigation measure Please provide an actual mitigation response linked to monitoring

Response The Environmental Management Plan in Chapter 15 of the Draft EIS has been augmented in the Supplementary EIS SA Water is responsible for preparing the CEMP OEMP and DEMP Environmental Management Plan that will detail the mitigation strategies and monitoring program This will be written in conjunction with the contractor

SA Water will be responsib le to ensure tha t the c onstruc tion c ontrac tor s EMP inc ludes adequate monitoring protocols for water quality and other environmental issues throughout the construction phase The EPA DWLBC SA MDB NRMB NVC local council and other relevant agencies will be consulted on the content of any environmental risk assessment and mitigation measure In addition specific State approvals will be obtained these usually stipulate specific conditions to be included in an EMP or similar management tool

The Contractor EMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

See also 80

Table 15-3 has been amended

Table 15-3 Potential mitigation measures for water quality parameters

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Develop and implement a Soil Erosion and Drainage Management Plan in accordance with the Stormwater Pollution Prevention Code of Practice for Local State and Federal Government

Works are expected to be planned and carried out to minimise the effects of runoff and erosion on the site and downstream areas

Surface water quality

Ensure that erosion and sediment control measures are in place prior to commencing any earthworks

Supplementary EIS for the temporary weir near Pomanda Island -57shy

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Sediment control structures are expected to be established around all areas prone to erosion including stockpiles batters and drainage lines Careful placementremoval of embankment material to reduce turbidity

Scouring mud waves and bank slump are a potential consequence of installation of the temporary weir Scouring and mud waves may be reduced by controlling flows and spillway width while area of impact associated with bank slump is expected to be reduced by weir design and careful placement of embankment materials

Use of sediment curtains around weir placementremoval to limit effects of turbidity created with placement of material and subsequent mud-wave Stabilisation of River banks immediately following constructiondecommissioning Treatments may include

Revegetation

Placement of geofabric

Obtain EPA Endorsement of the proposed approach to surface water

Exception to allow placement of fill material to create weir structure

Wetland management Develop and implement a Wetland Management Plan to manage the change in flow patterns resulting from the construction operation and decommissioning of the proposed temporary weir

Develop and implement a Groundwater Management Plan for the project

Groundwater

Groundwater is expected to be monitored throughout the construction operation and decommissioning phases of the temporary weir project

Groundwater parameters which may require monitoring include

Confined and unconfined water levels

Salinity

Hydraulic gradient

Supplementary EIS for the temporary weir near Pomanda Island -58shy

Project PhaseParameter Potential mitigation measure

Monitoring is expected to take place both upstream and downstream of the temporary weir

Existing monitoring programs which may be relevant include

DLWBC OBSWELL database

RMCWMB groundwater monitoring program

CSIRO Water for a Healthy Country

Obtain endorsement of the proposed approach to groundwater monitoring from DWLBC andor the EPA

Develop and implement a water quality monitoring program based on existing programs and monitoring stations

Monitoring

If water quality parameters are exceeded the following measures may be implemented

Increase use of geofabrics and turbidity curtains to address inadequacies in turbidity management

Cease work if turbidity if triggers are exceeded until such time as the triggers return to desired levels

Aeration should monitoring indicate that oxygen is required

Mixing to prevent temperature stratification of weir pool

Mixing aeration to prevent temperature stratification of weir pool

Co

nst

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tion

Op

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tion

De

co

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on

6 The extent of the Ecological Character (EC) of the Ramsar site is greater than the fringing Wetlands It includes the bodies of water in the lakes the species in on and above Although the individual aspects of the EC are mostly noted in the EIS the summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Response Additional comment o be inserted in Errata Chapter Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir)

The ECD of the Coorong and Lakes Alexandrina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Those species that are not listed nationally are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetlands will persist

7 Is it likely that the water body of Lake Alexandrina will acidify during the no-flow period given the drop in water level If so how does SA propose to manage this Does this mean that the weir closure period will bring the real time management strategy water level acidification trigger forward

Response See page 22 and 23 of the Supplementary EIS

Supplementary EIS for the temporary weir near Pomanda Island -59shy

The South Australian Government is investigating and implementing a range of acid sulfate mitigation measure including application of limestone and bioremediation The possible use of seawater is also being examined (EPBC Act reference 20084618 and an EIS is currently being prepared Introduction of seawater will only be undertaken if the temporary weir is in place the acidification triggers are reached and relevant approvals in place

Water quality monitoring in Lake Alexandrina (eg at -10 m AHD) indicates alkalinity is high (between 170 and 250 mgL as CaCO3) which means the water has relatively good buffering capacity depending on the transport of acidity (fluxes) from exposed sediments During periods of no flow pulses of acid can be transported to the water by rainfall or seiching (wave action) events However given that sulfuric materials have already formed over large areas the higher risk of acidification comes with refilling of the waterbody when mineral salts can be dissolved and acidic porewater can diffuse into the water column (note some research indicates this could occur with freshwater or saltwater ingress)

Management trigger levels for alkalinity and pH have been developed and trends are being monitored fortnightly If any of the trigger levels are approached (ie at different alert levels) the Government of South Australia will instigate certain actions such as monitoring at a higher frequency or implementing limestone slurry dosing programs

The biogeochemical modelling points to waterbody acidification at either a pH less than 6 or water levels below -15 m AHD Further refining of the modelling and investigations of sulfide oxidation rates and acidity transport are being undertaken and early indications are that waterbody acidification is more complex than relating it just to water level As such the weir closure period may not necessarily bring forward Lake Alexandrina acidification

8 The EIS states there will be a number of plans that do not appear to be available yet it is difficult to assess the effectiveness of mitigation without seeing these plans When will these be provided

Response Development of plans and actions is ongoing Response to 4 above lists many of these including the Long Term Plan Many plans have been provided to DEWHA as they are prepared

9 The EIS indicates that disconnection is likely to occur for 2-35 months even though under worst case scenarios it could be up to 7 or 8 months (Table 10-6) The EIS assessment is based on no flow period of 3 months Is the reason for this because SA is currently receiving 896GL over the border and they anticipate getting at least this amount in the 2009-2010 water year and subsequent years Or is there other justification for the reasons for using 25-3 month disconnection This difference in time period could change the likely impacts on hydrology and water levels which are key determinants of ec olog ic a l c harac ter DEWHA s assessment will take into ac c ount the worst case scenario

Response South Australia is now guaranteed a flow of at least 896GL during 2009-10 as the 200GL required for Critical Human Needs has already been secured and is held in reserve Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream The estimated time for disconnection for the 696 GL scenario is not relevant

The Errata chapter includes replacement of references to 940 GL with 896 GL on pages 2-13 and 2-19 of the Draft EIS

The time required to fill the weir pool from approximately -15m AHD to +01m AHD will be approximately 25 3 months If it is necessary to fill the weir pool more slowly (eg to minimise damage to upstream wetlands banks and levees) the flow at Lock 1 will not be reduced and any additional water will be delivered into Lake Alexandrina through a by-pass structure

10 As specified in 1(g) of the EIS Guidelines can you please detail the interaction between this action and others in the CLLAMM

Response Discussed at 4 above

Supplementary EIS for the temporary weir near Pomanda Island -60shy

11 In Part 3 of the EIS Guidelines you are required to take into account the long-term options for the CLLAMM While the Department acknowledges the actions that are being undertaken to develop a long term solution how will this action limit long term options

Response As discussed in the Supplementary EIS South Australia considers that the weir if constructed will not limit long term options Long term options are being actively planned in the knowledge that the temporary weir may be constructed

12 Section 11 of the EIS Guidelines require the objectives of the EPBC Act to be addressed Can you please provide further information addressing these objectives

Response The Draft EIS endeavoured to address the Guidelines for the Proposed Temporary Weir This Supplementary EIS supplements this by the addition of the community consultation report and a detailed review of issues raised

The response to question 4 details all related actions that the government is taking in the Coorong and Lakes Alexandrina and Albert Ramsar site including the development of a comprehensive long term environmental plan that shortly will be released for community consideration

Objects of the EPBC Act

(a) In the face of unprecedented environmental degradation of the Ramsar site and matters of national environmental significance caused by low freshwater inflows we are undertaking substantial conservation and remediation work involving many South Australian Government agencies These are outlined in the Supplementary EIS

(b) (c) (d) Further specific actions to conserve natural resources and bio-diversity are likely to be announced shortly in conjunction with the Australian Minister for Climate Change and Water It is expected that majority of these actions will be undertaken by local government the community land holders and the Ngarrindjeri People

(e) As the South Australian agency responsible for the Environment and Heritage and one of the custodians of the internationally listed Ramsar site the Proponent seeks to c oopera tively imp lement Austra lia s interna tiona l environmenta l responsibilities

(f) (g) The South Australian Government acknowledges the Ngarrindjeri People as traditional owners within the area of their current Native Title Claim within the context of the Aboriginal Heritage Act 1988 The Ngarrindjeri People collectively and individually have been consulted and given an opportunity to comment on the Draft EIS along with all other stakeholders and members of the c ommunity The State Government is endeavouring to develop a formal overarching agreement with the Ngarrindjeri in relation to consultation and negotiation on a range of environmental and cultural matters of joint interest

Work with Aboriginal people to manage biodiversity cooperatively and contribute to the reconciliation of past actions

Comments on ESD are included at question 25

More specific comments

13 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

Response Noted Corrected in Errata

14 On pg 4-4 it says that 3 of the 4 pumping stations are complete with only Murray Bridge to be completed but in Table 4-4 on the same page and on pg 2-3 it says Swan Reach is the only pumping station still to be completed

Response Mannum and Tailem Bend are complete Swan Reach was completed late December 2008 Murray Bridge has 2 pumps modified for lower water level operation but we are delaying some work on one pump at Murray Bridge in order to test it (unshymodified) in order to be better able to confirm the lower limit of operation

DEH s Corp ora te Plan inc lud es the objective

Supplementary EIS for the temporary weir near Pomanda Island -61shy

15 Orange-bellied Parrot sec tion 752 doesn t mention samphire hab ita t

Response Firstly in the history of documentation relating to this EIS on the preferred habitat of the Orange-bellied Parrot There appears to have been some confusion over the use of the words saltmarsh and samphire

Samphire is used interchangeably in South Australia to describe

a) species in the genera Sarcocornia and Tecticornia (formerly Halosarcia and Sclerostegia) and

b) habitat dominated by such species

Thus saltmarsh and samphire are interchangeable terms to describe the same habitat

Food plants associated with samphire (or saltmarsh) habitat are certainly known to be used as feeding habitat by the Orange-bellied Parrot in the lower lakesupper Coorong with recent records from this habitat from the Snake Pit (Tauwitchere Point) and Sir Richard Peninsula (Beacon 19) in recent years (06-08) predominantly from Sarcocornia

However it appears that within South Australia the Orange-bellied Parrot is less dependent than previously suspected on samphire vegetation Recent observations in South Australia (2003-) suggest that the species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

While most records are within 10km of the coast Orange-bellied Parrots were recorded in winter in the Tolderol area (north-western shore of Lake Alexandrina) between 1981 and 1985 (John Eckert sightings lodged with Birds Australia) and there is an anecdotal record of this species foraging in the Wellington area at Nalpa Station

In the referral for the Pomanda Island causeway (EPBC 4676) it is stated that the Causeway upgrade could at worst disturb less than 014 ha of samphire shrubland With 1289 ha of this habitat within the Ramsar boundaries the maximum loss of samphire species would be 001 In addition Ecological Associates (2008) identify that samphire species regenerate relatively quickly after disturbance

16 The Great Egret Cattle Egret and the Caspian Tern are not dealt with satisfactorily (pp 7-3334)

Response The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in SE Qld and NE NSW (HANZAB3)

The movements of Caspian Tern are poorly understood partly resident partly dispersive and possibly partly migratory (HANZAB1) The species is commonly observed on fresh and marine waters foraging on the wing for fish

17 The potential decommissioning impacts (pg 8-7) says tha t The impac ts a re expec ted to be further assessed during the planning for the decommissioning p rojec t as the

3 Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks Oxford University Press Melbourne

Supplementary EIS for the temporary weir near Pomanda Island -62shy

decommissioning is part of the referred action details will need to be provided to determine what the potential impacts are

Response The nominal design life for the temporary weir is 3 years and therefore not all impacts of the decommissioning are able to be assessed at this point in time For example it is difficult to be able to identify projects where the removed rock can be usefully employed

There a re no Ramsar-listed wetlands between Lock 1 and the p roposed temporary weir site however the Coorong and Lakes Alexandrina and Albert Ramsar site extends someway upstream of the weir site

18 On pg 12-2 the EIS sta tes

Response The Coorong and Lakes Alexandrina and Albert Ramsar site extends approx ten kilometres upstream of the proposed weir site (at the apex) to a point that represents the confluence between Lake Alexandrina and River Murray proper The relevant sentence on Pg 12-2 has been reworded to say There a re no Ramsar-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ramsar site

19 On pg 12-15 the EIS says tha t the weir will ac c elera te d rops in wa ter level during the period of d isc onnec tion however all the downstream wetlands will supposedly have already disconnected due to drought conditions with the exception of wetland type O whic h is not expec ted to d isc onnec t It is not c lear what period of d isc onnec tion is being referred to

Response The period of disconnection being referred to is the time during which there will be reduced flow over the temporary weir from the River Murray channel into Lake Alexandrina nominally 25 3 months (as discussed under question 9 and page 13)

Reword Section 125 (pg 12-15) in its entirety to read

As deta iled in Sec tion 1241 a ll wetland habitats downstream of the temporary weir location are expected to be affected by the drought and by 2012 only Ramsarshywetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state

Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flow see page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

20 Throughout Chapter 12 the EIS refers to impacts on EPBC-listed flora and fauna species only but it should be considering all flora and fauna within the Ramsar site

Matters of Na tiona l Environmenta l Signific anc e as a matter of p riority however implic it in the EIS and in our Ramsar obligations are the impacts upon all flora and fauna within the Ramsar site Tortoises and Japanese Snipe are good examples of non-threatened species that have been or are likely to be affected by altered hydrology or water quality There is an infinite list of taxa that could be considered in detail some of which we know little about but much of this work falls outside the scope of the EIS

Response The EIS foc uses on threa tened spec ies and

The EIS refers to Matters of NES (eg EPBC- listed flora and fauna) that will still be occupying Type O wetlands which will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir Impacts on other Ramsar Wetland Types (ie the rest of the Ramsar site) were not considered because the impacts of the drought were considered to be the primary determinants of change in ecological character for those wetlands Further discussed in Supplementary EIS

Pred ic ted c hanges to p rimary determinants of ec olog ic a l c harac ter ) only lists the p red ic ted c hanges for 2 out of the 6 p rimary determinants

21 Table 12-4 (titled

Response Update Table 12-4 to include the following

Supplementary EIS for the temporary weir near Pomanda Island -63shy

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts (2010 2012)

Salinity Discussed extensively in Section 10 Water Level Discussed extensively in Section 10 Water Regime Discussed extensively in Section 10 Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

22 Sec tion 127 (Summary of Chapter 12) doesn t summarise the impac ts as a result of the weir only the impacts from the drought

Response Discussed in Supplementary EIS

23 There doesn t appear to be any c onsidera tion of the interac tion between the timing of construction and when migratory species will be present (eg no consideration on pp 13-78 of whether the timing of construction (potentially October-January) will impact on when the Orange-bellied Parrot will be there (potentially March-early November))

Response As indicated in chapter 13 of the draft EIS there is a low risk that construction will impact on OBPs Construction works are localised and OBP habitat is not affected The only impacts to migratory birds including OBP may occur during the actual construction phase (displacement and habitat loss) and are expected to be short lived

Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to minimise the impact on Orange-bellied Parrots may result in construction occurring when other migratory species are present Migratory shorebirds for example generally return in late August and spend the entire summer at the Lower Lakes

24 In Table 15-9 on pp 15-2526 it says that a fauna inspection will be carried out in the construction area before any vegetation clearance and that any fauna located within the construction area shall be either relocated or dealt with in accordance with recommendations made by the qualified persons more information is needed eg a decision tree flowchart

Response A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water and DEH This knowledge has been considered by the Commonwealth It is acknowledged that more specific instructions on how this can be ac hieved will be inc luded in the Contrac tor s EMP The p rojec t will ensure tha t expert advice is available throughout the duration of the construction phase

25 Please re-consider 163 ESD whole approach The purpose of the weir is to protect water supplies not to prevent degradation

Response They have become one and the same over the life of the project To secure water quality is to secure supply The emergence of acid sulfate soil threats has presented us with a major risk for the water to become un-potable

The transitory effects of the temporary weir are far less than the long term effects of low freshwater flows

Principles of Ecologically Sustainable Development Guidelines Attachment 1 Part 3A

(a) The social and economic consequences of a city of 12 million not having a secure water supply are incalculable

(b) The threats of serious or irreversible environmental damage are discussed extensively in the EIS Whilst there is no full scientific certainty we are continuing to undertake extensive measurements modelling trials and emergency actions to minimise environmental degradation caused both by low freshwater inflows and the short term impact of the temporary weir

with the purpose of the weir in mind Not South Austra lia s

Supplementary EIS for the temporary weir near Pomanda Island -64shy

(c) Both the construction of the temporary weir if required and the actions being taken throughout the Ramsar site will benefit the present and future generations

(d) Whilst the purpose of the temporary weir is to protect water supplies we will take all reasonable steps to minimise any impact of the temporary weir on biological diversity and ecological integrity For example we are now proposing to include a fishway

(e) South Australia is a buyer in the water markets as required and supports the COAG initiatives to improve water markets and trade water information and research and an enhanced urban water reform framework We see no specific application of the ESD principles of improved valuation pricing and incentive mechanisms in the case of the temporary weir

26 If pumping to Lake Albert was not continued beyond June 2009 how would this affect the projections for impacts on the site (water levels the no flow period ASS exposure salinity levels)

Response On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009

The potential for acidification in Lake Alexandrina is based on worst-case scenario rainfall and inflows during 2009 South Australia receives most of its rainfall in winter and spring so the extent of inflows and how trigger points may be favorably impacted by improvements will not be known until later in 2009 Over winter and into 201011 there will be some recovery in the water level (as has occurred each winter over the last three years of minimum flows) above the critical acidification level due to reduced losses and local rainfall Once losses increase during the warmer months the water level would again fall without any additional inflows

As described in the draft EIS under worst case conditions and with continued pumping to Lake Albert it was projected that the water level in Lake Alexandrina will reach the critical acidification water level of -15 m AHD at the beginning of January 2010

However with 220 GL delivered to Lake Alexandrina during 200910 the water level could be maintained above trigger level for the remainder of the 200910 water year 170 GL of the 220 GL requirement is now being secured by no longer pumping to Lake Albert The remaining requirement of 50 GL has already been secured by South Australia through the purchase of temporary water during the 200809 water year

The South Australian Government has assessed the potential savings that could be made by the decision to cease pumping to Lake Albert and how these savings combined with other water sources may delay the need to construct the temporary weir The 170 GL which now will be retained in Lake Alexandrina each year must still flow past Wellington to ensure that the salinity at the major pumping station at Murray Bridge remains below 1400 EC and therefore cannot be retained up-stream of Murray Bridge and used for other purposes

In conjunction with the additional 50 GL already purchased by South Australia (making a total of 220 GL for the full year) this will delay reaching the critical acidification level in Lake Alexandrina until mid to late 2010 maintain lake salinities at lower levels during this period than would occur if water levels continued to fall and maintain lower ASS exposure during this period

Updated model projections for both water level and salinity in Lake Alexandrina are presented below

Supplementary EIS for the temporary weir near Pomanda Island -65shy

_

Lake Alexandrina Level Forecasting from 16 May 2009

-24

-23

-22

-21

-2

-19

-18

-17

-16

-15

-14

-13

-12

-11

-1

-09

-08

-07

-06

-05

-04

-03

-02

-01

0

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Wat

er L

evel

(m A

HD

)

Projected Level w ith Maximum Net Evaporation (1982) Conditions

Level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Level

Critical Acidif ication Level (-15m AHD)

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Losses Maxmimum Net Evaporation (1982) Conditions

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 and no irrigation in 200910)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD unless stated

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank filled to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -66-

_

Lake Alexandrina Salinity

Forecasting from 16 May 2009

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

11000

12000

13000

14000

15000

16000

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Sal

inity

(E

C)

Projected Salinity w ith Maximum Net Evaporation (1982) Conditions

Salinity w ith level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Salinity

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Salinity Salinity of Flow to SA varies from 200 to 350 EC (f low rate dependent)

Losses as stated

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 no irrigation 200910 onw ards)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank f illed to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -67-

Water supply

the weir is expec ted to have negligible effects on sa linity between Loc k 1 and Wellington

27 On pg 10-22 the EIS sta tes tha t then why is the weir needed to protect water

quality

Response The temporary weir will have minimal impact on water quality upstream of the temporary weir in terms of the inputs (particularly salinity) from upstream The primary purpose of the temporary weir is to prevent contaminated water from Lake Alexandrina being pushed into the River Murray channel upstream of Wellington through wind seiching Monitoring and modelling have demonstrated that even at the relatively low salinities in the lake currently incidents where water with a salinity in excess of the maximum target level of 1400 EC penetrates upstream to Tailem Bend may occur

28 Figure 1-3 (pg 1-4) shows a water level of -15m AHD (ie the critical acidification date) being reached in January 2009 What is the interaction between this and the proposed Clayton blocking bank which would bring the critical acidification date forward by at least 2 weeks into December 09

Response Pumping water to the Goolwa Channel will bring forward the time when the trigger water level of -15m AHD is reached by about 2 weeks however the critical acidification date will be delayed with the 220 GL delivered to Lake Alexandrina during 200910 (see response to question 26)

Should more than 896 GL year be ava ilab le [flowing ac ross the SA border] the potential effects of the proposed temporary weir are likely to be reduced in the Lower Lakes Does this mean that any water in excess of 896 GL will be allowed to flow into the lower lakes

29 On pg 10-7 it says tha t

Response Water allocated to South Australia in excess of 896 GL plus private and state carry-over will be allocated on a priority basis within the state Some of this may be allowed to flow to the Lower Lakes The application of any water in excess of 896 GL per year has not been determined and it is also dependent on the reason why there is exc ess wa ter For example unregula ted flows whic h a re flows tha t the MDBA is not able to capture a re likely to flow to the lakes while regula ted flows a re ava ilab le for allocation to support irrigation

30 The 201 GL critical human needs volume is based on level 5 water restrictions (pg 4-6) what is the plan for moving SA onto level 5 water restrictions considering only 896 GL is expected in 2009-10 (pg 1-3)

Response The total volume available to South Australia in 2008-09 is currently predicted to be at least 1140 GL Areas in South Australia reliant on River Murray water are currently on enhanced level 3 water restrictions The extra saving in moving to level 5 is 17 GL which is negligible in terms of the Lower Lakes

The Metropolitan Adelaide water supply is derived from two sources Inflows in the Mount Lofty Ranges during winter 2009 will impact on any decisions on water restrictions There is currently no plan to increase the restriction level from the current enhanced level 3 restrictions as the difference may be provided by additional MLR inflows

what is the increase in SA water use based on Population growth

31 Fig 2-2 on pg 2-5 shows 40 GL more being demanded than supplied by 2025

Response The 40 GL is the net effect of increasing demand further water conservation initiatives as described in the Water Proofing Adelaide strategy and reduction in available sources of water due to the impact of climate change

The weir is expec ted to a ffec t the amount of wa ter held between Lock 1 and Wellington and provide confidence that an extra [emphasis added ] 685 GL is ava ilab le for South Austra lians The 685 GL represents the amount of water needed to fill the weir pool from -15m AHD to +01m AHD but is not extra water that is available for extraction

32 On pg 10-32 the EIS says tha t

this needs to be clarified

Response Agreed The extra volume could only be available as a last resort and drawing down this weir pool would jeopardise water quality (salinity) as there would be no through flow to the Lower Lakes

Supplementary EIS for the temporary weir near Pomanda Island -68shy

33 On pg 2-2 the EIS states that roof run-off stormwater and recycled water are used for non-potable purposes how much Has this reduced reliance on Murray water Also mentions desalination plant will this reduce reliance on Murray water

Response Use of roof-runoff and stormwater particularly in the northern suburbs of Adelaide has provided additional water to reduce the demand on the traditional sources River Murray and the Mount Lofty Ranges Predominantly these have provided non-potable water for new development and as such are preventing increased demand from the traditional sources

It is clear that in critical periods of drought the 100 GL Adelaide desalination plant currently under construction will reduce reliance on the River Murray

While the desalination plant will reduce reliance on the River Murray this does not necessarily have a direct impact on the flow to South Australia required to maintain salinity at a satisfactory level (target lt1400EC at Murray Bridge) None of these nonshytraditional sources will remove reliance on the River Murray and it should be noted that a minimum flow to South Australia of about 900 GL per year is required to maintain salinity at Murray Bridge at less than 1400EC which is required for all potable use whatever the level of demand for Adelaide and regional South Australia

what is their estimated reduced reliance on Murray water Pg 4-17

34 Strategies 1 and 2 on pg 4-13 same question

Response Water conservation and recycling reduce the average water extracted from the River Murray and the recently released Water for Good plan quantifies this However in periods of extreme drought the same water savings are traditionally achieved through water restrictions and consequently these initiatives do not greatly reduce the need for River Murray water during critical periods

35 What is the safe operating height of SA Water pumping off-takes (pg 4-2)

Response Following modification to the pumps the safe operating level is currently -22m AHD Prior to the modifications the safe operating limit was around -04m AHD The estimates of the critical limits for the pumping stations have varied over time as the river level has dropped and the pumps could be tested outside of their normal operating ranges

36 If the pumps can pump down to -22m AHD then why is the weir pool at +01m AHD Does this factor in evaporation of the weir pool during times of low flow which would lower the water level Or is this considering the water quality of the lower lakes How can this be the case when the weir expected to have negligible effects on salinity between Lock 1 and Wellington

Response This level is set taking into account the requirements of the temporary weir during the recovery phase If Lake Alexandrina becomes saline the temporary weir needs to maintain a physical separation between the river and the lake as the lake level increases to allow the saline lake water to be flushed to sea

The level of 01m is a compromise While a higher level (up to 075m AHD or higher) would be preferred to facilitate flushing of lake water to the sea the foundation conditions for the temporary weir are not suitable for such a high weir if the lake levels continue to drop

c areful p lac ement remova l of embankment material

37 In Table 15-3 on pg 15-17 it says there will be what does this mean

Response Careful placement removal of the weir embankment material during constructionremoval will minimise both the area and quantity of disturbed bed material and hence minimise the immediate water quality impacts (mainly turbidity) and the inadvertent release of sulphuric acid from the sediments

38 SA has previously indicated it would legislate to ensure removal of the weir has this been done When will it be done

Response No The temporary weir will be removed when the decommissioning criteria (as agreed by the Water Security Council and accepted by the MDBA) are met

39 How will additional water secured through SA water security strategy and efficiency measures be managed ie will any be provided to Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -69-

Response See response to Q29

40 Are there any the implications of predicted future water demand in SA on the period of time that the weir is in place

Response This is not expected to be material during the expected life of the temporary weir

Predicted future demand for potable water for the major off-takes will have minimal impact on the time the temporary weir is needed The temporary weir is required to prevent saline or acid contaminated water from the Lower Lakes entering the river channel until such time as the quality in Lake Alexandrina no longer provides a threat to these water supplies whatever the demand

41 Will salinity increase behind the weir in the weir pool Given that saline water sinks the water overtopping the weir may potentially be fresher water Will salinity levels in the weir pool build up to a point where it might impact on the offtakes

Response Large quantities of salt flow down the River Murray every day but it is largely mixed and therefore will not separate and sink Therefore salinity levels in the pool between Lock 1 and the temporary weir are not expected to impact on the offtakes (Note that there are saline groundwater inflows to the river which can cause localised pockets of salinity but this occurs in normal river operation and is independent of the construction of a temporary weir These pockets of high salinity eventually mix and the salt is carried away in the general water body)

In the absence of a temporary weir when more saline water from the lakes is forced under wind seiche into the river it does sink to the bottom rather than mix with the less saline river water and the saline water then moves upstream This is exacerbated by the differing depths of the water at Pomanda Island and in the river channel upstream of Wellington

Modelling indicates an initial rise in upstream salinity during the weir filling period and then after that no major change in the long-term Provided there is no significant input of highly saline water from Lake Alexandrina (the purpose of the temporary weir is to stop this) the salinity gradients generated by evapoconcentration of the relatively low salinity river water will not be sufficient to resist the natural mixing as temperatures and wind conditions change This has been demonstrated by the natural break-up of the saline intrusions on the bottom of the river due to inflows from Lake Alexandrina which have been identified through monitoring over the past year

42 Can SA provide the modelling on the 696GL scenarios with and without the weir on water levels the no flow period ASS exposure

Response Refer to the response to Q9

The flow scenario proposed is unrealistic as South Australia is guaranteed a minimum flow of over 896 GL in 2009-10 (including the reserve for Critical Human Needs and private carry-over) Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream

The requested modelling results will be provided but should not be taken as representative of any realistic scenario

Removal triggers (pg 1-6)

norma l opera ting levels in rela tion to Hume and Dartmouth and what period of time these levels have to be sustained for

43 No definition of

Response The MDBA states that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

44 How long to fill Hume and Dartmouth Dams and how likely is this What is the worst case scenario Best case Is the filling and operation of these dams likely to be impacted by MDBstate water management

Response It is not possible to predict how long filling these storages to this level may take Hume storage in partic ula r is quite vola tile and c ould easily fill and spill within less than one year Dartmouth storage is more likely to take longer but the average end of season

Supplementary EIS for the temporary weir near Pomanda Island -70-

level is commensurately lower Under continuing worst case conditions the storages will not reach these trigger levels

The filling of these storages could be affected by decisions by all jurisdictions regarding the management of the Murray-Darling Basin including future sharing and reserve arrangements

45 Why was this trigger chosen rather than one focussed around water made available to South Australia from shared River Murray water or based on discontinuationreduction of dry-inflow contingency

Response These triggers were determined because they are open and transparent They are based on the best available technical advice

The triggers were agreed by the Water Security Council and accepted by the MDBA

need to meet a ll triggers Can SA provide any indication about the likely timeframe in which all triggers would be met

46 The timeframes on the removal triggers are unclear

Response Removal triggers are directly related to the drought and how much water is expected to become available It is not known when these triggers will be met

The MDBA notes that the specific timing of removal is highly dependant on the seasonal conditions at the time Lake Alexandrina next fills above +01 m AHD

no water quality impacts from Lakes water quality in the lakes is unlikely to improve with the weir in place so how realistic is this as a removal trigger If it is decided that seawater needs to be introduced to manage ASS this is likely to delay removal of the weir given the inability to meet this trigger

47 Regarding the 3rd removal trigger

Response Water quality in the lakes is unlikely to improve until additional fresh water flows down the river and either dilutes the lake water or flushes it to the sea If inflows to the lakes over the temporary weir exceed evaporation the water quality will begin to improve through dilution Major improvement in quality will not occur until there is a discharge of water from the barrages which cannot occur until the water level is restored to at least +05m AHD The critical salinity level in the lakes has been calculated at 3000 EC If inflows are predicted to reduce the lake salinity to less than this value the potential impact of lake water on major water supply offtakes is considered acceptable If seawater has been introduced to prevent acidification the volume required to dilute discharge salt to the extent that this target of lt3000EC can be met will be greater than if no seawater has been introduced However the volume of inflows required to improve lake water quality to an acceptable level if the lake has been allowed to acidify is likely to be even greater

This trigger has been purposely expressed as water quality rather than salinity because no decision has been made on whether seawater is to be used to manage acid sulphate soils (EPBC Reference 20084618) or whether an alternative strategy is to be adopted

If seawater is not introduced acidification may introduce a number of other water quality issues that need to be resolved before the temporary weir can be removed

48 In relation to the salinity trigger how much water is required to flow in to reduce salinity levels to below triggers stated What is the likely timeframe on getting this volume

Response The volume of water required to dilute salinity in Lake Alexandrina to meet the removal trigger will depend on the quality of water remaining in the lake and when the dilution occurs At the time of closure of the temporary weir it is predicted that the salinity in Lake Alexandrina will be approaching 10000EC Salinity will increase to about 28000EC within 12 months due to river inflows and evapo-concentration and will be significantly higher if seawater is introduced

Figure 211 in the Draft EIS shows how salinity in Lake Alexandrina continues to rise with continued low inflows The volume of fresh water eventually needed to reduce the lake water below the trigger level depends on how long the drought continues Typically the salinity of water in Lake Alexandrina will be diluted by 30 just by re-filling the lakes to 01m AHD

49 If the Australian Drinking Water Guidelines (2004) say that 275 to 550 EC is the acceptable salinity of drinking water (pg 10-4) then why is the removal trigger set at 3000 EC

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Response The desirab le sa linity ta rget for d rinking wa ter supp lies in South Austra lia has been identified as 800 EC based on AWRC and WHO guidelines Many supplies do not always meet this desirable limit The removal trigger for salinity in the lakes has been set at 3000 EC higher than the maximum limit set for Tailem Bend (1400 EC) and much higher than the desirable limit for drinking water of 800 EC because based on experience and from the modelling results the risk of water from Lake Alexandrina raising the salinity at the major water supply off-takes above the maximum target level of 1400 EC is acceptable

50 No definition of what the water quality risks are and how these would be measured

Response Refer to response to Q47

The primary water quality risk is salinity and this is dealt with comprehensively throughout the document Additional water quality risks arise from water moving upstream for Lake Alexandrina if the lake has acidified (heavy metals metalloids nutrients) These risks are closely monitored through existing water quality sampling programs associated with a major public water supply Algal blooms (potentially toxic cyanobacterial in particular) present an additional water quality risk that is addressed in the Supplementary EIS The presence of algae is monitored closely through a program established when lake and river water levels started to decline This program which is in addition to the normal sampling for public water supply purposes includes regular airborne videography and infrared photography with immediate ground truthing of any sites identified through the aerial survey work

It is not possible to quantify all of the water quality risks unless the management strategy for ASS is known in particular whether a preventive approach using seawater is to be used or a remediation approach The full impacts of these options are currently being investigated for the EIS to allow seawater into the Lakes

51 Fourth removal trigger is subjective what does this mean in practice Confidence is immeasurable this alleged removal trigger is more on outcome of the other removal triggers being met than a trigger in itself

Response The confidence required is in the consistency and robustness of River Murray water resource projections in relation to being certain we will not return to a similar situation of extreme low water levels as we are currently experiencing in the near future which may require re-instatement of the temporary weir

To some extent the comment that this trigger is an outcome of the first 3 triggers is correct However this trigger is intended to allow for the considerable uncertainty around the management regime for ASS and changes to operating rules in the MDB

52 58 states that once the water level exceeds +01m AHD the weir will cease to serve any useful function How will the structure of the weir albeit below water level change flow rates past the submerged weir

Response The temporary weir will have very limited impact on flows once water levels return to greater than +01m AHD in the lakes When the water level exceeds 01m AHD the temporary weir becomes drowned but it still provides a (partial) barrier to saline river water moving upstream

The submerged weir will still allow the prevailing flow to pass Should flow rates exceed the design of the temporary weir action would be taken to widen the flow path

Additional modelling will be undertaken to identify any backwater impacts from high flows in a situation where the temporary weir has not been removed (eg 50 000 MLday) The presence of the temporary weir would still provide some benefit in restricting any saline flows from Lake Alexandrina in to the River Murray channel even if the temporary weir was d rowned

Wetlands

53 In section 1246 on pg 12-11 under the head ing Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion is c onsidered insignific ant as many of these species reproduce sexually and wind or bird-d riven seed d ispersa l This is only a consideration of impacts upon reproduction not a consideration of whether the plants will even survive to reproduce

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Response Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately 035 m AHD At a water level of -15 m AHD this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the waterbody and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the lake be refilled with fresh water to its pre-drought level (05 to 08 m AHD) while the below-ground storage organs remain viable

54 In Table 12-3 on pg 12-6 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type O it says that the slightly quicker decrease in water levels as a result of the weir is expected to bring forward the exposure of some sediment (including acid sulphate soils) that would otherwise have been exposed within 9 months how much acid sulphate soils Is this the 5200 ha mentioned on pg 11-7

Response Yes it is 5200 ha and this is reiterated in the Supplementary EIS As discussed in the Supplementary EIS the reduction of flow during the filling of the weir pool reduces the volume of water such that a further 5200 ha of sulfidic soils is exposed in Lake Alexandrina This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage acid sulfate soils will need to be implemented across the Lake in this case

55 In Table 12-3 on pg 12-8 for wetland type XI how can there be no recorded change at shy05m AHD but complete disconnection at -15m AHD

Response Presumably the comment refers to wetland type Xf not wetland type XI In Table 12-3 for wetland type Xf under Existing c ond ition (app roximately -05 m AHD) rep lac e No rec orded c hange with Not c onnec ted to the ma in body of the lake Will only be a ffec ted by ongoing d rought

Covered in Supplementary EIS

56 In Table 12-3 on pg 12-8 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type 4 the EIS says the weir is not expec ted to further impac t the management of seasonally flooded agricultural land when are they seasonally flooded Are the 25-3 months following weir closure going to prevent this seasonal inundation

Response In Table 12-3 for wetland type 4 under Impac t of p roposed temporary weir within Ramsar wetlands to existing text add whic h oc c urs a t wa ter levels gt 087 m AHD At the trigger level for weir construction (-15 m AHD) water levels will be 237 m below those that lead to inundation of surrounding agricultural land With or without the temporary weir in place water levels will remain well below 087 m AHD for the 25 3 month period following weir construction if it proceeds

Covered in Supplementary EIS

57 In Table 15-1 on pg 15-2 in the row on acid sulphate soils the EIS says that contingency measures may be c onsidered if a lka linity dec lined to a spec ified level what is this level How and where will this be measured What contingency measures would be implemented

Response Table 15-1 refers to Table 15-6 Potential mitigation measures to manage acid sulfate soils which contains the levels (100 and 25 mgL as CaCO3) In Table 15-6 for dot point 2 it c ould be c hanged to If a lka linity c onc entra tions dec line to 25 mgL as CaCO3 then immediate mitigation measures such as limestone slurry dosing are expec ted to be undertaken

Since August 2008 the SA MDB NRM Board has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (eg sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC

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It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (report 1 March 2009) The EPA also compiles the raw data in a spreadsheet available to South Australian government agencies

58 How will the Wetland Management Plan (Table 15-3 pg 15-17) manage the change in flow patterns Does have any suggestions on how to mitigate the impacts of the no-flow periodfirst year reduced flows period

Response Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

59 In Table 15-3 on pg 15-18 it mentions several potential water quality protection measures including use of a turbidity curtain stabilisation of river banks etc Under what conditions would each of these measures be implemented Same for contingency measures for acid sulphate soils outlined in Table 15-6 on pg 15-20

Response The EPA has pointed out that the EMP scope should include monitoring and managing turbidity impacts during construction and any EMP should be approved by relevant authorities including the EPA prior to any works being carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) which contains the overarching EMP SA Water and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Table 15-3 has been amended

60 Will there be any interactions with other referrals Will the presence of the weir impact on the Goolwa Channel referral

Response The temporary weir is part of a planned progressive response by the South Australian Government to worsening conditions in the Lower Murray in South Australia This Cabinet approved response plan is based on water levels in the barrages weir pool The critical trigger for the temporary weir is -15m AHD The trigger for the project to pump water to Lake Albert was -05m AHD and the trigger for the proposed Goolwa Channel Water Level Management Project is -12m AHD These actions are all linked as part of the overall response strategy The presence of the proposed temporary weir will not impact on the Goolwa Channel project as the latter project will be constructed well prior to the proposed temporary weir near Pomanda Island

61 It is likely that the presence of the weir may adversely impact on the recovery and management of the ecological character of the and therefore in the implementation of the long term plan for the site Does SA have any suggestions about how this will be managedmitigated

Response The temporary weir will not adversely impact on the recovery and management of the ecological character and will assist in preserving the range of options that can be considered under the long-term management strategy If the temporary weir is not constructed and the area acidifies or a greater volume of seawater is required to prevent this the detrimental impacts on the long-term plan will be greater

62 Page 10-25 will SA be purchasing water to ensure that the hydrological disconnection associated with the filling of the weir pool is reduced from 3 to 1month Please provide details under what circumstances would this occur

Response The South Australian Government is committed to pursuing a fresh water solution for the Lower Lakes including the purchase of water from the market However

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no commitment of additional water to the Lower Lakes can be made until the winter 2009 inflows are known

Re-wetting of upstream wetlands

63 Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

THIS SECTION DOES NOT EXIST and they do not appear to be described elsewhere (pg 10-10 also mentions likely changes to groundwater interactions and the re-wetting of dried sulfidic sediments and the associated ecological effects that would result and refers to Ch 15 for management tha t s in p lac e) mitiga tion measures mentioned aga in on pg 11-9 but no details

Response The reference to section 1554 should read 15412 and has been corrected in the Errata to the Supplementary EIS Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant Further details are provided in the response to question 64 in regards to ASS mitigation and management of wetlands above Pomanda Island All appropriate approvals for structures will be sought through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project

64 As the weir pool fills and upstream wetlands are re-wetted there exists a real potential for the introduction of low pH water with high metal concentrations into the River Murray (pg 11-8)

Response Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on potential impact refilling wetlands will have on water quality of the Main River Channel and ecological impact of further acidification of wetlands

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the MDBC Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from DEH project identifying acidification remediation options for the Lower Lakes Construction of structures and other on-ground works for remediation at priority wetlands and Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRM Board is managing the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project with a steering committee comprising of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRM Board DEH DWLBC MDBA SA Water EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of 01m AHD CSIRO have undertaken a preliminary assessment of the ASS hazard for each of the 75 wetlands An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of each wetland will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and

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ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island eg wetlands providing important aquatic refuges

65 Which wetlands will be re-wetted What are their sizes water levels condition etc

Response Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at +01m AHD The Table below provides information of the c ommenc e to fill level surfac e a reas and ASS management assessment for eac h of the 25 wetlands

NAME

SA (ha) at pool (~075m AHD)

SA (ha) at 02m AHD

commence to fill m AHD

Require ASS management

Riverglades 446 196 -051 Yes

Wellington Marina lt 191 lt 191 lt -080 Needs reassessment

Saltbush Flat 855 88 -025 No

Teal Flat Hut 202 15 -019 Yes

Walker Flat South Lagoon 888 601 -010 Yes

Wellington North (Murrundi) 9 32 -010 Yes Lake Carlet 3457 2998 -065 Yes

Devon Downs North 2627 822 -040 Yes Lake Bywaters 388 321 -017 No Marks Landing 1929 1453 -060 No

Coolcha Lagoon 1284 436 -045 Yes

Tailem Bend 957 811 -057 Yes

Younghusband 223 23 -010 Yes Younghusband West 1089 887 -062 Yes Caurnamont 903 464 -021 No Craignook 369 208 -002 Yes

Forster Lagoon 80 641 -022 No Henley Park 224 177 -027 No Bow Hill 475 140 -033 No Mannum Swamps 1977 1450 -035 Yes Mason Rock 258 91 -046 Yes Reedy Creek 986 436 -004 Yes Priess Landing 5 29 -069 No

Teal Flat 82 476 -011 No

Wongulla Lagoon 124 365 -046 No

Total 24449 13161

66 In the final paragraph on pg 12-16 the EIS says that re-wetting could potentially cause water in these wetlands to become acidic (if acid sulphate soils are re-wetted) which c ould c ause the following ac id ity would then remob ilise meta ls c onta ined within the sediments causing disease or death in fish due to metal toxicity Should this be experienced management measures identified in Chapter 15 will need to be undertaken What a re the management measures How will SA know if this has occurred (ie monitoring)

Response Refer to response in Ref 64 in regards to management of potential risk of ASS in wetlands inundated at 01m AHD The Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project incorporates the development of a monitoring program to assess the success of the ASS mitigation strategies and ecological impacts This will include the monitoring of water quality metals biota such as fish groundwater and vegetation

67 What will be the objectives of the management plan for re-wetting exposed acid sulphate soils How will it achieve these objectives (Table 15-6 pg 15-21)

Response The objectives of the management plan for re-wetting exposed acid sulphate soils are

To mitigate the risks of acid and metal mobilisation to the main River channel water quality and biota of the River Murray and associated wetlands

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Mitigate the risk of acid and metal mobilisation within the wetlands above Lock 1 when they are refilled and Ensure the development of ASS mitigation methods incorporate the environmental values of each of the wetlands

The objectives will be achieved through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project which will develop site-by-site management options for ASS hazards The risk assessment has been undertaken which has identified 14 wetlands that require management of ASS hazard Management options are currently being developed and may include regulating structures and other methods such as neutralising agents mulching and revegetation with the aim of ameliorating the risk to the main River channel due to the rewetting ASS hazard wetlands

68 Will the rewetting strategy for ASS areas in the weir pool affect the time it takes to fill the weir pool and therefore prolong the period of no flow to Lake Alex

Response The refill volumes for each of the 25 wetlands that will be inundated at 01m AHD with the construction of a temporary weir near Pomanda Island are currently being calculated using modelling and survey work It expected that the total volume of water required to refill these wetlands will be insignificant in relation to the volume of water required to fill the River channel and would not prolong the period of no flow to Lake Alexandrina

With only 3 of the 75 wetlands in this reach currently wet due to the low River levels it is important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island The re-wetted wetlands will provide important aquatic refuges and breeding opportunities for biota

Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

Threatened and migratory species

69 On pg 13-13 the EIS says The lac k of c onnec tivity [ie as a result of the weir b loc king migration] is expected to also hinder gene flow between populations potentially leading to a decrease in diversity in both Murray Cod and Murray Hardyhead populations if it c ontinues for a suffic ient period What would be a suffic ient period in this c ase Would three years (the design life of the weir) be a sufficient period Obviously for Murray Hardyhead even one year of interrupted reproduction could be significant as the species only lives for 2 years (pg 13-14)

Response A fishway to suit large and small species will be included in the weir design and design is currently underway

70 At what water level will the Swamps of the Fleurieu Peninsula disconnect from the main body of Lake Alexandrina (as per pg 13-4)

See page 32 of the supplementary EIS under the heading Impacts upon tributary wetlands

71 Lack of detail in section on Orange-bellied Parrot (pg 13-8) to exactly where will vehicle movement be spatially restricted How will the creation of new tracks be limited What vegetation will be cleared and how much

Response Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coor ong_Survey_lowpdf

In order to gauge the potential impact of the construction of the temporary weir on local biodiversity a thorough ecological survey of the immediate area in Spring 2009 is

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desirable Survey results can then inform relevant mitigation strategies to be included in the EMP

Construction activities on (Pomanda Island) will be restricted to along the northern edge of the island and locally around the abutment It is expected that the temporary weir will cause a minor loss of some of the reed beds along the western access road to the construction site due to the need to construct a wider road for truck traffic The construction footprint will be minimised as far as practically possible by minimising the road width and avoiding the reed beds where practically possible Construction activities on the eastern side will be localised to the immediate area around the abutment The landscape on the Eastern side is characterised by farmed paddocks Hence no reeds (and no habitat of the Orange bellied Parrot) are expected to be impacted on the Eastern side

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

72 In Section 1352 on pg 13-9 rela ting to the Southern Bell Frog it doesn t mention tha t the frogs have been found at Pelican Lagoon (pg 7-24) the section goes on to mention that the site at which the southern bell frog was recently recorded is expected to be disconnected from the water when Will the regulated pumping system continue to operate

Response The main body of Pelican Lagoon where Southern Bell Frogs (SBF) have previously been recorded (River Murray Wetlands Baseline Survey 2005) has been dry since 2007 It is unknown as to whether SBFs are still located in the dredged area closest to the river It is expected that this dredged area will remain inundated at +01m AHD but the rest of the wetland will remain dry

73 Where is the previously occupied southern bell frog habitat near Wellington How will the raised water level help frogs to recolonise this habitat (pg 13-10)

Response The previously occupied site for the Southern Bell Frog near Wellington is called Ferry Crossing (Coordinates139386 -35337) The recording was in the 2000 frog census on 15 September 2000 numbers were identified as few The only other areas where they have previously been recorded within the Lower Lakes are at Tolderol Game Reserve and Clayton (Dunn Lagoon) These sites are to the West of Wellington on the shores of Lake Alexandrina

The raised water level of the weir pool will re-hydrate the wetland and provide re connection with the main river channel This in turn enables the re-establishment of emergent and submergent vegetation within the wetland providing suitable habitat for the species to colonise and reproduce Reproduction requires still or slow moving water (Australian Government 2009)

Australian Government 2009 Significant Impact Guidelines for the vulnerable growling grass frog (Litoria raniformis) EPBC Act Policy Statement 314

74 An Environmental Management Plan is proposed as mitigation to the likely impact of disruption to Southern Bell Frog tadpole migration (Table 16-1 pg 16-3) how will the EMP mitigate this impact Need more information on the potential for the weir to disrupt the dispersal and migration of southern bell frog tadpoles (pg 13-10)

Response This response takes into consideration the history of inter-governmental documentation on this point in relation to the proposed Pomanda Island Temporary Weir and a lso the Dra ft EPBC Ac t Polic y Sta tement 314 Signific ant impac t Guidelines for the vulnerable growling grass frog (Litoria raniformis) [= southern bell frog] (Feb 2009)

Environmental conditions habitat and breeding

The preferred habitat for breeding of the southern bell frog is high emergent vegetation cover (eg Phragmites and Typha) and still or slowly-moving water (Stratman 2007 DEH 2009) Current conditions in the Lower Lakes region are poor and breeding is unlikely to be occurring in the region at the moment It is unlikely that breeding will occur immediately downstream of the temporary weir in the short-term Immediately upstream of the temporary weir it is likely that habitat conditions will be maintainedenhanced (see also page 30 of this document)

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Migration of southern bell frog

It is now considered that the original comment in the draft EIS of The likely impacts on this species are confined to possible Interruption to dispersal and migration of tadpoles Additional pressures resulting from the construction and operation of the temporary weir include short term changed water regimes water chemistry and localized noise As no individuals have been recently recorded at the proposed site these local disturbances are not expected to impact the population was incorrect in its reference to tadpoles The adults of the species are highly mobile (movement of up to 212 m in a single night has been recorded referred to in Schultz 2008) Less is known about the mobility of tadpoles Tadpoles may be involuntarily swept over the temporary weir during significant flow events The top height of the proposed temporary weir is lower than the normal operational sill level at the Goolwa barrages so the structure will only present a barrier to dispersal of the Southern Bell Frog during unfavourable conditions such as those that have prevailed for the last 18 months

Since adult frogs are highly mobile the causeway and abutments associated with the temporary weir may impact on the movement of adults along the banks of the river corridor Experimental developments in Victoria have used culverts or pipes placed beneath roads as corridors to try to link populations however Bell Frogs have not been observed using them to date (G Heard personal communication)

Survey

The SAMDB NRMB advised that a targeted frog survey was needed to determine whether Southern Bell Frogs still remain in the vicinity of Pelican Lagoon prior to the development of the Environmental Management Plan

DEH undertook a habitat preference survey during March 2009 and a follow-up survey is planned for Spring and Summer 2009 to assess population numbers The rapid assessment of suitable habitat for the Southern Bell Frog (March 2009) was conducted around the perimeter of Lake Alexandrina and Lake Albert with survey sites stretching along the edge of Lake Alexandrina from Milang to Wellington then Wellington to Meningie along Lake Albert around to Narrung The result of this habitat assessment is a proposed targeted species survey in line with the original project objectives

As indicated in Figure 7-4 of the Draft EIS L raniformis has been detected at wetland habitats around Lake Alexandrina and in the lower reaches of the Murray River upstream of the lake including locations near Narrung Point Malcolm Wellington and around Milang Most of the sites based on habitat mapping undertaken by DEH are characterised by permanent water and to some extent reedbeds

Mitigation

The comment on mitigation that was included in the draft EIS is relevant

All construction operation and decommissioning activities are expected to be done in accordance with an Environmental Management Plan A survey for this species is expec ted to be c onduc ted in 2009 to better understand the p resent d istribution The initial assessment to indicate likely target sites (preferred habitat survey) has now been completed and the follow-up survey is planned for spring summer later in 2009

75 On pg 13-11 the EIS says that the Yarra Pygmy Perch are more commonly found in the well-vegetated lake margins and the channels of Hindmarsh Island and the lower ranges of the eastern Mt Lofty Ranges tributaries but that these areas are currently disconnected from the main body of Lake Alexandrina (also on pg 14-1) When did the channels of Hindmarsh Island disconnect Yet it is stated in the EIS the eastern Mt Lofty Ranges tributaries (Currency and Finniss) a ren t expec ted to be d isc onnec ted until lake levels drop to -12m AHD (pg 10-1) do you mean Angas and Bremer

Response refer to the discussion on page 23 of the supplementary EIS regarding Connectivity of Surface and Ground Waters

76 Why do PIRSA Fisheries have a policy of not re-stocking fish species (pg 13-14) and what is different about these circumstances that would mean it is now a suitable option

Response PIRSA Fisheries advises that in the absence of a fishway stocking of fish to increase populations in a degraded habitat is unlikely to result in a net increase in the population However as the water is pooled upstream of the new temporary weir there could be some limited restocking as the environment improves to allay any concerns

Supplementary EIS for the temporary weir near Pomanda Island -79-

that cod populations have suffered from the weir works The PIRSA website has a policy paper4 which explains why large scale restocking is not supported (there are implications of spreading diseases in wild populations from those that have been housed in aquariumsgrown in aquaculture there is also the risk of limiting genetic diversity if stock have been bred from only a few source fish and a series of other issues)

In regards to the broader issue of re-stocking native fish species within the site that have been lost to the freshwater environment due to their complete disconnected from the lake re-stocking before recovery of the ecosystem is not appropriate Upon recovery of the ecosystem and re-establishment of an appropriate freshwater ecosystem these species will either re-colonise from elsewhere or if only located regionally re-introduced via a stocking program An existing program is in place whereby populations are being bred in captivity to allow later re-introduction in the future of EPBC listed (Yarra pygmy perch and Murray hardyhead) and regionally significant species (Southern pygmy perch River Blackfish and Southern Purple-spotted gudgeon) We are presently in the situation where for some species (those listed above) there are no remaining genetically-distinct populations remaining in-situ so the only option is to reintroduce those held in captivity if we want the population to persist Murray cod are believed to be a single genetic unit across South Australia and hence re-population from upstream populations should enable recovery This could be supplemented by a breeding program but would be subject to a complete collapse of the SA South Australian population and approval from PIRSA as would the re-introduction of other species presently held in captivity and would be subject to specific testing and satisfaction of relevant conditions

In addition to these potential activities a fishway is now being included in the design for the temporary weir to enable the egress of species from the lake environment into the river channel above Wellington

77 What is the evidence that Murray Cod and Murray Hardyhead are able to withstand high turbidity conditions (pg 13-15)

Response No data on the tolerances of Murray Cod and Murray Hardyhead to high turbidity conditions are available Evidence on tolerance to relatively high turbidity is correlative Both of these species are distributed across lower regions of the Murray-Darling Basin in areas subject to relatively high turbidity Turbidity in the River Murray in South Australia is highly variable and largely influenced by discharges from the clay-laden Darling River (Woodyer 1978) Turbidity at Morgan averaged 516 NTU between 1994 and 2004 with peaks as high as 304 NTU (Westwood and Ganf 2004) Turbidity in Lake Alexandrina is also highly variable with mean values between 1975 and 1978 varying from a high of 93 NTU to a low of 9 NTU with localised values as high as 150 NTU recorded (Geddes 1988)

78 What would the parameters be for reintroduction of Yarra Pygmy Perch andor Murray Hardyhead (pg 13-16)

Response The reintroduction of the Yarra Pygmy Perch and the Murray Hardyhead would be undertaken once the habitat has been rehydrated and the keys components to their survival are in place such as

There is a level of confidence inflows into South Australia will be able to sustain the habitat at least in the medium term Habitat structure has recovered (eg aquatic plants) sufficiently to provide for o Spawning o Shelter o Food source and o Predation avoidance Water quality parameters are within tolerances (specified in the draft EIS) of each species such as o Salinity o pH o Dissolved oxygen o Water temperature o Turbidity and o Concentrations of contaminants particularly Aluminium

4 httpwwwpirsagovau__dataassetspdf_file000950895Stock_enhancement_policy_Aug_07pdf

Supplementary EIS for the temporary weir near Pomanda Island -80-

For Murray Hardyhead the following ranges of parameters have been utilised for reintroduction at a Lower Lakes site

EC 2000 30000 EC

DO gt50 mgL (ANZECC WQ Guidelines)

Turbidity 2-200 ntu (ANZECC WQ Guidelines)

84PH 70

Yarra Pygmy Perch would have similar parameters but with a much lower salinity range

79 On Pg 14-7 it says that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB what noise levels will construction create

Response At this stage it is difficult to predict what the average noise level might be Presumably levels will fluctuate and for short periods of time the 56db level may be exceeded Important also in the equation is the distance of the waterbirds from the noise source If the equipment levels a re say 85dB(A) then they ll d rop to 45db (A) within 100m

There are no wetlands on the eastern side near the abutment We expect any areas around Low Point populated by birds to receive noise levels similar to that from a busy highway This same comment will apply for the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels so it is assumed they would occur further north into the wetland area

Monitoring of EPBC-listed species throughout the project is expected to occur to ensure construction operation and decommissioning activities do not impact on EPBC-listed spec ies how will monitoring ensure this This can only work if particular contingency measures are undertaken if a particular measure is observed during monitoring

80 On pg 15-24 it says tha t

Response Monitoring during operation of the weir Monitoring efforts will be coordinated as part of the SA MDB NRMB s na tura l resourc e c ond ition monitoring program It will include additional monitoring efforts as per expert advice

Monitoring during the construction and decommissioning of the weir It is recognised that the monitoring of the EPBC listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life breeding cycles The monitoring focus will be of an observational nature mainly in regards to compliance monitoring to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by Commonwealth and NVC) and the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora amp fauna expert advic e if warranted In add ition the Contrac tor s EMP will identify based on a risk assessment which specific mitigation and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations is recorded

Fishway

81 One of SA s river hea lth ob jec tives under the River Murray Ac t is Barriers to the migra tion of native species within the River Murray system are to be avoided or overc ome (pg 3shy36) The weir would obviously impede the migration of native species without appropriate measures eg fishways

Response As explained in the Supplementary EIS a fishway is now included in the design for the temporary weir SARDI have indicated that they have sufficient knowledge to be able to design a fishway without the need for further site survey work

82 On pg 5-5 the EIS says that no provision is necessary for fish passage

Response See response to 81

83 The weir may impede upstream movement of juvenile and adult (spawning) Murray Cod and would possibly affect the downstream drift of larvae into if lake if spawning in the

Supplementary EIS for the temporary weir near Pomanda Island -81-

river was to occur (pg 7-29) possibility of fishway to allow larvae movement or other mitigation measures

Response See response to 81

84 On pg 13-12 the EIS says that the weir is expected to limit migration abilities

Response See response to 81

85 Why wouldn t Murray Cod use the fishway (Tab le 15-9 pp 15-2526)

Response Due to concerns about the lack of a fishway a design process has been initiated with the assistance of consultants to determine a suitable design concept that would allow passage of both NES and other fish species A concept design is expected to be available in July 2009 The inclusion of a fishway has a number of challenges not the least of which is the initial desire of the fish specialists to pass all the normal flow of approx 1 GLday through the fishway rather than over the spillway

86 Construction of the weir embankment begins when water levels in Lake Alexandrina are between -05m and -10m AHD (pg 5-11) however on pg 12-17 it says construction is preposed to commence when lake levels are at -11m AHD which will occur in October 2009 according to Figure 1-3 and then in Table 16-1 on pg 16-2 it says that construction is proposed to commence at 9 months before Lake Alexandrina is predicted to reach shy15m AHD

Response We will commence work at the latest date regardless of the water level that will allow closure of the river by the required deadline date It is expected to take approx 9 months from the award of contract to closure of the river but the weir construction will not be completed until a number of months after the closure date

87 2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Response South Australia is guaranteed 896 GL of dilution and loss flow plus 201 GL of Critical Human Needs reserved from 2008-09 The figure of 940 GL was a possibility in December 2008 but should not be used

The graphs provided clearly state 896 GL flow for 2009-2010

88 A dilution flow of 696 GL per year is available to SA which is used to maintain salinity levels at Murray Bridge below 1400 EC (pg 2-13) however on pg 4-5 it says than 200 GL in addition to the 696 GL is needed to maintain the salinity at this level at Murray Bridge on pg 10-7 it says that 695 GL is the dilution flow

Response The dilution and loss component of Entitlement Flow guaranteed to South Australia under the Murray-Darling Basin Agreement is 696 GL per year This does not meet the normal system losses within South Australia (average about 1130 GL per year) and this flow does not dilute salinity sufficiently to maintain lt1400EC at Murray Bridge Modelling has shown that an additional 200 GL is required to maintain salinity at Murray Bridge at lt 1400 EC (ie a total flow of 896 GL)

As stated in the response to question 9 South Australia is now guaranteed a flow of at least 896GL during 2009-10 The 896 GL includes 201 GL extracted for Critical Human Needs

Note that the 201 GL for Critical Human Needs serves a dual purpose in that it also contributes to the dilution of the salt loads as well as being extracted mainly in the lower reaches of the river for use in the potable water supply system

89 The text on pg 2-15 says that it is predicted that by May 2009 salinity in Lake Alexandrina will be about 7260 EC however Fig 2-11 on the same page and Fig 1-4 on pg 1-4 show that salinity is predicted to reach only just over 6000 EC by May 2009

Response Both graphs are the same and by May 2009 it was projected that the salinity would be around 6000 EC Current salinities indicate that this projection will be accurate The figure of 7260 EC on page 2-15 is incorrect and is corrected in the Errata

90 It would require 220 GL in 200910 and 365 GL in 201011 to maintain the lakes at 10cm above the critical acidification level [ie maintain the lakes at 1-4m AHD (sic)] however it is unclear if this means water flowing over the weir or additional water purchased from upstream (pp 4-78)

Supplementary EIS for the temporary weir near Pomanda Island -82-

Response South Australia is committed to providing a minimum River Murray flow of 350 GL per annum to Lake Alexandrina via Wellington This minimum flow is required to maintain potable water quality (salinity not exceeding 1400 EC) at the SA Water Corporation major pumping station at Murray Bridge

The cessation of pumping from Lake Alexandrina to Lake Albert preserves approximately 170 GL per annum in Lake Alexandrina and reduces the additional water requirement for 200910 from 220 to 50 GL and the requirement for 201011 and subsequent years to 195 GL per annum The 170 GL annual savings is a subset of the 350 GL annual commitment

The additional 50 GL (200910) and 195 GL (201011) requirements are over and above the 350 GL commitment and could be sourced from improvements in River Murray flows improvements in eastern Mount Lofty ranges tributary flows better than worst-case rainfall directly over Lake Alexandrina (Lake Albert is now under alternative management) better than worse case evaporative losses and purchases from intra and interstate

91 In 2007-08 SA was supplied 1564 GL of water and the River Murray supplied 95 of this (Table 1-1 pg 1-2 2) however on pg 2-4 it says that in 2007-08 SA Water provided SA with over 176 GL of water 95 of this was sourced from the Murray

Response Table 11 may be poorly labelled The figure of 1564 GL in 2007-08 is the demand from the Metropolitan Adelaide Water Supply System It includes water pumped through the Mannum Adelaide pipeline system and the Murray Bridge Onkaparinga pipeline system so therefore covers Adelaide plus the surrounding areas supplied from these pipelines The 176 GL figure in 2007-08 represents the above demand plus the usage from the other two major pipeline areas supplied from below Lock 1 (ie Swan Reach amp Tailem Bend)

92 On pg 2-12 the EIS says that in 2006-07 SA Water provided SA with just over 245 GL of water approximately 90 of which came from the Murray however in Table 1-1 on pg 1-2 2 it says SA used 1805 GL 79 of which came from the Murray

Response See Response to 91 above

Supplementary EIS for the temporary weir near Pomanda Island -83-

Supplementary EIS for the temporary weir near Pomanda Island -84-

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report

85

1 Introduction

Community Consultation Report purpose The Community Consultation Report is a companion document for the Supplementary Environmental Impact Statement (EIS) for temporary weir near Pomanda Island This Report is the record of activities completed during the public consultation period and a record of the submissions received on the draft EIS

This document demonstrates that the Department for Environment and Heritage (DEH) created a public interest context for the Environmental Impact Statement process

The Department gathered processed and responded to public submissions so that the Supplementary EIS was appropriately produced

Objectives for this Report are

to meet the requirements of the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act)

to record the actions of the Community Consultation process

to record all submission summaries and a response to them This is a significant aspect of the Community Consultation Report (Appendix IX)

to demonstrate that a diligent transparent and effective process was in place which optimised receipt of public submissions relevant to the draft EIS

Summary This document overviews

four Community Information Sessions about the Draft EIS for the general public targeted consultations with Ngarrindjeri and ten other specialist groups media generated during the consultation period processes for receiving submissions and for developing the Supplementary EIS

2 Community Information Sessions Advertising and materials distribution prepared the way for the Community Information Sessions

Community Information Sessions were advertised using newspaper advertisements the DEH website and the Coorong Lower Lakes and Murray Mouth Project (DEH) email Bulletin lists (See Appendix VI)

Draft EIS materials (CD hard copy Executive Summary) were distributed widely free of charge The full text Draft EIS was also made available in appropriately targeted local government offices and schools and a number of full text Draft EIS Appendices were also available Hard copy Draft EIS were available for $100 from one Adelaide retail outlet (See Appendix VI Distribution List)

Four Community Information Sessions were held as follows

Murray Bridge Tuesday 24 March 2009 1000am - 1230pm Uniting church Worship Hall Registered attendees 50 people

Meningie Tuesday 24 March 2009 300pm - 530pm Meningie Bowling Club Registered attendees 47 people

Goolwa Friday 27 March 2009 1000am - 1230pm Centenary Hall Registered attendees 93 people

Clayton Bay Friday 27 March 2009 400pm - 630pm Clayton Community Hall Registered attendees 53 people

Supplementary EIS for the temporary weir near Pomanda Island -86-

A total of 243 people attended the four Community Information Sessions

The agenda for these meetings were as follows

Community Information Sessions Agenda

Facilitator Lindsay Holmes (Meeting Success)

Session Length 25 hours

Timing Task Responsible person

(mins) 5 Welcome and Ground Rules Lindsay Holmes Welcome to Country 5 Explain purpose of Session Peter Croft 5 Introduce specialist panel Lindsay Holmes 20 Explain session agenda and process Hon Dean Brown

Water Presentation 25 EIS introduction presentation Russell Seaman 5 How to respond to the EIS Peter Lumb 5 Explain small group purpose Lindsay Holmes 15 Tea Break 20 Work in small groups Lindsay Holmes

Groups identify and prioritise questions for resourc e peop le

60 Resource people answer questions Chaired L Holmes 5 Meeting thanks and closure Peter Croft

Explanation of the agenda

The purpose of the Community Information Sessions was to provide information about the EIS process and to assist people in preparing their written submission (comment) on the draft EIS It was made clear that the sessions were about gaining information rather than making verbal public comment on the draft EIS

A range of options for lodging submissions was presented

At each Community Information Session there was a panel of five or six specialist resource people

Supplementary EIS for the temporary weir near Pomanda Island -87-

The panel was drawn from the following

Peter Croft DEH Director Coorong Lower Lakes and Murray Mouth Projects

Russell Seaman DEH Manager Environmental

Dr Kerri Muller Contract Ecologist

Ross Carter SA Water Manager Major Projects

Glynn Ricketts DWLBC Environmental Water amp Infrastructure

Judy Goode DWLBC River Murray Environmental Manager

Hon Dean Brown Drought Reference Group

Premier s Spec ia l Advisor on Drought

Paul Harvey Murray Darling Initiative

Program Leader

Jan Whittle SA Murray Darling Basin NRM Board

River Murray Environmental Manager Unit

The panel of specialists was introduced early in each meeting prior to two major presentations

Russell Seaman gave a PowerPoint presentation which overviewed key aspects of the draft EIS for the proposed temporary weir near Pomanda Island

The Hon Dean Brown gave a PowerPoint presentation which provided a Murray-Darling Basin water issues context for the proposed temporary weir

Participants formed groups of eight with a trained DEH facilitator The purpose of the group fac ilita tion was to write questions on la rge post-it notes These questions were to be sorted and answered by the specialist panel

As group facilitators wrote questions the questions were continuously collected and placed on a wall Specialist panel members gathered and discussed who would be the most appropriate panel member to answer each question Like-questions were assembled with like Duplicate or overlapping answers were avoided

The meeting regathered and the specialists answered questions in an open manner

DEH provided a light meal at the end of each Community Information Session Community members were invited to stay on after the meeting to informally discuss issues and ask questions of the specialists Many members of the public accepted the invitation

This meeting format allowed all community members the opportunity to ask questions hear answers from people with specialist knowledge and then to engage with them further This was a successful format for the purpose of sharing information A large number of questions were answered and the community had maximum exposure to specialist panel members Panel members and community members generally responded favourably to this format

The records of these meetings include the wording of each question submitted to the specialist panel (Appendix IV) A summary of broad indicative categories of questions are included in Appendix IV including a graph consolidating answers from the four Community Information Sessions

People who attended the Community Information Sessions were invited to pre-register via email at eisdehsagovau or to register through an EIS 1800 number hotline (Appendix VIII) Registrations were sought to ensure that venues had sufficient capacity there was a sufficient number of group facilitators and so that catering was adequate Registrations were also accepted on entry and all registrants were supplied with a

Draft EIS Executive summary

CD containing a submissions cover sheet the Executive Summary the full text Draft EIS and all Appendices of the Draft EIS and

paper summary of the main PowerPoint Draft EIS presentation

Registration also provided the option for people to provide an email address so that they could receive Coorong Lower Lakes and Murray Mouth project updates

Supplementary EIS for the temporary weir near Pomanda Island -88-

In addition copies of Sim T and Muller K (2004) A Fresh History of the Lakes Wellington to the Murray Mouth 1800 to 1935 SA Murray Darling Basin Natural Resources Management Board Government of South Australia were available to registrants courtesy of the MDB NRM Board

3 Targeted Meetings The Ngarrindjeri People individually and collectively are involved in ongoing consultation about the about the Draft EIS for the proposed temporary weir near Pomanda Island Consultation about the Long Term Plan for the Coorong Lower Lakes and Murray Mouth will be ongoing

Ten targeted meetings were held between 2 February and 2 April 2009 Two meeting were held in Adelaide and eight were in the region (Appendix III)

The targeted meetings were attended by Peter Croft Director Coorong Lower Lakes and Murray Mouth Projects and Russell Seaman Manager Environmental (Department for Environment and Heritage) Peter Croft briefly discussed the developments leading towards the Long Term Plan for the Coorong Lower Lakes and Murray Mouth while Russell Seaman provided the PowerPoint presentation used for the Community Information Sessions but tailored the presentation towards the interests of particular audiences Brief records of these meetings appear in Appendix V

In each case these targeted meetings were scheduled meetings which allocated time on their agenda for the additional presentations about the Draft EIS and the Long Term Plan

4 Overview of media articles (see Appendix VII) This section provides the media context during the time leading up to the opening for public comment on the Draft EIS for the proposed temporary weir near Pomanda Island (12 March) to the close of the comment period (9 April)

In January and February 2009 med ia foc ussed on d isc ussions about flood ing the Lower Lakes Two of the 15 stories provided mention of the proposed temporary weir Through March when the Draft EIS for the proposed temporary weir near Pomanda Island was released 18 of the 20 articles focussed on the proposed weir Some media reporting (as summarised by Media Monitors) did not clearly differentia te between the EIS for the flood ing of the Lower Lakes and the EIS for the Proposed Temporary Weir indicating and exacerbating some public confusion

Main discourse The South Austra lian Government s ma in message was tha t the weir is a last resort tha t will only proceed if absolutely necessary in a worst case scenario situation The South Australian Government is committed to seeking a fresh water solution - they do not want to build the weir

A consistent criticism of pursuing approval for the weir is that it indicates that the South Australian Government has given up on a freshwater solution The media surveyed indicates that a fresh water solution is the preferred and only suitable option If the South Australian Government was serious about providing a solution media discourse suggests they would use the money to purchase water rather than for construction of the proposed temporary weir

Many who are opposed to the weir are of the opinion that the government has already made its decision and the weir will go ahead

Other issues raised There were several other issues raised in the articles including

the proposed temporary weir will cut off the River Murray from the Lower Lakes (one article)

there are alternatives to the weir such as storm water harvesting and more water efficiency (one article)

if the weir is built it is a temporary weir and temporary solution and the final decision on the weir will come six months prior to decision to flood the lakes (one article)

the number of regulators and weirs being planned in addition to the proposed temporary weir Clayton Finniss Latham Point Goose or Goat Island (two articles)

Throughout the majority of articles the weir was referred to as the weir or the Wellington weir and approximately 10 per cent of the time it was called the Pomanda weir

Supplementary EIS for the temporary weir near Pomanda Island -89-

A media release by the Federal Minister for Environment Heritage and the Arts mentioned the need for a long term vision and noted that the Australian Government has committed $200 million from its Water for the Future Plan to assist in the planning process and an additional $10 million towards the development of a long term plan for the Coorong and Lower Lakes

Two media reports expressed concern about the triggers to remove the proposed temporary weir saying that unless increased salinity and acidification levels are addressed and there is freshwater released into the lakes one of the triggers that salinity levels drop below 3000EC - will not be able to happen

Summary

Media analysed

Medium (Total) Channel Number ABC 16 5AA 5Radio (22) Triple M 1 9 Network 2 10 Networks 1Television (4) ABC 1 1 Independent Weekly 1 Adelaide Advertiser 1 Stock Journal (Regional) 3 Times Victor Harbor 1 Murray Valley Standard 1

Print (8)

Lakelander 1

Media release The Hon Peter Garrett Minister for the Environment Heritage and the Arts (one)

Four were regional stations five were Adelaide metropolitan stations and seven were both Adelaide metropolitan and regional stations

Total - 35

5 Receiving submissions and developing the Supplementary EIS The Draft EIS was open for public comment from the 12 March to 9 April 2009

The public were invited to provide written submissions as emails as emails with word attachments or to send hard copy using a free post address

Seventy submissions were received from the public There were 49 individual submissions 18 from community and other organisations and three from local government All submissions are available on DEH website wwwenvironmentsagovaucllmmsubmissions-receivedhtml

Submissions were uploaded twice per week during the public comment period Submissions were listed by author or organisational author as per Appendix I and Appendix II

Supplementary EIS for the temporary weir near Pomanda Island -90-

Timeline of the post-Community Consultation period

9 April Acceptance of submissions closed at 5pm

10 13 April

During the four days over Easter submissions were read summarised and a statement provided in a response column Key words in submissions were identified Summaries and responses were entered into a specially prepared Microsoft access data base Summaries from the data base are provided as appendix ix

14 April

A list of key words was compiled from the access data base The data base was then searc hed by a ll relevant key word s All sub missions jud ged to be in sc ope and a ssoc ia ted with a key word or key word string were then assembled Submissions were then sent to thirteen specialist writers Most writers had attended a meeting at which the requirements for preparing responses were outlined and the constraints of the tight timeline emphasised Other writers had individual briefings Writers could choose to receive hardshycopy of all relevant submissions or access copy on the internet The broad objective provided to writers was to create an over view summary of issues in response to issues associated with the key words for which they were responsible

15 17 April Specialist writers had three days in which to write their over view summaries

17 April Summaries were returned for compilation into the supplementary EIS and an executive writer and assistants then had six days to create an integrated supplementary EIS

24 April A draft of the supplementary EIS was prepared and sent to specialist writers for comment to be returned by 12pm Monday 27 April

27 April

Comments were incorporated into the draft of the supplementary EIS and a new version prepared for a briefing meeting on Tuesday 28 April The objective of this meeting was to facilitate final changes before chief executive and ministerial sign off

30 April The supplementary EIS was prepared and sent to the chief executive and the minister s offic es

Supplementary EIS for the temporary weir near Pomanda Island -91-

Supplementary EIS for the temporary weir near Pomanda Island -92shy

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report ndash Appendices

93

Appendix I Submissions received Individuals

Surname First name Suburb Date Submission

number

Cooke Roger Goolwa 29032009 PTW00001

Galea Michael Clayton Bay 30032009 PTW00002

Fargher Philip Norwood 01042009 PTW00003

Zoerner Andrew Prospect 03042009 PTW00004

Smith Douglas Goolwa 03042009 PTW00005

Rees Melanie Henley Beach 03042009 PTW00006

Brisco Mike Campbelltown 04042009 PTW00008

Moyle Ian Woodcroft 05042009 PTW00009

Harvey Richard North Adelaide 06042009 PTW00011

Richards Sally Finniss 06042009 PTW00012

Giles Trevor Langhorne Creek 06042009 PTW00013

Lower Brenda Goolwa 06042009 PTW00014

Michelmore Frederick Gordon Middleton 07042009 PTW00015

Lucas Ann Goolwa 07042009 PTW00016

Jones Glen Adelaide 07042009 PTW00017

Fenton Derek Finniss 07042009 PTW00019

Tjukonai Vesper Meningie 07042009 PTW00020

McFarlane Keith Tailem Bend 07042009 PTW00021

Read Tony Beaumont 07042009 PTW00023

X Mick Mannum 08042009 PTW00024

Hartnett Anne Milang 08042009 PTW00025

Whitehead Alexander Hindmarsh Island 08042009 PTW00027

Fairweather Peter Adelaide 08042009 PTW00028

Thomas Robert Goolwa 08042009 PTW00029

Carroll Barbara Happy Valley 08042009 PTW00030

Jones Henry Clayton 08042009 PTW00031

Bagley Chris Milang 08042009 PTW00033

Yelland Liz Milang 09042009 PTW00034

Vonow Lynton Lobethal 09042009 PTW00035

Trigg Ruth Normanville 09042009 PTW00036

Yelland John Milang 09042009 PTW00037

Brooks Bruce Finniss 09042009 PTW00038

Walker Keith Yankalilla 09042009 PTW00039

Harden Trevor Finniss 09042009 PTW00041

Allnut Bruce Finniss 09042009 PTW00042

Shillabeer Neil Oakbank 09042009 PTW00043

Heyne Ron Goolwa 09042009 PTW00044

Showell Jacqui Goolwa Beach 09042009 PTW00048

South Cecily Milang 09042009 PTW00049

Moon Silver Finniss 09042009 PTW00051

Supplementary EIS for the temporary weir near Pomanda Island -94-

Surname First name Suburb Date Submission

number

Hunter Rex 09042009 PTW00052

Bradford Karen Milang 09042009 PTW00059

South Mike Milang 09042009 PTW00060

Belford Beryl Mt Barker 09042009 PTW00063

Hobbs Elizabeth Goolwa 09042009 PTW00064

Vizard Talina Victor Harbor 09042009 PTW00065

Carter Carlsa Bridgewater 09042009 PTW00066

Scobie Keith Meningie 09042009 PTW00069

Russell Ruth Magill 16042009 PTW00070

Young amp Jury Mike amp Ken Goolwa 16042009 PTW00071

Submission received under special circumstances Submission sent prior to end of community consultation period

Supplementary EIS for the temporary weir near Pomanda Island -95-

Appendix II Submissions received Organisations

Organisation Date Submission

number

Southern Alexandrina Business Association Inc 04042009 PTW00007

Signal Point Riverine Environment Group Inc 05042009 PTW00010

Alexandrina Council 07042009 PTW00018

The Marina Hindmarsh Island 07042009 PTW00022

SA MDB NRM Board 08042009 PTW00026

Rural City of Murray Bridge 08042009 PTW00032

Australian Institute of Landscape Architects 09042009 PTW00040

Ngarrindjeri People 09042009 PTW00046

DTEI 09042009 PTW00047

Environmental Defenders Office (SA) Inc 09042009 PTW00050

The Coorong District Council 09042009 PTW00053

River Lakes Coorong Action Group Inc 09042009 PTW00054

Nature Conservation Society 09042009 PTW00055

Murray-Darling Basin Authority 09042009 PTW00056

Australian Democrats 09042009 PTW00057

Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

09042009 PTW00058

PIRSA Fisheries 09042009 PTW00061

Natural Heritage Trust 09042009 PTW00062

Conservation Council of South Australia 09042009 PTW00067

Goolwa District Ratepayers and Residents Association Inc 09042009 PTW00068

Supplementary EIS for the temporary weir near Pomanda Island -96-

Appendix III Participants and notes from Targeted Meeting Sessions

Local Knowledge Reference Group

Date Wednesday 4th February 2009 1100am 200pm Location The Monastery

In attendance Dean Brown Bill Paterson Prof Diane Bell Mike Geddes Mike Hammer Neil Shillabeer Paul Davis Rebecca Lester Rob Fitzpatrick Sebastian Lamontagne Mary-Anne Healy

Summary of comments or issues

Draft EIS was presented to the Local Knowledge Reference Group (LKRG) - draft is confidential

Consequences of weir removal and ability for system to recover

Scope of EIS should extend beyond matters of NES

Management strategies for potential flooding should be addressed in the EIS

Approvals process

Concerns regarding high water mark in relation to the causeway and Ramsar boundaries

Apologies were given to the group in regards to the lack of communication around the draft EIS in the past

Discussion

Raised issue re water levels relating to the barrages should say 7000 years

Changed the word ing to levels never rec orded ra ther than not seen sinc e the c onstruc tion of the barrages

No work has been done on how to recover the environment after the removal of the weir

Not going to remove the roads and tracks

Impacts locally not Ramsar site

Weir sinks over time

Remove down to bed level should not be any impediment to what was originally there

Will take time but should result in no impact

Weir will be there for 3 years

SA Water suggests there will be minimum impact

Mud waves will cause impact but will be transported away from sedimentary processes

Increased sedimentation as a result of the structure and disagreement that there will be a significant impact after the removal

The need to conserve the Ramsar wetland and what might be the implications Is it just going to go ahead Worried about the significant damage and if the system will ever recover

Cannot assess what has been done Needs clarity about the purpose of the group

Issues around rates of change and thresholds associated with the weir Also life stages and ecological character

Limited scope about this in the EIS only addresses matters of NES

Will edit the factual errors

Will help edit as well

Worried about experts need for higher level expertise for public comment period

Supplementary EIS for the temporary weir near Pomanda Island -97-

What if there are natural water flows floods Recovery Should be reference in the document to flood event happening and the ability to manage that

Agrees with Bill and need to understand and have something in place if there is a flood and removal of the weir

States that the draft EIS seems to have solid blame on the drought but over-allocation and excessive use are contributing factors as well Look at the language and justification of the EIS Issues about the decision making Commonwealth SA Gov

Understands that it goes to Commonwealth and SA Govt makes the decision Need approval under the EPBC Act

Need approval for MDBA and Minister

Interested to see if the Ramsar site is actually the boundary of where the weir will be built and the implications of that and whether the weir can take place

Drew a diagram of where the cadastral boundary is and where the causeway and proposed temporary weir are Assuming this is where the high water mark is

The whole group are concerned that the high water mark is actually exceeding where the causeway is and if that is the case the causeway and where the weir will be built will actually be in the Ramsar site

Supplementary EIS for the temporary weir near Pomanda Island -98-

Meningie Community

Date Thursday 5th February 2009 700pm 1100pm Location Football Club Rooms Meningie

In attendance Approximately 200 locals Andrew Beal Prof Diane Bell Robyn McLeod Dean Brown Peter Croft AProf David Paton

Summary of comments or issues

Dean Brown Prof Diane Bell Andrew Beal Peter Croft Robyn McLeod and AProf David Paton each gave a short presentation on current issues based around the Coorong and Lower Lakes providing management options

Summary of conditions and long term plans to help secure a future for the Lower Lakes Coorong and Murray Mouth

Following the presentations the community members were given the opportunity to ask questions of the presenters

Neil Shillabeer facilitated the meeting

The meeting was a little heated and closed around 11pm with people staying to speak with the presenters and other expertsofficials

Questions and discussion

What can we do to make other states realise that we are in a dire situation and that we need more water

What is temporary

Groundwater

Over-allocation

Where is the support for the community

Ngarrindjeri hurting no one is speaking with them or the community

What are the government officials going to do to help the community

Yes they are helping the environment but not the economic values and people

Why c an t they have a p ipeline like the other side (referring to the Langhorne Creek irrigation line)

Why haven t they been told about the c osts involved with this p ipeline

Lake Albert s a lloc a tion

What level will the Lakes be once the weir is in place

What are the trigger points for removal

If the weir is built are they going to put in fish ladders or will they be blocked

If Lake Alexandrina gets lower how are they going to continue pumping into Lake Albert

If seawater is let in how are they going to deal with the millions of dead fish and the clean up

How are they going to fix South Austra lia s own wa ter issues and a lloc a tions Need to address what is happening here before we blame upstream

Supplementary EIS for the temporary weir near Pomanda Island -99-

Milang Community

Date Thursday 12th February 2009 130pm 500pm Location Milang Institute Building

In attendance Anne Hartnett Dianne Bell Ken Follett Tim Trevorrow (APOL) Rowena Brown Dr Rob Fitzpatrick Bruce Brooks Graham Gates Lesley Fischer Tony Randall Peter Alexander Wayne Brown Carol Richardson Greg Lundstrom Richard Owen Peter Croft Clare Manning Russell Seaman Karyn Bradford Kathryn Rothe Shirley Smith Liz Barnett Simon Oster

Summary of comments or issues

The Lower Lakes Partnerships for Recovery

Lower Lakes communities are keen to use their knowledge labour and community infrastructure to bring about Lakes and River recovery

The community seeks partnership with government to

- Rescue and remediate degraded environments

- Impede further degradation

- Instigate environmental management and development practices

- Address current and future effects of climate change

Projects have been identified for both immediate and long term implementation

Revegetation Revegetate areas subject to Acid Sulfate Soils with plants having low impact on soil

saturation in

- Priority areas in Finniss River and Currency Creek

- Receding lake shores

- Known ASS hot spots

- Spots at-risk of drying out wind erosion and sun exposure and affected by stock access

Revegetation capacity building Collect seeds for replanting (native plants)

Undertake at-risk plant rescue and propagation

Purchase propagation and planting of annuals

Plant large trees away (upwind) from Lake edge as leaf litter will provide sources of organic matter and iron to Lakes (builds resilience)

Flora and fauna protection Control of increased feral populations arising from revegetation

Establish refuges for endangered flora (and fauna)

Weed control

Protecting fringing vegetation Protect lake revegetation areas from cattle

Protect cattle from poor quality drinking water

Environmental remediation Community Acid Sulfate Soil treatment projects

Source local limestone for application to ASS

Supplementary EIS for the temporary weir near Pomanda Island -100-

Nurture and capture knowledge

Train communities to identify and map plants useful for land protection and remediation

Create systems for long term monitoring of soils vegetation growth and regrowth

Establish community survey systems to map current and changing status of soils

Collect and contribute data that will enhance GIS data banks and veracity

Create local administrative and data collation processes to manage the above incorporating two-way communication and mutual benefit from data

Monitor water use to aid in the beneficial allocation of water resources

Supplementary EIS for the temporary weir near Pomanda Island -101-

Peter Croft s Murray Futures update for the Lower River Murray Drought Reference Group representatives

Date Thursday 26th February 2009 200pm 500pm Location Murray Bridge

Summary of comments or issues

Status of Environmental Impact Statement for the proposed temporary weir near Pomanda Island

Timelines for the project

Community involvement

Timelines for the Long-Term Plan to secure a future for the Coorong and Lower Lakes Ramsar site

Community Action Planning

Information provided

EIS has not yet been finalised or lodged but is in the critical final stages and is expected to be lodged shortly

We will be holding some Community Information Sessions in the 4th week of March (pending approval from the Commonwealth)

There will be a media release of notices via national state and local press announcing the sessions locations and times to inform the communities (subject to Commonwealth approvals)

These sessions are to summarise the draft EIS allow community members to ask technical questions of some specialists and provide advice to the community on preparing submissions on the draft EIS

A Reference group has been developed (The Long-Term Plan Reference Group) and brings together community leaders scientists and government staff with a view to develop a long-term plan to secure a healthy future for the Coorong and Lower Lakes Ramsar site

This is an important first step to help identify a realistic sustainable future for the region one that will address the environmental community and economic values that are important to the region

Our aim is for a coordinated management response for the future of the Coorong and Lower Lakes And involving the community along the way is critical to the success of our work

We are aiming for a 1st version of the Long-Term Plan ready for public consultation in April We will ensure that a range of different communities get on the list of possible locations (eg Milang and Langhorne Creek)

Notices of such events will be distributed through the national state and local press as well as our website

On 12th February we met with representatives of Landcare Groups and Local Action Planning Groups to discuss proposals for community action around the Lakes

A number of areas of action were identified and a small team with representatives from DEH Regional Conservation Team and LAP Coordinators will flesh out the actions in more detail

A Plan of Action is being developed for trial projects with potential funding of $100000 that may be available to support some preliminary work We plan to finalise the details and get activities rolling ASAP

Supplementary EIS for the temporary weir near Pomanda Island -102-

Ramsar Taskforce Committee

Date Friday 13th March 2009 1100am 1230pm Location Wyndgate

In attendance Ramsar Taskforc e c ommittee members Peter Croft Russell Seaman and Peter Lumb

Summary of comments or issues

Peter Croft briefly introduces EIS processes and distributes draft EIS community development and hard copy Executive Summary

Russell Seaman gave a presentation in the EIS and asks for feedback

Broad range of questions ranging from fish ladders in the weir to alternative options

Questions and discussion

Will the Supplementary EIS be made public

Will the Australian Government then require community consultation on the Supplementary EIS

Why is there such a short time for public comment on the draft EIS

What do you mean by environmental hotspots

Has any thought been given to a natural causeway near Pomanda Island

Is the weir site within the Ramsar site

Where will the water come from to flow over the weir if a weir is built

Comment about the importance of fish ladders

Emphasise that the weir is not a trigger for sea water incursions

Emphasise that the presentation is mostly based on worst case scenarios

The EIS must mention over-allocation

Emphasise actions taken or about to be taken when possible

Emphasise terrestrial vegetation more as well as Lake bioremediation

How much employment will be created in the region

Is it possible to have Councils administer vegetation and bioremediation projects rather than the Attorney-General

Supplementary EIS for the temporary weir near Pomanda Island -103-

Scientific Advisory Group (SAG)

Date Monday 16 March 2009 930am 1130am Location L5 81 Flinders Street Adelaide

In attendance Rebecca Lester Ingrid Franssen Mardi van Wielan AProf David Paton Adrienne Frears Glynn Ricketts

Summary of comments or issues

Decision trees and timelines

Alternative options

Trigger points

Questionscomments

Needrequest to set aside 5 for science to underpin management

Lake Albert needs early consideration

Need a decision tree as some actions are alternatives or consequent actions

Link decision tree to timeline and water flows

Need to account for measures for Long Term Plan to prevent the need to do reactive work again in ten years

Assumption restore wetland functioning to build resilience

Focus on upper Finniss and Currency dam bypasses upstream modelling water allocation and managing low-flows

Scientific Advisory Group can assist with advice if needed

Pomanda weir s estimated c ost $150m

Need to find out if there is a major ecological downfall if the acidification occurs

Reduce or stop pumping for winter lower evaporation and stop wind erosion

Apply limestone only when triggers are reached

Any ideas for the Long-Term Plan will influence the second version of the Plan

Ephemera l systems a re na tura l Lake Albert is a termina l wetland no outflows

A more complete document will allow a more thorough examination of the situation (possibly in April)

Which trigger will come first

Is a virtual weir still on the table

Does the dam allow for a fishway

Supplementary EIS for the temporary weir near Pomanda Island -104-

South Australian Murray-Darling Basin Natural Resource Management Committee

Date Thursday 19 March 2009 930am 1200pm Location Murray Bridge

In attendance SA MDB NRM Board members Peter Croft Kerri Muller and Lindsay Holmes

Summary of comments or issues

Questions focussed on conditions climate and the environment

Questionscomments

How will the weir be deconstructed

Can we separate the effect of the weir from the effect of the drought

Is the 350GL of wa ter over the weir in c urrent c ond itions

Will water go into the Lake when there are disconnection issues

Will there be a short-term increase in salinity while the pool fills

What is the current river level

Does the EIS consider scouring

Is flooding risk considered (in EIS)

Mud waves are a major issue

Why will construction of the weir be worse during summer

What are other alternatives

When does the EPBC Act review end

Can we make a definitive statement about what happens to the wetlands

Supplementary EIS for the temporary weir near Pomanda Island -105-

Icon Site Community Reference Committee

Date Monday 23rd March 2009 930am 1200pm Location Langhorne Creek Bowling Club

Summary of comments or issues

Questioned the science and experts available

Alternative options were discussed

Questioned engineering aspects of the weir

Russell Seaman presented an overview of the draft EIS

Group showed concern for repercussions of actioninaction

Questions asked

Coorong evaporation 200GL of fresh or seawater

Who will DEH engage as experts to advise on seawater incursion

What will DEH be basing their knowledgeevidence on in regards to the seawater incursion

Has anything like it been done before

Mulching

Limestone locally sourced

Coorong North lagoon monitoring and ASS who is monitoring and what is being done to remediate the hyper-saline conditions

To what extent can we replicate what was in the past southeast freshwater

Salinity in the south lagoon would the level allow Rupia sp to establish itself

Mechanical mouth operation as opposed to dredging has this been considered

What are some other options

Has the department looked at Vortex sand pumping

Will there be culverts between the Lakes through the causeway for water to flow via wind seiching

More research needs to be done has the Department considered engaging the local knowledge Don t dup lic a te researc h

If temporary why are you considering installing fish passages in 5 years time Should that not be done at the time of the weir installation

What levels are you looking at for the lakes

Supplementary EIS for the temporary weir near Pomanda Island -106-

Russell Seaman presentation Overview of the draft EIS for the temporary weir near Pomanda Island

Questions asked Why 01 AHD for the spillway

At what Lake level will it start acidifying

Should we have a lower weir

What is the risk of salt levels increasing when you stop the flows for 3 months

Will ground waters be coming in

What about the banks collapsing

What is the water quality of ground water and will it contaminate the Lakes

What happens if water flow exceeds 15GL per day ie if flood occurs will the structure cope

How quickly will the structure sink is it 1m per year

Will the weir be in place by 1st January 2010 as the graph indicates

When is -15 AHD expected

Has the Premier decided to buy water to see the Lakes through to winter 2010

Have you factored in the local rainfall flows within Currency Creek and Finniss

Is there an indication of seepage of ground water into any region of the Lakes

Have you looked at Biochar for remediation purposes

Lime straight pH neutraliser or feed the bacteria

Why not put a carbon source in there as well

Supplementary EIS for the temporary weir near Pomanda Island -107-

Lower River Murray Drought Reference Group

Date Thursday 2nd April 2009 Location Murray Bridge Council Chambers

Chair Dean Brown In attendance 14 Reference Group members 15 people in the Public Gallery

Summary of comments or issues

EIS Presentation by Peter Croft 30 Minutes including questions

Peter Croft presented overview of the draft EIS

Issues relating to seepage

Costs and issues relating to weir construction

Weir removal

Timelines for weir construction

Questions and comments

All questions asked were from Reference Group members with occasional comments from the public gallery

If the weir is built will more wetlands be closed between the weir and Lock 1

Are estimates being made of loss of water to seepage through the cracked levee banks above the weir And will this seepage appear in the Lake

Will it be the case that water will stop flowing over Lock 1 at some stage to facilitate the construction of the weir

Adrian Pederick MP asked who wrote the draft EIS

Member referred to a rumour that irrigation will cease with weir construction

Can you be clear about the cost of the temporary weir if built

Is the cost of the causeway included

Where will the SA Government get the money to construct the weir (Some anxiety that it would be CLLMM money (Comment wasn t c learly aud ib le)

What is the likelihood of a virtual weir

There was a question (inaudible) about the height of the weir above sea level (Was it about the adequacy of the height to secure water supply if the Lake levels rose)

How much of the weir would be removed when decommissioned

Comment about the complexities of start times and the apparent late start to protect water supply

Update on other matters Peter Croft Closing date for submissions on the draft EIS on proposed temporary weir

Promotion of availability of all documents and information sources

The Goolwa Channel referral lodgement is imminent

Actions Application for projects under $120000 April 10

Approvals process for lime-stoning the first flush coming down the Finniss and Currency Creek

Seeding and bioremediation workshop held Tuesday 31 March

Rural Solutions developing a bioremediation plan around both Lakes

Supplementary EIS for the temporary weir near Pomanda Island -108-

Appendix IV Organisations that participated in Community Information Sessions

The Advertiser

Department for Environment and Heritage

University of South Australia

La Trobe University Centre for Sustainable Regional Communities

Native Food

Investigator College

River Lakes and Coorong Action Group Inc

South Australia Murray Darling Basin Natural Resources Management Board

River Murray Boat Owners Association

River Murray Museum of River History

Department for Sustainability and Environment

Wellington Lodge Pty Ltd

Ranges to River NRM Group

Food and Beverage Australia Ltd

Narrung Wetland Monitoring Group

BMT-WBM (Engineering and environmental consultants)

River Lakes and Coorong Action Group

All Land and Livestock

Clayton Bay Community Association

Finniss Catchment Group

Southern Alexandrina Business Association Inc

Coorong District Council

Narrung Dairy Farmers

Southern Fishermen s Assoc ia tion

Clayton Bay Foreshore Committee

SA Water Corporation

Fleurieu Regional Development

Alexandrina Council

University of Adelaide

Supplementary EIS for the temporary weir near Pomanda Island -109-

Appendix V Participants and notes from Community

Information Sessions

Community Information Sessions Agenda

Proposed Locations Meningie Murray Bridge Goolwa Clayton Bay Facilitator Lindsay Holmes (Meeting Success) Session Length 25 hours

Timing Task Responsible person

5 min Welcome and Ground Rules Lindsay Holmes

Welcome to Country

5 min Explain purpose of Session Peter Croft

5 min Introduce specialist panel Lindsay Holmes Explain session agenda and process

10 min Water Presentation Hon Dean Brown

25 min EIS Introduction presentation Russell Seaman

5 Min How to respond to the EIS Peter Lumb

5 min Explain small group purpose Lindsay Holmes

15 min Tea Break

30 min Work in small groups Lindsay Holmes Groups identify and prioritise questions for resourc e peop le

40 min Resource people answer questions Chaired Lindsay Holmes

5 min Meeting thanks and closure Peter Croft

Supplementary EIS for the temporary weir near Pomanda Island -110-

Meningie Community Information Session

Date Tuesday 24th March 2009 300pm 530pm Location Meningie Bowling Club

Questions asked of the specialist panel listed by category

Lake Albert Is pumping going to stop or continue at Lake Albert

In worst case scenario what will be done about Lake Albert if it runs dry

Assuming a weir will be built what actions will be taken to maintain Lake Albert

What is the future for Lake Albert

Why isn t Lake Albert written up more in the d ra ft EIS

River flows Why are upstream tributaries not included in the flow data considering it is the Murray-Darling Basin system (The information is then misleading for Min Garrett)

Inflow figures Are these figures based on whole basin or just the Murray River catchment

Is there information on how much water is coming in to the basin catchment (not just inflows)

Is 350GL guaranteed to come over the weir per annum Is that happening now

How will the weir pool level be maintained ie Where will the water come from Does this relate to water buy back

Why c an t some of the wa ter held on fa rm dams etc be released and peop le use a little less water to maintain levels (federally)

What measures are being considered to improve sharing and saving water throughout the Basin

How much area is considered Murray-Darling catchment

put in place to use alternative storagemake Adelaide less dependent on the Murray

Ramsar How will the Ramsar convention be respected

Australia signed the Japan-Australia migratory birds agreement (also with China) re wetlands of international significance How will the weir effect this agreement

Is government looking at taking control re Ramsar site

Wildlife What happens if there is a fish kill in Lake Albert

Will the weir affect cod numbers and is there a plan to recover this species

Has the magnitude of a fish kill been considered ifwhen the weir is built Consider Lake Albert amp Lake Alexandrina separately

What will happen to the fish turtles etc if salinity increases

Acid Sulfate Soils (ASS) Why hasn t the government looked a t other op tions for remed ia tion for ASS

What is the long term planmedium term plan for Lake Albert and the ASS issue

What is the gas that comes out of the mud in Lake Alexandrina (Three cases of dizziness when exposed to this)

What can be taken out of Menindee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Alternative catchments Adelaide is now taking 90 water from Murray What is being

Wha t c an be ta ken out of Menind ee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Supplementary EIS for the temporary weir near Pomanda Island -111-

Salinity issues What mitigation strategies are in place to mitigate hyper-salination in the Lakes

Salt water sits beneath fresh water How will the salt water flow over the weir

If the weir is pumped is the pumped-out water saltier

Does the salt water layer

How are they going to flush the salts that accumulate in the weir pool

What is the evaporation rate per annum at the present time considering the Lake levels today Is it still 800GL

Rainfall Was there rainfall measured over Lake Alexandrina in winter last year (No rainfall measured by farmers)

Why doesn t the d ra ft EIS mention Lake ra in

Will decreasing the surface area of water in the Lakes reduce rainfall over the Adelaide catchment increasing the strain of Adelaide Hills reservoirs

Proposed temporary weir impacts How is the weir going to be removed

What is the trigger point for the weir decommissioning

Given the modelling and g iven the government dec ides to build the weir why isn t a lock considered Would allow navigationfish passageflow management

Why is there no facility for navigation through the weir

Why a re there no fishways Why isn t it nec essa ry to have fishways

Is the base of the weir stable enough to stop slippage of the structure

How will they monitor the silt on the downside of the weir and particularly with ASS

Will time to fill the weir pool be more than three months (based on worst-case scenario) Will some leak out under the levee banks

When would construction start

What would it cost to move the intake points above Lock 1

Will the weir help mitigate acid soils in the Lower Lakes

Why does the EIS not address much between Lock 1 and the weir in relation to damage of embankmentshabitat above the weir

How can they guarantee that removal of the weir will allow things to go back to the way they were

Social and economic impacts What consideration has been given to sustaining cultural flows for Indigenous people

Are the social impacts of building the weir and low flows being considered in the decision to build the weir

What provision has been made in the EIS for socio-economic impact factors

Seawater If seawater is let in how far into the groundwater will the seawater penetrate What will be the impact on the level of groundwater

How will the weir affect the decision to allow seawater into the Lakes

How does the weir link with the seawater incursion and will it need another EIS

Politics and Government When is the Murray-Darling Basin Authority going to get up and running (currently only a CEO and Chairman) If it were in place then politics will be in order ()

There have been a lot off government bodies set up over the last few years What has their role been and what is their role now

What is the government doing to educate the public

Supplementary EIS for the temporary weir near Pomanda Island -112-

Miscellaneous Have the trigger points been addressed

Will the weir guarantee water for stock from existing pipelines

Will the weir cause impact on the positive impact that wind seiching plays in the system

Do submissions all go together to the Commonwealth

What will happen when a flood occurs at the Narrung pumping station Will it be removed and the channel opened

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 2 fishways) 14 River flowsallocations 11 Salinity issues 6 Lake Albert 5 Wildlife (Fishturtles) 4 Social and economic impacts (one Indigenous) 3 Ramsar 3 Sea water incursion 3 PoliticsGovernment 3 Acid Sulphate Soils 3 Rainfall (Lake rain) 3 Miscellaneous 4

Supplementary EIS for the temporary weir near Pomanda Island -113-

Murray Bridge Community Information Session

Date Tuesday 24th March 2009 1000am 1230pm Location Uniting Church Worship Hall

Questions asked of the specialist panel listed by category

Acid Sulfate Soils (ASS)

What effect will the weir have on the current situation of Acid Sulfate upstream given that the weir will not be constructed within the next three years

How extensive are the potential Acid Sulfate areas

How deep does the lake need to be to prevent ASS

What is the plan to deal with acidification post weir

What is worse Seawater or lake acidification

Salinity issues How will salt get back into the Lakes

What measures will be taken to address salt building up behind the weir (upstream)

How can you handle the salt (that will come down the river) How will it be managed

Have you considered installing pipesregulators to manage salinity at the base of the weir

Wildlife What evidence do we have that the birds will return after construction

Have we calculated impact of extinctions

River flows allocations Is there a lot of water available for sale

Why hasn t temporary wa ter been purc hased

What about buying water as an alternative to a weir

If a weir is built will there be more water allocations in SA

If the weir goes forward who will receive the water that will be saved from less evaporation Will the allocation be more

18 wa ter a lloc a tion Universa l na tiona l standard set a lloc a tion Why isn t there an agreed allocation standard to all usersirrigated Why not a special rule to override current allocation agreements

Has there been an audit on un-metered bores in the Basin and what action is being taken

How much have extractions increased and what were base extractions

Developed methods to estimate inflows model for calculating extractions How much water is prevented from entering the system Where do extractions go Why is there no graph for extractions for entire systems How is the flow calculated Where is this information available

What is the definition of inflows

Where is the water coming from to maintain the level of the weir pool and the river level

What are the differences in water quality in the channel with or without a weir How serious is the situation What about the use of water upstream Over-allocation

Proposed temporary weir Has consideration been given to the weir at Wellington having a fishway

Will the weir pool inundate the wetlands upstream

How will the water and salt discharge over the weir into Lake Alexandrina Spillway Gate

How will the process prevent the build up of algal blooms and nutrients behind the weir

Supplementary EIS for the temporary weir near Pomanda Island -114-

What will build up behind the weir (eg iron etc)

Water hitting the weir what is going to happen

Why a temporary weir Why remove it and rebuild it

When the weir is deconstructed what happens to debris rocks etc

What will the volume of seepage be What are the implications

Will construction of the weir begin in June

What are the trigger points for removal of the weir

Why is a permanent weir not being considered CSIRO says conditions will get worse

How are they going to remove the weir

How is the level going to be maintained as weir is expected to sink in sediment

Why is the weir being build to 01m above sea level

If and when the weir is removed can it be reassembled quickly

How long will the weir take to build

Were other options considered for construction of the weir and what were they

Have you found a solution to the weir foundation (ie mud and construction of the weir at Pomanda Point)

What is the trigger to open the weir

Are the triggers to demolish the weir strict

Why haven t they got sta rted on build ing the weir

Lock Have investigations been made to have a permanent weir with lock with fishway and means of allowing the bottom salt water to be discharged

Has there been consideration of a lock with the weir (or a bypass channel)

Why have we not considered a lock

Why consider a temporary weir when a permanent weir could be constructed with a lock to maintain a navigable river system

Politics government and planning What about the constitutional right that the river be navigable from top to mouth

When will the Murray-Darling be run federally Not by the states

Why not hand over water management to the Commonwealth

When will the government declare this a disaster

What grantsassistance will be provided (eg tourism) Irrigators get support Why not others Industry assistance

Why is the weir being considered as part of a piecemeal approach What about a long-term plan

Is the weir part of the broader management of the Lakes and Murray Wha t s the b igger picture and where does it fit

Why is there not an integrated plan including Goolwa Channel regulators rather than doing it piece by piece

What is the present status of the Goolwa Channel projects

Is there a trigger for putting in a desalination plant at Tailem Bend

How will the remediation be managed and the long-term effect of the silt build-up be dealt with

Will building of the weir delay the equitable distribution of water in relation to other states

If the weir is built what are the triggers for letting in seawater to the Lakes

Riverbanks What measures have been taken to ensure the levy banks do not collapse with the higher river levels

What proactive approach will be taken to care for river banks

Ifwhen we build the weir what about the raising of the head River bank decline

Supplementary EIS for the temporary weir near Pomanda Island -115-

Has there been any consideration given to realigning the Lake Alexandrina shoreline Reduce evaporation in future

Pumping stations

Cost of moving pump stations above Lock 1

Chapter 4 Relocation of pumping stations above Lock 1 (needs clarification)

If they put in the weir will they continue to pump water to Lake Albert

Society and economy What is the impact on peoplecommunities

Why is economic impact not dealt with in the EIS

Miscellaneous What s the likelihood of worst-case modelling becoming irrelevant Is it likely that worst-case modelling is over predicted

Numbers of questionscomments on each topic indicative

Proposed Temporary Weir (Locks 4) 27

River flowsallocations 13

Politics Government (2 Goolwa channel) 13

Acid Sulphate Soils 5

Riverbanks 4

Lock 4

Pumping stations 3

Society and Economy 2

Wildlife 2

Miscellaneous 1

Supplementary EIS for the temporary weir near Pomanda Island -116-

Goolwa Community Information Session

Date Friday 27th March 2009 10000am 1230pm

Location Centenary Hall

Questions asked by the specialist panel listed by category

Wetlands Milang wetlands identified as number one natural resource by Adelaide University It has now been disconnected for two years Why is it not mentioned in the EIS

Will the wetlands between Lock 1 and the weir be filled How much water is needed to fill these wetlands Will the filling of wetlands result in an increase in acid

Bioremediation Are they considering bioremediation rather than building a weir

Impac t of g rasses tha t a re na tura lly g rowing on beac hes of the Lake

River flowsallocations What s being done about the wa ter supp ly

How much inflow into the River Murray in SA comes from SA compared with inflow across the VicNSW border (see figure 0-2 of the Exec Summary)

What flows would be necessary past Wellington to support a virtual weir at AHDs of -15 shy2 -25m

Will the weir be able to withstand a significant flood

How will water flow over the weir and into the Lower Lakes or will it flow through a gate underneath

How much water bypasses the weir if it is built

What will happen to the temporary weir if there is a flood Will it get washed away

Has the sc enario of three months without flow into the Lakes to fill the weir pool been allowed for in determining the trigger date of Jan 2010

Is it possible to have a shorter period where there is no flow over the weir but take a longer time to fill the weir pool

Has the government considered buying water to maintain the annual 350GL to the Lower Lakes

If the Lower Lakes are without water for three months during construction will the government purchase additional water to factor this in

Why doesn t the environment get a wa ter a lloc a tion like every other user

Why does Adelaide not have underground storage or other measures to alleviate the need for taking water from the River and hence for need of a weir

What difference would it make if we moved down to critical human needs rather than gardens and swimming pools

What is the impact of the various private and public water storages when comparing the Federation Drought and the current drought

What proportion of the Living Murray water agreement will reach the Lower Lakes (of the 500GL from 30 June 2009)

Ramsar What is the potential threat to the Ramsar status of the wetlands

Has the Wellington weir been put to Ramsar

Could building the weir lead to international action and delisting

Wildlife (Four questions on fish passage a re listed under Proposed temporary weir )

How do we consider the impact on species which are not listed under the EPBC Act These species are part of the ecosystem and food chain

Has the EIS looked at all species that will be affected eg snakes kangaroos and others

Supplementary EIS for the temporary weir near Pomanda Island -117-

Will the weir reduce flows significantly downstream and continue to adversely affect wildlife already in distress

There will be a spike in salinity in the Lake after disconnection which may lead to fish kill in certain species eg carp Fish kill will give high ammonia and low dissolved oxygen what is the impact on the other species as a result of this

Acid Sulfate Soils (ASS) What is proposed to address Acid Sulfate Soils

Acidification problem on land There are options to cover sand other than freshwater

Is the lake bed soil at Pomanda sulfuric

What does the Department anticipate will be the result of disturbing and replacing thousands of cubic metres of sulfuric soil above and below the weir

What is the problem with ASS What does it do that is so bad

When acid soils dry out does they still retain their acidity What happens when they turn to dust

What problems have Acid Sulfate Soils caused so far Why do we need to be concerned about this problem

Wha t is the government s stra tegy to c ombat the ac id and heavy metals entering the river as a result of varying levels caused by wind seiching

Salinity issues Why after Lake Alexandrina has been sucked dry should the Lake have to put up with the salt from behind the weir therefore making the Lake worse with a high salt content

What happens to the salt which normally comes down the River and flushes to the sea via the Murray Mouth

Will the weir result in a highly saline weir pool

How will the accumulated salts be flushed at the weir

How quickly can the rocks be removed if it becomes apparent that the weir pool salinity levels have unexpectedly risen to unacceptable levels If not quick enough what is the contingency plan

What is happening to water above the weir Will salinity affect Adelaide water supply

Where are the salt and other contaminants going to go once the weir is constructed

What consideration has been given to the massive mobilisation of salt that would follow heavy inflows

Has the government considered increased salinity building up behind the weir

If the weir has a long life will salinity keep rising

Won t sa lt and toxin c onc entra tion inc rease upstream of the weir

What science is there that demonstrates the mixing of saline waters in the weir pool immediately above Wellington to be kept to acceptable levels while the weir is in operation Is there any precedent of a similar scale for this mixing scale

Proposed temporary weir impacts If the weir is there for a long time what are the groundwater impacts

Why are there far more truckloads of material being put into building the weir as opposed to taking it out

What are the implications of taking the weir down

Impact of increased vehicle access on Lakes beaches on Sulfate soils dust and wildlife

How do you intend to remove the weir given it is a massive structure

How do you intend to remove the weir given it is a temporary structure

What part of the structure and sub-structure will remain after decommissioning

What are the consequences if the weir fails to withstand a flood

If the temporary weir is engaged for three years but is required for longer what would it take to remain operable for as long as it is needed

Wha t will happen a fter the end of the three years of the weir s life

Is twin lakes concept a possibility Has it been sufficiently considered

Supplementary EIS for the temporary weir near Pomanda Island -118-

What is the effect of the weir on the water ecology in the channel (downstream) Eg water rats crustaceans birds beetles etc

Is a fishway being incorporated into the design of the weir

During the period of disconnection can a tunnel be built through the weir to allow fish passage

Will the temporary weir include provision for a fish ladder

What provisions are there in the weir construction for fish ladders and other access for boating

What is the level of the weir spillway and the level of the weir pool behind it

What is the level of the weir itself

Is it possible that the temporary weir will need to be replaced by a barrage if the drought continues

Why not build a permanent weirlock rather than building a temporary weir that may need to be re-built in a number of years

How long do you expect the weir to be in place

Social and economic impacts Where do we take our concerns about economic and social impacts of the situation

Politics and government What are the budget figures of water (both temporary and permanent) How much do they expect to pay per GL

The weir won t a llow boa t tra ffic Is this aga inst the c onstitution

Is it legal to build a weir which will hold the River flow to the detriment of the Riparian rights users downstream

Is it true that Commonwealth or State Laws require the River to remain navigable

How can I use this process to promote a change to the system of governance (States sharingallocations)

How can this consultation process address over-allocation

What is being done about over-allocation

Over-allocation in other states is at the root of the problem When will governments apply sufficient pressure to deal with the shortage of water coming over the border

What is going to happen with the issue of over-allocation and theft of water upstream

Would it be better to spend money on infrastructure instead of buying back water

We need a 50 year plan to remove all man-made infrastructure in the Murray

Why doesn t the federa l government focus on new sources of water being made available For example new engineering securing water from Queensland and delivering it to northern point of Murray-Darling

Is the Murray-Darling Basin Agreement still a legal document Is it still in force

What is the federa l Minister s responsib ility to the c ommunity c onsulta tion p roc ess (Specifically relating to issues submitted to state and if they disagree with the citizen who adjudicates)

What coordination is there between different government departments

Miscellaneous Why was A Fresh Water History g iven out today To influenc e thinking

How long under the worst case scenarios will the water contained by the temporary weir remain suitable for Adelaide use

What would be the cost of shifting the uptakes above Blanchetown

How are they measuring water quality in Lake Alexandrina What about DO and temperature

What role is the rising water temperature having on the aquatic species and water quality as a whole

Will the water beyond the weir cease to be aerated as a result of the weir

How much has wind seiching been considered in the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -119-

Why has there been no consultation with community in Milang Why have they been neglected

Wha t does spend mean in rea l wa ter terms We need a bold idea

If the weir is built will the blocking banks at Clayton Finniss and Currency Creek still be needed

If the blocking banks go ahead with the weir still go ahead

If the drought continues and the weir goes in and barrages are left closed what will happen to the Lakes and Coorong

Trigger Points What will be the indication to dismantle the weir

What is defined as temporary and what are the decommissioning triggers for the weir

Lake Albert What is the future of Lake Albert

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 4 on fish-ways) 21

River flowsallocations 16

PoliticsGovernment 15

Miscellaneous (including 5 on water quality) 12

Salinity issues 12

Acid Sulfate Soils 8

Wild-life (Fishturtles) 4

Ramsar 3

Wetlands 2

Bioremediation 2

Social and economic impacts 1

Lake Albert 1

Supplementary EIS for the temporary weir near Pomanda Island -120-

Clayton Community Information Session

Date Friday 27th March 2009 400pm 630pm Location Clayton Community Hall

Questions asked of the specialist panel listed by category

Regulators Why is a regulator at Clayton for pumping to the Goolwa Channel considered above letting seawater in to it

If the Clayton Regulator is built will it protect the water quality at the pumping stations (without building the weir)

How does the function of the Pomanda Island weir relate to the functions of regulators proposed for Currency and Finniss Creeks and Clayton

Is the weir going ahead as well as regulators If so why are both necessary

With the proposed regulators will the inflows of water to the next section be regulated from the bottom of the weir or from the top ie What will happen to accumulated salt behind the weir

Why is information on the regulators only in the papers and not mentioned in this forum

Lake Albert Should the weir at Pomanda Island proceed what are the ramifications for the future of Lake Albert

River flowsallocations Has blocking off the wetlands between the weir and Lock 1 to allow water when available to run into Lake Alexandrina been considered

If the weir is installed is the initial idea to pump water into the weir pool immediately or to leave it to whatever comes in

If the water extraction cap in other states is applied in 2012 will we get any water flow to SA

What are restrictions in other States on water use

What if anything happens in other states in allocating water as NSW has no meters

How is water removed from the River tracked

How is surface diversion tracked and measured

Has there been an assessment of all water storages available to the MDB

Do we believe SA will actually be able to get more freshwater from the larger eastern states as they are also growing

Would stormwater redirection help the Murray

What is stopping us from buying more water

How can the process of buying water be sped up

Ramsar

of the Murray-Darling Basin and River mouth is of paramount importance

Wildlife Ecology of LakeRiver studies on cod too late They have been in scarce supply for a long time

Given that the Yarra Pygmy perch is in other river systems why is it included

No cod in the Lower Lakes for decades Why are they included in the draft EIS

Is a base line study into Bell Frogs too late

Has anyone looked at the effect of the weir and its repercussion on micro-invertebrates etc on whic h a ll the Lakes residents (human anima l and p lant) depend

The Coorong and La kes site is reg istered a s an interna tiona l Ramsar wetla nd Isn t the Prime Minister responsib le for p rotec ting this a rea Isn t this the b ottom line The ec ology

Supplementary EIS for the temporary weir near Pomanda Island -121-

What effect will the proposed seawater introduction have on the Lower Lakes freshwater species

Why are marine species that were prevalent before the barrages not mentioned in the EIS

What study has been done on non-river marine species threatened by not allowing seawater in as nature would have done under these circumstances

How will species not listed in the EPBC Act be addressed

Acid Sulfate Soils What is the risk of potential ASS becoming actual ASS

The Executive Summary of the draft EIS alerts to the danger of acidification of the weir pool above the weir when wetlands are flooded again Is it intended to close off the entrances to them Has there been any decision yet about exactly what the effect of covering ASS with water (salt or fresh) will be

What will happen to the wetlands above the weir when they are refilled with water Is there a danger of the water being contaminated due to acidic soils

Due to ASS and extraction for urban use it appears that the weir must be in place by mid-January 2010 Is that the case

If the weir is installed is the intention to block off back waters and lagoons below Blanchetown If so are these subject to ASS

Bioremediation Is there something groupsindividuals can do to help with bioremediation projects etc How can we be involved

Will revegetating problem areas with dust fix the problem

Salinity issues What are the impacts of salt water within CurrencyFinniss Rivers

In the introduction it was stated that salt levels in the Goolwa Channel are 20000 ppm (parts per million) I believe they are 30000 ppm Is your information up to date

What will happen to salt accumulation when the proposed temporary weir is removed

Will the water coming over the weir spillway bring the salt with it or will salt build up at deeper levels

How will the salt coming past Pomanda Island be managed with a complete blockage that has a low level spillway in shallow water east of the main River channel

Does the weir prevent salts from being flushed out to sea (ie they will be built up behind the weir)

Rainfall Has consideration been given to constructing a barrage behind the temporary weir given continuing long-term low average rain fall

Proposed temporary weir Given the EIS indicates a 3 year lifespan of the weir what is the situation if the objectives of its installation are not met

Given the criteria for removal why is the design life for 3 years only

How permanent is this weir

If a weir is built upon removal will it all be removed or will it be a narrower channel

Figure 0-4 (lake level and the -15m red line) Is this the trigger for both the start of weir building and the introduction of seawater into the Lower Lakes

In the draft EIS statement there was no mention of effect on commercial social recreational or irrigation impacts Have these been considered

What is the impact of not constructing the weir

If the weir fails to guarantee water supply to Adelaide will it be removed

How long is the temporary weir to be in place

Why is the weir going to be temporary

Supplementary EIS for the temporary weir near Pomanda Island -122-

Has any consideration been given to building a barrage not a weir at Pomanda Point and removal of existing barrages below

Why not build a permanent structure which will service us for the next 100 years

Social and economic impacts Does the EPBC Act consider social and economic issues that the weir will impact on

How is this affecting tourism throughout the Lakes

How are the social and economic impacts being understood

Seawater If we let seawater in would it be flushed out again Would it return to fresh water

Is seawater into the Lakes seriously being considered What are the strong arguments against seawater as a sustainable option for the Lakes

Have we looked at letting seawater in at similar locations in Australia eg Mantra And the effects

Are Professor Gells results for c ore sampling about historic a l seawa ter being c onsidered (in letting seawater in)

Have any studies been conducted to consider the impact of salt water entering this Lake What were the outcomes of it

What prevents the weir height to be increased to say 07AHD to permit ingress of seawater to allow sufficient depth (~05AHD) and the operation of boat ramps jetties sailing clubs and safe navigation within the Lakes

Has a desalination plant option been considered for Beach 19 Lake Albert and Cantara (Replacement of fresh water from evaporation etc)

Politics and government Why has it been left so long for the urgency of this to be recognised and acted on

If the Federal government takes control of the MDB will that make this EIS invalid

Will the d ra ft EIS need to be reviewed due to the Government s rec ent dec isions regarding the blocking banks at Finniss amp Current Creeks

How does the EPBC Act deal with long-term management of the Lower Lakes

As it impacts on matters of NES does a state territory or industry need to get approval under the EPBC Act to get current or future water extractions

Why isn t the Commonwea lth ac ting to restric t a lloc a tions more urgently

Does the construction of the weir contravene Section 100 of the Australian Constitution that gives States or people rights to use water for conservation or irrigation

Due to state environmental assessments being overridden by emergency powers how a re issues suc h as wa ter a ffec ting ac tivities and wetland management p lans add ressed in this process

Miscellaneous Why is the Murray called a river when it is a series of pools

Has the idea of an island in the middle with dredging around it been considered for Lake Alexandrina

Why were 1982 figures used when 2006 was the worst case (until now)

Can we have hope that we will get to a sustainable system and that irrigation can provide Australian food

Has sea level rise been a consideration in the draft EIS and how may this impact on the weir if built

Were there EIS studies on any of the other 4000 barriers across the Murray

Has study of other precedence areas such as Mandura been done

Would it help if we had dry toilets

What level will the Lake be allowed to come up to once the weir is in place How far below the weir will the lake level be

Why have they decided on a pool of 01AHD given that previous pool level of the whole area was at +05 to 06 (Given that top of tide is +06m)

Supplementary EIS for the temporary weir near Pomanda Island -123-

How will water restrictions apply to small farmers on the river

Why wasn t Finniss Angas Bremer etc in MDB c a tc hment a rea

Why hasn t more been done about effic ienc y improvements in wa ter use by loc a ls as well as industry and people in Adelaide and beyond

If we all collected domestic water from properties etc would it negatively impact the Murray

Why isn t Myponga used to supp ly wa ter to the Fleurieu

Why has no impact study on underground water in the Currency Finniss and lower south east region been done

Has there been a comprehensive study of ground water and surface water into the area surrounding Lake Alexandrina

Why is there no navigation pass in the weir or no provision for one in the future

What will happen to Lake Alexandrina if water is pumped out into the Goolwa channel

Once the Lake is dry how will the Clayton channel then be refilled

Trigger Points Where are the trigger points for monitoring salinity and calcium carbonates sites located

Once we reach a certain trigger level at a monitoring site is the weir removed immediately or does it have to sit at a point for a certain amount of time

Will the weir be deconstructed if one trigger point is reached or all trigger points

Wha t is the trigger point for the guaranteed dec ommissioning of the weir

What are the triggers for removing the temporary weir

If the main a im of the weir is p reserva tion of Adela ide s water supp ly why is the level of water in the Lakes the trigger point for construction of the weir rather than the ability to extract water for Adelaide Is the real reason to do with Acid Sulfate in the Lakes

What is being done now to speed up the process of water allocation

Respiratory problems Low water levels are increasing the dust levels How quickly will this be covered to tackle health issues such as respiratory problems

Are health effects of the dust being surveyed What evidence is there of this

Has research been done regarding increases in respiratory problems

Supplementary EIS for the temporary weir near Pomanda Island -124-

Numbers of questionscomments on each topic indicative

Miscellaneous 20

Weir construction impacts 12

River flowsallocations 12

Wildlife 9

PoliticsGovernment 8

Sea water 7

Trigger Points 7

Regulators 6

Salinity 6

Acid Sulfate Soils 5

Social and economic impacts 3

Respiratory problemshealth 3

Lake Albert 1

Ramsar 1

Consolidated list of question topics from all Community Information Sessions

River flowsallocations 50

Weir construction impacts 47

Politics amp Government 39

Miscellaneous 37

Proposed Temporary Weir 27

Salinity issues 24

Acid Sulfate Soils 21

Wildlife 19

Seawater 10

Social and economic impacts 9

Lake Albert 7

Ramsar 7

Regulators 6

Trigger Points 7

Lock 4

Riverbanks 4

Pumping stations 3

Rainfall (Lake rain) 3

Respiratory problemshealth 3

Wetlands 2

Bioremediation 2

Supplementary EIS for the temporary weir near Pomanda Island -125-

Graph of consolidated question topics from all Community Information Sessions

All CIS Questions Summary

0

10

20

30

40

50

60

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Miscel

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Prop

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Tem

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)

Salin

ityiss

ues

AcidSu

lfate

Soils

Wild

life

Sea

water

Socia

l and

econ

omic

impa

cts

Lake

Albe

rt

Ramsa

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Regul

ator

s

Trig

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ints

Lo

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Riverb

anks

Pum

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Rainfa

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Respir

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Bior

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Supplementary EIS for the temporary weir near Pomanda Island -126-

Appendix VI Advertising copy used in the consultation process

Date Thurs 12th March 2009

The Australian

The Victor Harbor Times

The Advertiser

The Southern Argus

The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -127-

Supplementary EIS for the temporary weir near Pomanda Island -128-

Date Thurs 12th March 2009

The Australian The Victor Harbor Times

The Advertiser The Southern Argus The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -129-

Supplementary EIS for the temporary weir near Pomanda Island -130-

Public Release Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island Email Update Sent 12th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -131-

Public Release Amended Draft Environmental Impact Statement for the

proposed temporary weir near Pomanda Island Email Update Sent 17th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -132-

Public Release Reminder re lodging submissions - Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 1st April 2009

Supplementary EIS for the temporary weir near Pomanda Island -133-

Public Release Submissions due 9 April 2009 Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 6th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -134-

Public Release Consultation period for draft EIS closes Draft Environment

Impact Statement for the proposed temporary weir near Pomanda Island

Email Update Sent 15th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -135-

CD Pack Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island

Supplementary EIS for the temporary weir near Pomanda Island -136-

Executive Summary

Supplementary EIS for the temporary weir near Pomanda Island -137-

Distribution of draft EIS Executive Summaries and CDs

Organisation Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Alexandrina Council 2 2 5 45 50 Coomandook Community Library

1 0 20 20 1

Coorong District Council 2 2 5 45 50 DEWHA library 2 2 5 5 Goolwa Public Library 1 50 50 1 Meningie Community Library 1 30 30 1 Milang Old Schoolhouse Community Centre

1 50 50

Mount Barker Community Library

1 20 20 1

Mt Barker Natural Resource Centre Mt Compass Library

1 20 20

1 Murray Bridge Library 1 Murray Bridge Natural Resource Centre

1

Rural City of Murray Bridge 2 1 National Library of Australia 2 Port Elliot Library 1 State Library Adelaide 2 1 Strathalbyn Community Library 1 Strathalbyn Council Office 2 Strathalbyn Natural Resource Centre Tailem Bend Community Library Tailem Bend Office of Coorong District Council Tintinara amp Coonalpyn Community Library Tintinara Office of Coorong District Council Victor Harbor Natural Resource Centre

1

5 5

20 20 1 30 30 1

30 30

95 100 5 5 30 30 1 50 50 50 50 1 30 30

30 30

1 30 30 1

1 30 30

1 30 30 1

1 30 30

1 30 30

Victor Harbor Public Library 1 30 30 1 Willunga Environment Centre 1 30 30 CLLMM Project Team 2 2 40 20 Mapland (DEH) 2 2 5 45 50 Meningie Community Information Session

200 100

Murray Bridge Community Information Session

200 100

Clayton Community Information Session

200 100

Goolwa Community Information Session

200 100

Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 SA Government Ministers Hon Mike Rann MP Premier Minister for Economic Development Minister for

1

20 20 20

20 20 20 10

2

10

2

Supplementary EIS for the temporary weir near Pomanda Island -138-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Sustainability and Climate Change Hon Paul Holloway MLC Minister for Urban Development and Planning

1 2 2

Hon Jay Weatherill MP Minister for Environment and Conservation

1 2 2

Hon Paul Caica MP Minister for Agriculture Food and Fisheries Minister for Regional Development

1 2 2

Hon Gail Gago MLC Minister for StateLocal Government Relations Hon M OBrien MP Minister for Employment Training and Further Education Hon T Koutsantonis MP Minister for Correctional Services Hon J Rankine MP Minister for Families and Communities Hon M Atkinson Attorney-General Hon M Wright MP Minister for Police Hon John Hill MP Minister for Health

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

Hon Kevin Foley MP Treasurer Minister for FederalState Relations

1 2 2

Hon Jane Lomax-Smith MP Minister for Tourism

1 2 2

Hon Patrick Conlon MP Minister for Transport Energy and Infrastructure

1 2 2

Hon Karlene Maywald MP Minister for the River Murray Minister for Water Security

1 2 2

Shadow Ministers Martin Hamilton-Smith MP 1 2 2 Adrian Pederick MP 1 2 2 Mitch Williams MP 1 2 2 Aust Govt Ministers Minister Penny Wong 1 2 2 Minister Peter Garret 1 2 2 SA Parliamentarians Parliamentary Leader SA Greens - Mark Parnell

1 2 2

Parliamentary Leader SA Democrats - Hon Sandra Kanck MLC

1 2 2

SA Parliamentary Library 1 1 Chief Exec DEH - Allan Holmes 1 Chief Exec EPA - Helen Fulcher 1

5 2 2

5 2 2

2Chief Exec DWLBC - Scott Ashby Chief Exec DTED - Brian

1 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -139-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Cunningham Chief Exec DTEI - Jim Hallion Chief Exec SA Water - Anne Howe Chief Exec DPC - Chris Eccles 1 2 2 Chief Exec DPLG - Ian Nightingale

1 2 2

Chief Exec PIRSA - Geoff Knight

1 2 2

Chief Exec DTF Rob Freeman 1 2 2 Dr Tony Sherbon 1 2 2 Mr Dean Brown 1 1 Mr Simon Stretton 1 2 2 Mr Sean Berg 1 2 2 CLLMM Steering Cttee 8 8 8 CLLMM Project board 4 4 4 Conservation Council of SA -Julie Pettett

1 2 5

Spares 2 2 500 500 92 15 25 2410 2012 11

Hard Copy Append CD Exec Sum CD Ordered 140 20 0 2500 2000

1 2 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -140-

Web content

Supplementary EIS for the temporary weir near Pomanda Island -141-

Supplementary EIS for the temporary weir near Pomanda Island -142-

Supplementary EIS for the temporary weir near Pomanda Island -143-

Fact Sheet

Supplementary EIS for the temporary weir near Pomanda Island -144-

Supplementary EIS for the temporary weir near Pomanda Island -145-

Appendix VII Media generated by the consultation process

Radio 12012009 410 PM ABC North amp West SA (Port Pirie) Late Afternoons - Kieran Weir Interviewees Michael Pengilly Liberal Member for Finniss Duration 10

18 01 2009 850 AM 5AA (Adela ide) Mic hael Keelan s Weekend - Michael Keelan Neil Humphrys amp June Taylor Interviewees Simon Birmingham South Australian Liberal Senator Duration 710

8012009 954 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 025

Newsreader News Director Ms Monique Crichton Duration 014

8012009 603 AM Triple M (Adelaide) 0600 News

8012009 1212 PM 5AA (Adelaide) Mornings - Mike Smithson Interviewees caller Jeff Mike Rann SA Premier Duration 1133

8012009 731 PM 5AA (Adelaide) Matthew Pantelis - Jeff Burzacott Interviewees Caller Robyn Duration 1605

8012009 1127 AM ABC 891 Adelaide (Adelaide) The Soapbox - Sonya Feldhoff Interviewees Michael Pengilly Member for Finniss Duration 328

8012009 1212 PM ABC North amp West SA ABC North amp West SA (Port Pirie) SA Country Hour -Annabelle Homer Interviewees Senator Sarah Hanson-Young Australian Greens SA Duration 415

8012009 100 PM ABC 891 Adelaide (Adelaide) 1300 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Martin Hamilton-Smith SA Opposition leader Mike Rann SA Premier Duration 119

8012009 600 PM ABC 891 Adelaide (Adelaide) 1800 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Duration 033

9012009 632 AM ABC 891 Adelaide (Adelaide) 0630 News - Newsreader Interviewees Arlene Buchan Australian Conservation Foundation (ACF) Duration 036

9012009 704 AM ABC 891 Adelaide (Adelaide) 0700 News - Newsreader Interviewees Arlene Buchan ACF Duration 050

3022009 1003 AM ABC 891 Adelaide (Adelaide) 1000 News - Newsreader Interviewees Karlene Maywald SA Minister for the River Murray Duration 046

12032009 830 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 017

12032009 521 PM ABC North amp West SA (Port Pirie) Late Afternoons - Annette Marner Interviewees Caller Tom Karlene Maywald Minister for Water Security

Supplementary EIS for the temporary weir near Pomanda Island -146-

Duration 847

13032009 809 AM 5AA (Adelaide) Pilkington amp Conlon - Tony Pilkington amp Keith Conlon Interviewees Karlene Maywald SA Minister for the River Murray and Water Security Duration 628

13032009 840 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan - live from Goolwa Interviewees Prof Diane Bell Resident and former Federal independent candidate for the Seat of Mayo Duration 239

13032009 910 AM 5AA (Adelaide) Mornings - Mike Smithson Interviewees Senator Sarah Hanson-Young Australian Greens Party Duration 612

13032009 1024 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan Interviewees Clem Mason Lower Lakes and Coorong Infrastructure Committee Lesley Fisher Lower Lakes and Coorong Infrastructure Committee Duration 923

13032009 1105 AM ABC 891 Adelaide (Adelaide) The Soapbox - Matthew Abraham and David Bevan live at the Goolwa Sailing Club Interviewees Dean Brown Premiers Special Drought Advisor Robyn McLeod SA Independent Water Commissioner Duration 603

31032009 835 AM ABC North amp West SA (Port Pirie) Morning Show - Kieran Weir Interviewees Dr Jochen Kaempf Oceanographer Senior Lecturer Flinders Uni Duration 1136

Television 8012009 600 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Martin Hamilton-Smith SA Opposition leader Peter Garrett Federal Minister for the Environment Rory McEwen Acting Water Minister Senator Sarah Hanson-Young Australian Greens Party Simon Birmingham Liberal Senator for SA Duration 135

8012009 601 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Henry Jones fisher Jock Veenstra tourism operator Kym McHugh Mayor Alexandrina Michael Smyth Channel 9 reporter Duration 200

12032009 516 PM Channel 10 (Adelaide) TEN News - George Donikian and Rebecca Morse Interviewees Karlene Maywald Water Security Minister Mark Parnell Australian Greens Martin Hamilton-Smith SA Opposition leader Duration 147

Print media PG227 13 March 2009 The Hon Peter Garrett MP Minister for the Environment Heritage and the Arts Final terms of reference for Barrage EIS httpwwwenvironmentgovauepbcnoticesassessmentslower-lakeshtml Stock Journal 19032009 p 8 General News Adelaide Advertiser 14032009 p 27 General News Lakelander 27032009 p 9 General News Stock Journal 19032009 p 12 General News Stock Journal 19032009 p 16 Letters Times Victor Harbour 19032009 p 1 General News Murray Valley Standard 19032009 p 4 General News

Supplementary EIS for the temporary weir near Pomanda Island -147-

Appendix VIII Summary information of enquiries and

submissions for provision of the proposed temporary weir

Summary information

Number of phone calls to EIS hotline 52 Number of emails to eisdehsagovau from unique individuals 82 Number of feedback comments on the CLLMM website 14 Number of subscriptions to e-newsletter via the CLLMM website 48 Number of Community Information Session registrations on the CLLMM website 47

Number of submissions received by email 61 Number of submissions received by letter 9 Total number of submissions received 70

Number of unique visitors to the CLLMM website 1588 Number of visits to the CLLMM website 2834 Number of page views on the CLLMM website 9343

Supplementary EIS for the temporary weir near Pomanda Island -148-

Submission Summary

Mr Roger Cooke The writer proposes a major scheme which aims to simultaneously drought-proof the Murray-Darling Basin and to meet 2020 emissions targets Features of the scheme include - Laying concurrently gas and water pipelines from the NW Shelf to major centres including SA mining towns and Adelaide - Laying irrigation pipes to replace open channels a financial stimulus package - Piping LNG to replace coal-fired energy production assisting Australia to meet 2020 emissions targets The submission outlines a national water distribution scheme as well as a proposal for creating a river channel in order to prevent evaporation across the Lakes while maintaining a freshwater channel The writer proposes a scheme for a long-term solution to the Lower Lakes The writer suggests a permanent weir is necessary as drought will increase in severity and frequency The proposed scheme would aim to reduce evaporation occurring over the Lakes by creating a channel from a proposed permanent weir to the barrages The writer suggests benefits to the Coorong mitigation of Acid Sulfate Soils a freshwater environment for boating while p rotec ting Ad ela id e s wa ter supp ly

Mr Michael Galea Argues there are too many unquantifiable risks associated with the proposed weir and freshwater is needed now The writer bases the submission on local knowledge and common sense He reports the awesome impact of low water on many plants and animals in recent years in the vicinity of Clayton Bay He expresses concern that a weir will pool polluted water upstream and the saline spike will kill tens of thousands of carp and pollute Lake Alexandrina

Mr Philip Fargher The writer is keen to see base environmental River flows established through the use of Commonwealth Government powers The writer outlines established processes of River flooding which periodically flushed out saline water from the Lower Lakes and Coorong Changes to the system due to locks allocations irrigation and the barrage are noted Seawater flooding of the Lakes is thought to lead to negative and unpredictable results as tidal exchanges are insufficient Acid Sulfate Soils require freshwater flows or peripheral lime sand

Mr Andrew Zoerner The writer is concerned that a freshwater environment in the Lower Lakes will not survive unless a Lock is built east of Clayton as well as a water pipeline from Wellington The aim is to maintain freshwater around Goolwa Hindmarsh Island and Clayton for environmental cultural historical industrial recreational and tourism reasons while preserving local flora and fauna

Mr Douglas Smith The submission has nine points The author seeks clarification identifies gaps and expresses points of view The author asks that the definition of sea level and salinity measures are clarified He notes that ferry operations are

Appendix IX Table of submissions

The table below provides a summary of submissions received during the public consultation period An electronic copy of the submission can be located on the DEH website httpwwwenvironmentsagovaucllmmtemporary-weirhtml

Submission no

PTW00001

PTW00002

PTW00003

PTW00004

Submission from

PTW00005

Supplementary EIS for the temporary weir near Pomanda Island -149--

Submission no

Submission from Submission Summary

not discussed under the do nothing option and notes that the difficulties of decommissioning a weir are understated He notices that there is no discussion of management of blue green algal blooms above the temporary weir

PTW00006 Ms Melanie Rees The author argues that efforts to mitigate negative impacts of a proposed temporary weir are grossly inadequate and any amendments envisaged to the draft EIS will not make the weir development acceptable Threats to species and communities are not adequately addressed or are downplayed or discountedThe author indicates concern about the lack of genuine community consultation and argues that the weir development should be considered with other developments because there are cumulative impacts She expresses points of view on public understanding of pertinent issues drought the importance of cost benefit analysis and suggests changed wordings The author suggests investigating filling reservoirs and drawing from them while relocating pumping stations She suggests that stormwater statistics are inaccurate and recommends increasing stormwater harvesting to alleviate reliance on the River Murray The author provides detailed information about the Southern Emu-wren noting Draft EIS information is out of date Gaps are identified in that phytophthora impacts are not considered at the weir building site and the impact of a weir on Callop fish is not discussed

PTW00007 Mr John Clark President Southern Alexandrina Business Association Inc

This submission puts a case for an alternative to the proposed temporary weir near Pomanda Island SABA argues for a permanent lock (Lock 0) in the vicinity of Tailem Bend SABA refers to Gell et al and notes the estuarine but predominantly freshwater environment of the Lower Lakes A navigable lock with a fishway would support the ecology and recreational fishing and boating (boating valued at $200m pa) and meet water security objectives SABA argues that climate change increases the logic of a permanent Lock 0 Supports remediation and revegetation where appropriate and seawaterif needed to check Acid Sulfate Soils

PTW00008 Mr Mike Brisco This submission draws on authoritative literature on climate change The author argues that the weir is proposed in an inadequate context that is the context of severe drought in south eastern Australia The proposed weir should be located in other scenarios - especially for example that of rapid climate change In the event that the weir needs to remain in place projected sea level rises need to be considered in its design The main point is that the impacts of the proposed weir cannot be understood in an inadequate context An additional chapter is suggested Other detailed suggestions are made for changes to the draft These changes show more dramatic water security issues than currently documented in the draft EIS (for example diminished run off over time into Adelaide water storages)

PTW00009 Mr Ian Moyle The writer has lived and worked at Narrung and has lasting educational and environmental interests in the Lakes and Coorong He is c onc erned b y governments lac k of acknowledgement of climate change and previous poor water management He urges the state government to get serious about collecting and using rainwater and grey

Supplementary EIS for the temporary weir near Pomanda Island -150shy

Submission no

Submission from Submission Summary

water re-use PTW00010 Ms Jan Meek

Secretary Signal Point Riverine Environment Group Inc

The group believes a weir willl become permanent and that a revised draft EIS should be prepared based on this premise There are seven issues of concern listed Gaps and lack of clarity in the draft EIS are identified The group indicates - that species rescue outside the Ramsar boundary is unacceptable and that the EIS needs to include species impact statements on a range of species - that an impact of a weir will be increased salt discharge salt interception schemes or mitigation measures need consideration - weir removal triggers are unrealistic and imprecise and out of the control of the SA Government

PTW00011 Mr Richard Harvey

PTW00012 Ms Sally Richards

The writer has a long association with the Coorong and Lower Lakes He indicates his opposition to any seawater incursion In relation to the weir he understands that in the order of 500 tonnes of salt a day would build up This would impair water piped to Narrung The writer urges strong action by Federal Government to reverse over-allocation The writers submission is informed by her residence in the Finniss Catchment and membership of the Finniss Catchment Group Points made by the writer include - more freshwater in the river system - over-allocation and poor management of water continues today - for example in the Finniss catchment where there is no Water Allocation Plan - system wide over-allocation must be addressed - more species than those listed in the draft EIS should be considered - the weir will have impacts beyond the weir site The writer advocates working with community and nature and and disallowing XXXXXXX water supply control (company not named for legal reasons)

PTW00013 Mr Trevor Giles

PTW00014 Ms Brenda Lower

The writer has very extensive experience living and working as a primary producer in the Langhorne Creek District and has a strong attachment to the Lower Murray Region He notes the lack of freshwater will lead to habitat loss and that all water supply proposals are interconnected All projects together are an overall threat to the environment Other concerns include - the bund at Narrung Narrows and proposed regulators prevent wind seiche - lack of consideration of groundwater - no fishway inclusion - the unsuitability of the weir site Freshwater is the only viable solution to retaining habitat The writer is concerned about the river and the people of the district and she asserts that water is needed now The author notes negative impacts of increasingly saline water on turtles birds and fish and is concerned about sulfidic soils and human health The author favours a permanent weir and seawater incursions to cover soils

PTW00015 Mr Frederick Gordon Michelmore Farmer

The author is concerned by the increasing salinity in the Lakes He suggests spending 10 of the cost of the weir on increasing rainwater capture from roofs Other sources of water must be found because the river can not keep up with demand

Supplementary EIS for the temporary weir near Pomanda Island -151shy

Submission Summary

Ms Ann Lucas The writer is concerned about previously estuarine areas between the Murray Mouth and Beacon 19Goolwa Barrage which are an important habitat for migratory birds It is suggested freshwater is accessed for the area in order to return it to estuarine conditions - possibly through the use of an inexpensive Desal plant

Mr Glen Jones General Manager Boating Industry Association of SA Inc (BIASA)

Points on matters of national environmental significance relating to the EIS no comment Concerns - BIASA would have liked to see provision for boating

ac c ess (a vessel loc k ) through the weir - the greatest concerns of BIASA are for both the natural environment and the declining economic viability of many businesses and communities along the River Murray downstream from Lock 1 and in the CLLMM region - concerns are for both the immediate situation and the longer term The submission documents the broad membership of BIASA the operation of BIASA and the organizations with which it liaises and for which it provides advice The submission documents financial losses being incurred (economic losses $ figures) as a result of low water levels and low water flows The cost of repairing river bank slumping and impact on ferry services and nearby communities are mentioned The impact of low water levels and low water flows in the CLLMM on social and health wellbeing of communities and jobs in boating and tourism businesses is documented in some detail and discussed The submission supports the immediate construction of a weir

Mr John Coombe Chief Executive Alexandrina Council

Points on matters of national environmental significance relating to the EIS - concern about the future health of the Ramsar protected areas - concern about the lack of fish passage between Lake Alexandrina and the River Murray and vice versa Concerns - most concerns are based on the premise that the weir will reduce water flows into the CLLMM region however this will be temporary only (90 days) - potential for unknown andor unforeseen impacts of building a weir on biodiversity and water quality both upstream and below the proposed weir - the biodiversity of the CLLMM region is dependent on freshwater for survival and is getting insufficient freshwater - infestations of tubeworms and other pests have the capacity to impact on biodiversity including turtles (not currently listed under EPBC Act) - health problems caused by excess dust from dry lake bed areas - increased impact of environmental condition on social and economic wellbeing of the region Suggestions building of a lock upstream is preferred because it will allow fish passage and boating access up and downstream

Mr Derek Fenton Points on matters of national environmental significance relating to the EIS No specific points were raised but a concern was expressed about impact on other species which are not listed under the EPBC Act

Submission no

PTW00016

PTW00017

PTW00018

Submission from

PTW00019

Supplementary EIS for the temporary weir near Pomanda Island -152shy

Submission Summary

Concerns the main concern is for lack of water for environmental flows in the River Murray in the CLLMM area

PTW00020 Ms Vesper Tjukonai Points on matters of national significance relating to the EIS not addressed except to say that in Ngarrindjeri traditional thinking animal bird and fish species (part of Ruwe) are not separated as in Chapter 13 but considered in an integrated way Concerns - questions the thoroughness of consultation with Ngarrindjeri Traditional Owners - impact of declining quality of river systems on humans (especially Ngarrindjeri in this case) - construction of weir would reduce water flows available for the Ngarrindjeri - continuing noise nuisance from pumps at Narrung Narrows pumping especially low frequency noise (health problem) - lack of clarity of the relationship between the Narrung Narrows bund the proposed weir and the future need for pumping at Narrung Narrows - potential health impacts of dust from the exposed edges of drying lakes - there could be increased pumping in summer and autumn at Narrung Narrows if the weir is built - current restriction of activities including collection of traditional foods basket making and others - soc ia l imp a c ts of the d rought a nd inappropriate water

hoard ing and fa rming method s Suggestions - Include the Ngarrindjeri Nation as Traditional Owners of the CLLMM region in the Draft EIS Executive Summary and Draft EIS Fact Sheet - Refer to Ngarrind jeri as Nation and Trad itiona l Owners - Go beyond consultation to partnership with traditional owners in planning and management - Consideration of impact of the drought and water quality situation on humans (Ngarrindjeri Nation and the wider community)

PTW00021 Mr Keith McFarlane

Background local landowner along Lake Alexandrina (family since 1845) cattle production irrigation Points relating to matters of national environmental significance EIS - Mr McFarlane says that the CLLMM is the most important part of the MBD and that river flows must be allowed for environmental maintenance as the highest priority - He is concerned that increased salinity below lock 1 caused by building the weir will be disastrous for the Ramsar-listed wetlands - He is also concerned that mud disturbance around the weir site during construction would turn the water saline and impact on all fish species Mr McFarlane does not support the building of the temporary weir at Pomanda Island The closure of wetlands along the River Murray is supported as long as there is periodic re-wetting Additional concerns Mr McFarlane is concerned that the seasonality of wind direction and speed across Lake Alexandrina may not have been taken into account when the modelling was done and that SW winds in winter and spring will counteract river flow such that river salinity will

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -153shy

Submission no

Submission from Submission Summary

build up more quickly than has been suggested in the draft EIS Suggestions - that Acid Sulfate Soils have not been a problem to date and could be counteracted in future by seeding into exposed areas - it is not necessary to keep the Lakes up to pool level in drought because the Lakes will present a smaller surface area for evaporation reducing amount of water lost - establishment of more rainfall recording stations around the Lower Lakes region to improve the accuracy of data used in modelling

PTW00022 Mr Tom Chapman Director The Marina Hindmarsh Island

Points relating to matters of national environmental significance EIS - the weir would reduce (economic and) environmental activities of the LLMM region - suggests that a fishway should be included in the weir Support the submission supports the proposed weir as a last resort but argues that a permanent lock between Tailem Bend is a better solution He views the weir as a high cost item to build and maintain as well as not allowing boating access between the Lakes and the River Concerns Mr Chapman is very concerned about the impact of lack of boating access through the proposed weir and the consequent negative impact on economic activity in the LLMM region especially on the recovery of boating but not necessarily limited to boating Perspective a worst case scenario and the weir might not be removed for a considerable time (many years) Alongside this he also supports the introduction of seawater into the LLMM and makes points about historic and current salinity levels in the LLMM

PTW00023 Mr Tony Read The author argues that there is no compelling evidence to build a weir He indicates that long-term investments are required for long-term solutions A short and a long-term solution exist The author refers to research into aquifers beneath the Adelaide Plains and provides a reference He indicates that groundwater bores can be increased quickly if necessary and argues that brackish bore water can be desalinated more cheaply than seawater He makes a case for a long-term solution that is the Twin Lakes concept He notes that the partial weir options do not support any argument to build a weir

PTW00024 Mr Mick The writer supports building a weir He notes that people upstream are suffering He is concerned about evaporation losses

PTW00025 Ms Anne Hartnett Points on matters of national environmental significance relating to the EIS - this EIS is only a partia l doc ument bec ause there a re many interrelated interventions occurring in the CLLMM region a single holistic EIS should be put together covering all of the interventions - the site of the proposed temporary weir is at or near a biodiversity hotspot as pointed out in Appendix 15 and was this considered when the site was chosen - potential for release of metals (including heavy metals) from sediments by acidification and associated ecological impacts are unknown

Supplementary EIS for the temporary weir near Pomanda Island -154shy

Submission no

Submission from Submission Summary

- the potential threat of blue-green algal outbreaks and the associated impact are not addressed sufficiently - concern that the honouring of international biodiversity agreements is not a high priority (migratory birds Ramsar wetlands) - an apparent inconsistency in that -15 m AHD is proposed as the trigger level for building a weir and is also the point at which Acid Sulfate Soil risk increases substantially yet the water level after building a weir

will drop below this to -167 m AHD concern that the scenario from here might need to include seawater introduction into the lakes and there is no EIS relating to this possible intervention Concerns - the size and therefore the impact of mud waves generated during the construction of the proposed weir are unknown - the lack of information on rates of acidification and lack of chemical analysis of the sediments and the potential for release of heavy metals upon acidification - cutting off the river from the Lake by building the weir leading to loss of the aerating wind seiche effect - if there are low water flows over the weir in future what will be the impact on water salinity levels upstream - has sought clarification on the cost of engineering solutions but not received information Expresses supports for 10 other submissions Suggestion - proposes that the money that would be spent on all interventions and engineering solutions be used instead to buy water for environmental benefit as well as human consumption

PTW00026 Ms Judy Goode River Murray Environment Manager SAMDB NRM Board

The SA MDB NRM Board agrees the weir should only be built when all other solutions have been exhausted The submission argues in detail and with reference to EPBC-listed species and numerous other species that a fish passage is required to support migration of species upstream and downstream and to support upstream movement as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river Upstream wetlands The submission asks for consideration of the environmental impacts of re-filling wetlands and potential impacts of Acid Sulfate Soil mobilising into the river The submission indicates inadequate measurement of water savings from wetland closures in Section 434 There is an unquantified assumption about the prevalence of the Southern bell frog in Section 1310 which requires consideration Water qualitywater quantity impacts A significant omission is identified in that salinity impacts are not modelled over three years The weir pool above the weir will be relatively small and the impact of wind seiche in the pool is not understood Additional modelling is sought for acid release from acid

Supplementary EIS for the temporary weir near Pomanda Island -155shy

Submission no

Submission from Submission Summary

soils metals release increased nutrient loads blue-green algal outbreaks increased sedimentation and turbidity increased temperatures fish and other biota kills odour dissolved dust fuel and oil spills Further modelling on a range of scenarios Impacts of construction The weir site is at a junction of the Lake and River and is a biodiversity hot spot A more comprehensive explanation of the choice of this weir site is required Technical issuesmore details which require more consideration What are the environmental impacts of sourcing the weir building materials SA Planning justification in writing for exemption under the Development Act Environment and Construction Management Plans How do all the costs which would be included in a properly constituted business plan compare to the potential purchase of water (for a freshwater solution)

PTW00027

PTW00028

Mr Alexander Whitehead Hindmarsh Island resident

Supports the building of a weir at Pomanda Island Also suggests that regulators not be built in the lower reaches of the river and that seawater be allowed into the Lakes

Prof Peter Fairweather Professor of Marine Biology School of Biological Sciences

Background Research Associate and Prof of Marine Biology Flinders University Points on matters of national significance relating to the EIS - the submission raises a number of concerns about the adequacy of the geographic scope of the EIS the treatment of different types of aquatic habitat the use of averages in modelling and several other points listed below Concerns - there is a concern about gaps in the EIS relating to factors that drive ecosystem change the submission questions whether maxima minima and seasonality rates of change have been considered in addition

to average values as these are important - argues that the Coorong and Lake Albert will be affected and should therefore be included in the EIS - questions whether the impact of a weir really is insignificant relative to the effects of drought - questions the reliability of modelling for years 2 and 3 and suggests that more caution should be used in interpretation towards the end of the period - that there is a gap in the EIS in the treatment of aquatic habitat types such as the benthos and the water column - that the different models appear to use different weather sequences to predict outcomes for the same sets of years and that more attention should be given to variation as a result of different weather sequences The authors are not opposed to the need for or construction of a weir but argue that the accuracy of the EIS needs to be improved in relation to several matters of national environmental significance Other points raised The legibility of many Figures in the EIS was not adequate A comment about bird species discussed in 142 and 143 and whether these are the correct or appropriate species

Mr Robert Thomas Points on matters of national environmental significance relating to the EIS none

PTW00029

Supplementary EIS for the temporary weir near Pomanda Island -156shy

Submission no

Submission from Submission Summary

Concerns - concerned about health problems relating to lowered Lake water levels (dust) Supports the construction of a weir at Pomanda Island Suggestions - not to build the regulators around the lower reaches of the River and allow seawater into the Lakes - as a longer term solution suggests the building of a barrage with a lock at Wellington

PTW00030

PTW00031

PTW00032

PTW00033

Ms Barbara Carroll Native Foods amp Plants

Confidential submission

Mr Henry Jones Commercial Fisherman Boating Industry Association

The writer is a commercial fisherman He and his family have been in the Coorong Lower Lakes and Murray Mouth commercial fishing industry for six generations The industry in the area has achieved a number of significant firsts in sustainable fishery management The author now feels ashamed for the following reasons - the extinction of species - the dredging of the Murray Mouth - the death of two thirds of the Coorong - the changing from estuarine to marine of the remaining third of the Coorong - the change from once busy bustling wetlands to a sandy wind-blown desert - the exposure of Acid Sulfate Soils - the pain inflicted on our native animals especially the pain and death of turtles - the slow death of native water rats deprived of habitat - the death of small Lake birds who no longer have their sustaining habitat - the tonnes of dead mussels invertebrates and macro invertebrates - the Government blaming drought rather than providing environmental flows The writer submits that a weir will cause major fish kills and further environmental decay

Ms Gloria Booker Manager Development amp Environmental Services Rural City of Murray Bridge

The submission points out that there was insufficient time for Elected Members and the Council to provide formal comment The Murray Bridge community may receive aesthetic and environmental benefits from raising the River level but this should not be to the detriment of native wild life and migratory birds Points made include - the weir is a last resort in ensuring water for critical human needs - ecological damage is not irreversible - the proposed weir is of sufficient height to prevent salinity moving upstream from Wellington - professional fishermen are provided with access to Lake Alexandrina - the location of pumps does not allow salt water to be washed back into the river - consideration be given to allowing river craft and fish to move from the River to the Lake

Mr Chris Bagley Dryland Farmer

Points on matters of national environmental significance relating to the EIS - the Draft EIS carries no mention of the highly regarded and important Milang Snipe Sanctuary Concerns

Supplementary EIS for the temporary weir near Pomanda Island -157shy

Submission no

Submission from Submission Summary

- that SA water planning focuses too much on consumption - that the Draft EIS indicates that only 50 of the weir material is to be removed a the end of its life and that this is not acceptable - that there may be a weir collapse with associated impacts due to the nature of the base material Suggestions - the a uthor strong ly suggests tha t Dilution Flow be

rep lac ed by the c onc ep t of Maintena nc e Flow with a rationale and that MDB management should focus on this - that the Draft EIS focuses on a base flow of 350GLyear past Pomanda Island he suggests that other scenarios and their impacts also need to be considered including zero flow 700GLyr and 2000GLyr - the author supplies a water resource report for the MDB (Mar 09) and proceeds to argue that SA can buy environmental water to save the Lower Lakes without building the weir and for 25 less cost than weir

construction and removal a set of Tables outlining water purchases over the next 3 years is presented

PTW00034 Ms Liz Yelland General concerns are expressed about the draft EIS It fails to concentrate on all species and acknowledge interdependency It fails to persuade that sufficient water will overspill the weir into the Lake No or insufficient water could result in Carp dying and then all Lake life dying Suggests that the proposed temporary weir EIS should be considered with a seawater incursion EIS In relation to chapter 10 the author is concerned that Weir construction will signal to upstream river management that there is no need to provide water to replenish the Lakes as it evaporates Ch 10 is not predicated on the view that there is already an environmental emergency further endangering international treaty sites - Political will addressing over-allocation can save these wetlands - The author expresses concerns about Goolwa Channel and Finniss and Currency Creek regulators - Questions why so little attention is given to the Coorong Comments on Ch 5 - The writer provides an image of childrens Lego sinking in porridge - Local knowledge and draft EIS Appendix 6 are referred to as the author makes the case for the difficulty of establishing the weir at the designated site Comments on Ch 11 - Asks the question what is the possible effect of cutting off the seiche surges of water from Lake Alexandrina into the lower reaches of the River Murray - Local knowledge of seiching is provided which indicates that the River beyond Murray Bridge during times of very low flows has been oxygenated and saved - Also during low flow periods the seiche and wind variations allows salinity and pollution burden to be transported to the Murray Mouth Should seiching be interrupted increasing salt build up causes flocculation of clay particles suspended in the River Conditions then support the possibility of blue-green algae blooms

Supplementary EIS for the temporary weir near Pomanda Island -158shy

Submission no

Submission from Submission Summary

- The author is sceptical that temperature inversion will mix salt to an extent which allows low flow to transport it away - Negative effects of seiching - Salinity build up since 2002 is described (reference provided) - Acid A graph is provided with detailed interpretation of wind salinity water levels and pH The author concludes that generally wind seiching has positive outcomes and that acid is not showing signs of being a problem and salinity could be managed by intermittently ceasing pumping - Concerns about mobilising acid upstream from the weir in wetlands which have been cut from the River Comments on Chap 16 - It is the author s view tha t the EIS implies a n ac c ep tanc e of an unacceptable environmental collapse which shames country and governmentThe weir is an enormous gamble due to the possibility of the weir sinking that construction methods will be ineffective and there are probable unexpected consequences

PTW00035 Mr Lynton Vonow Points on matters of national environmental significance relating to the EIS - the EIS is deficient in that it is not presented as part of an integrated plan for the region and its water and environmental problems - potential impact of building a weircompared to only

having the sill a t the entra nc e to Lake Alexa nd rina a t Pomanda on fish eg Murray Cod Concerns - that the environmental impacts of permanent weirs along the River Murray are severe and the temporary weir poses a similar risk - that the weir would increase the likelihood of blue-green algal blooms in the river upstream of the weir (and associated risk to drinking water supply) - that the salinity spike that would occur in the water near Pomanda Island after construction of the weir would be very detrimental to long-necked tortoises through the negative direct impact of tubeworms which are salt-tolerant Suggestions - that better alternatives to building a weir are (a) purchasing water (b) increasing water harvesting in the metropolitan area of Adelaide (c) relocation of pumping stations to upstream of Lock 1 and that increasing the storage at Mt Bold reservoir has significant problems including negative environmental impacts - that as the Lake levels drop the problem of wind seiching of saline water into the river will decrease - that acid Sulfate Soils are not as serious a problem as was predicted - that allowing seawater into the Lower Lakes would be very destructive The author supports the submissions of 17 other people and groups

PTW00036 Ms Ruth Trigg Concerns - the author is concerned about the basic premise(s) for construction of a weir at Pomanda Island and offers a critique of the process which has led to this point She analyses Chapter 3 of the Draft EIS using an

Supplementary EIS for the temporary weir near Pomanda Island -159shy

Submission

no Submission from Submission Summary

ana lytic a l framework and a toolkit of d ifferent method s (such as Critical Discourse Analysis and a number of others) - from the list of 73 reports agreements and Acts of Parliament relevant to the River Murray system in the CLLMM region (cited in the submission and in Chapter 3) it is argued that the existence of these documents has not helped to retain the long-term health

of the river system - the lack of accountability with regard to the health of the MDB river system in the present system of government and interactions between governments - the unavailability of water audit figures for the whole MDB system for more than one month of data at a time (data seen as withheld) - tha t the voic e of multina tiona l c omp anies and sha rehold ers overrid es the environment s need s illustra ted

with recent quotes from the media about continued expansion of irrigation in upstream states - that the decision to build the proposed weir is connected

with the a im of g rowing South Austra lia s popula tion (to 2 million by 2050) and that keeping this expansion target in the face of present difficulties with the

sta te s wa ter sup p ly is unreasona b le - that the collective voices of knowledgeable people who live near and care about the River system in the CLLMM region will not be listened to Suggestions - the author suggests that new models of economic growth and development need to be urgently considered (eg further development and use of the Genuine Progress Indicator Dr P Lawn Flinders University) The author supports the submissions of 16 other individuals and groups

Supplementary EIS for the temporary weir near Pomanda Island -160shy

PTW00037 Mr John Yelland Points on matters of national environmental significance relating to the EIS - concern that the EIS guidelines have not been followed Concerns - the author seriously questions whether the weir structure can be built considering the nature of the foundation material especially the apparent unsuitability of the foundation at the western end and quotes material presented in Appendix 5 - the mud waves formed by the dumping of rock have not been studied adequately - the wetlands upstream of the proposed weir which are currently dry will be re-wet at some stage with potential for acid formation and release of heavy metals these acids and metals might not be adequately

flushed with the weir in place and the risks need to be studied - the Draft EIS is deficient in that it does not refer to other proposals such as the regulators at Clayton and at Finniss and Currency Creeks modelling of salinity and Lake water levels should take these other

developments into account The author supports the submissions of 13 other individuals and groups

PTW00038 Mr Bruce Brooks Points on matters of national environmental significance relating to the EIS no direct comment but questions are asked about some assumptions and the accuracy of

Submission

no Submission from Submission Summary

modelling presented in the EIS which lead to decision points (water levels wind speed and salinity) Concerns - argues that the problems of the CLLMM are not primarily a result of drought by comparing Figures 0-2 and a graph showing Murray-Darling Catchment annual rainfall trends 1950 2008 (both graphs with trendlines the latter graph possibly not in the draft EIS but presented at community consultation meetings) - argues that the data and modelling that have been used that point to -15 mAHD (trigger point) being reached in Lake Alexandrina in early 2010 may be incorrect and predicts that the levels reached will not be as low as this in the worst case scenario Further he presents data from Kotwicki 1993 (a factor relating evaporation from the lake to pan evaporation measured in situ at the lake) which differs from the factor used b y MDBC a nd uses Kotwic ki s factor to arrive at a higher Lake water level than predicted in the EIS - concern that the salinity levels in the Lakes in the modelling output presented in the EIS are underestimates and that the data need to be looked at again

PTW00039 Dr Keith Walker This is a detailed submission which provides important knowledge and information on a range of relevant issues including ecology and threatened species of the lower Murray and CLLMM The submission raises many pertinent questions Points on matters of national environmental significance relating to the EIS - a weir pool is not the same habitat for plants and animals as a river or a lake conditions in the pool will favour species such as common carp and discourage riverine species in particular - there should be a fish passage in plans for the weir - the author is concerned that diadromous fish (ie requiring access to the sea) are prevalent in the lower Murray but these would be unable to move beyond the weir - more consideration should have been given to the wetlands between Blanchetown and Wellington - contends that statements on page 13-17 (Interaction of salinity with EPBC-listed fish species) about salinity tolerance of early stages of freshwater fish are misleading - the author says that the discussion of EPBC-listed species is incomplete and superficial - states that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the MDB including the CLLMM region are currently being evaluated for EPBC listing

- the author disagrees with statements in the Draft EIS that suggest tha t the weir would not a ffec t c ond itions a fter d isc onnec tion a rguing instead tha t rec overy will b e delayed - suggests that Chowilla should be listed among the Ramsar wetlands because birds may need to move that far if food becomes scarce in the CLLMM region Concerns - the proposal should be considered alongside other current and planned interventions in the CLLMM regions for

Supplementary EIS for the temporary weir near Pomanda Island -161shy

Submission no

Submission from Submission Summary

the purpose of the EPBC Act - that over-allocation of water is likely to be a major contributor to the crisis in the CLLMM - that the alternatives to a weir have not been adequately considered in terms of feasibility costs and benefits in economic and environmental terms ideas such as shandying water are put forward - that there is a significant risk of development of algal blooms including toxic blooms in the weir pool and that there is scientific literature on this local situation - that the weir will be in place for at least 10 years (with reasoning for this conclusion) - the construction of access roads to Pomanda Island should have been subject to an EIS as it iswas a (dynamic) sand spit - that there is little reference in the EIS to work on Acid Sulfate Soils in other places - that the salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences that the tolerable salinity limits for freshwater species need to take into account peak levels not

average levels - that flooding of the Lakes region with seawater will cause a total ecosystem collapse of a Ramsar-listed wetland - that the weir will have an impact on pest species (common Carp and tubeworm) but this is not addressed in the Draft EIS - tha t the term keystone spec ies is misused in Chapter 6 Suggestions - more attention should be paid to mixing processes in the weir pool and Lake Alexandrina with respect to the perceived increased risk of algal bloom formation - tha t we should ma ke more use of others c onsid erab le experience on dealing with Acid Sulfate Soils

PTW00040 Ms Alison Radford SA President Australian Institute of Landscape Architects

The AILA notes that the following points appear to be missing from the Executive Summary under the terms of reference of the EIS and should be included there as they have been addressed in the body of the Draft EIS - what is the potential for deterioration of the quality of water in the weir pool - is there a soil acidification risk upstream as a result of the construction works - how will the weir pool be filled without increased water flows to the River - there d oes not a p p ear to b e any worst c ase sc ena rio discussion of the effects of further disrupting flows within the main River channel Also AILA notes that while there has been a lot of discussion of impacts downstream from the proposed weir in the Draft EIS there is not a corresponding examination of effects upstream AILA requests that future consultation processes include information sessions in the Adelaide metropolitan area

PTW00041 Mr Trevor Harden This submission argues that dust from exposed dry lake beds in the CLLMM region is a major problem and concern and that the best way to control this problem is to fill the Lower Lakes region with seawater a step which requires that the weir at Pomanda Island be built as soon as possible The author is opposed to community groups who advocate a freshwater solution only and argues that historically the

Supplementary EIS for the temporary weir near Pomanda Island -162shy

Submission no

Submission from Submission Summary

CLLMM area is very likely to have been saline especially at times of low river flow He takes issue with the d oc ument A Fresh History of the La kes by Sim and Muller a nd a rg ues with the support of quotes from journals and personal observations that the CLLMM has a history of being a saline estuary at certain times

PTW00042 Mr Bruce Angus Allnutt Committee Member River Lakes amp Coorong Action Group

The submission mainly addresses Chapters 8 and 10 of the Draft EIS Points on matters of national environmental significance relating to the EIS - queries why there is no fishway in the proposed weir - contends that many statements in the Draft EIS use

language tha t suggest there may be impac ts but the authors believe that many of these impacts will definitely eventuate - the authors suggest that impacts on non-listed EPBC-listed species can affect EPBC-listed species because they are part of the same food chain Errors - Page 10-2 of the Draft EIS the authors state that

Tookayerta Creek is a tributary of the Finniss River not of Lake Alexandrina also the Finniss River and Currency Creek flow into the Lower Murray not Lake Alexandrina Concerns - the lack of consideration of ground water resources in the

Draft EIS - that the site for the weir is unsuitable - the loss of habitat due to lack of freshwater flows - that the social issues and impacts are not addressed - that the effects of drought on low water levels are overstated and that the impacts of water over-allocation are likely to be substantial - Table 10-4 states that water levels in Lake Alexandrina will be maintained at +08 mAHD the authors argue that levels of no greater than +07 mAHD should be maintained otherwise there can be serious

erosion damage - the authors are concerned that the systems modelling uses incorrect assumptions or is not reliable (Table 10-8 and Section 1042) - that Section 107 may not be taking into account the extraction of water from pipelines being constructed that take off water upstream of the proposed weir Questions and suggestions - that the EIS should be part of a combined EIS for the larger set of interventions occurring in the CLLMM region - Section 823 that hazardous substances be stored well away from the weir site during construction - query whether the site of the spillway is optimal and suggest that in the present eastern location this will lead to worse silting problems than if it were placed further west - on page 10-3 there are additional reasons for increase in salinity in the Lower Lakes - in Table 10-3 the word sp illway should be inserted a fter weir in the sec ond aspec t point - query why the dilution flow would be disrupted apart from during the weir pool filling period (Table 10-3) - in Table 10-4 there should be a LAC for the Angas River - the modelling has used worst case scenarios was any modelling done with other scenarios

Supplementary EIS for the temporary weir near Pomanda Island -163shy

Submission no

Submission from Submission Summary

- the authors would like clarification of the last paragraph on page 10-30 - top of page 10-31 The authors endorse the majority of the key points of 15 other submissions

PTW00043 Mr Neil Shillabeer Chairperson Lower Lakes and Coorong Infrastructure Committee

Points on matters of national environmental significance relating to the EIS - potential effects of significant mud displacement during building of the weir on aquatic life - states that the Draft EIS Chapter 12 (page 12-2) is incorrect and that the Ramsar boundary does extend above the proposed weir site and quotes section 1248 (page 12-12) Some wetland s up stream of the

weir [that are] still within the Ramsar boundary are expec ted to experienc e eleva ted wa ter levels Concerns - that the time required to fill the weir pool will be greater that stated in the EIS because swamps between Wellington and Mypolonga have subsided and the soils under the swamps have dried out these will take time to be re-wet

- that the weir will be difficult to complete (close) satisfactorily given the design and construction method and that it may be unstable as a result - that the scale of the proposed weir is much larger than the example quoted in the EIS of the blocking bank at Narrung Narrows which has already had problems that required attention including recent problems not included in the Draft EIS

PTW00044 Mr Ron Heyne The author supports a weir or a permanent lock at Pomanda Island and seawater incursion into the Lakes The author is concerned about other weirs at Finniss River Currency Creek and Clayton and pumping water from Lake Alexandrina into the Goolwa channel He understands this will deplete the Lake and expose more Acid Sulfate SoilsHe proposes a channel into Lake Albert from the Coorong

PTW00046 Mr Shaun Berg Lawyer Ngarrindjeri People

This is a lengthy detailed submission which addresses a variety of issues and makes 57 points about the Draft EIS The submission suggests that the Draft EIS for Pomanda Island be rejected and that the building of the proposed weir should be rejected on a number of grounds It is argued that the EIS has failed to take into account Ngarrindjeri views and that Ngarrindjeri Native Title Rights are affected Finally the submission appends the disclaimers in the Draft EIS and the Appendices to the Draft EIS and thereby points to a number of uncertainties in systems modelling (eg salinity wind) and efforts made by Government and consultants to reduce these uncertainties This submission supports those made by two other individuals Early in the submission the following points are made about the wishes of the Ngarrindjeri

1 natural solutions should be used rather than engineering solutions

2 solutions should consider the CLLMM region as an integrated whole

3 the CLLMM region needs to be maintained as a freshwater area

4 environmental flows to the system are needed to

Supplementary EIS for the temporary weir near Pomanda Island -164shy

Submission no

Submission from Submission Summary

maintain freshwater ecology 5 exposed lake beds should be remediated by

plantings or sand 6 cattle and other animals should be excluded from

these areas to minimize acid soil problems 7 hot spots of acid soils should be treated with lime or

sand Omission Table 4-3 is referred to in the text of the Draft EIS but is not supplied Points on matters of national environmental significance relating to the EIS At least 5 points relate to the EPBC Act - the Australian Painted Snipe should be considered in the EIS (with reasoning) - the EPBC protec ted matters searc h tool wa s used to generate the list of EPBC-listed species likely to be found in the region This result is indicative only has consultation with experts also occurred - the draft EIS does not include the Coorong or Lake Albert in relation to impact on Ramsar listed wetlands yet the Coorong and Lakes Alexandrina and Albert were listed together as a wetland of international

importance under the Ramsar Convention the three are related especially given that water is being pumped from Lake Alexandrina to Lake Albert - the potential impacts of weir operation and removal on

EPBC-related matters has not been not addressed Concerns - EIS process at least 6 points deal with EIS process for

example there is concern that the Draft EIS is not a stand-alone document as required (eg accompanying documents referred to in the Draft are not all available)

- Integration is needed at least 5 points deal with the need to consider this Draft EIS together with the environmental impacts of other current or planned interventions in the region (such as the introduction of seawater into the Lower Lakes)

- Over-allocation it is suggested that over-allocation of water is a major reason for the current crisis

- Technical concern is expressed that too little detail is provided about the construction of the weir

- Removal of the weir no consideration has been given to the removal of the weir if the Lower Lakes have been flooded with seawater This needs to be considered

- Alternative solutions 14 points deal with alternative solutions to the building of a weir it is argued that alternative solutions have not been described or considered in sufficient detail particularly the possibility that

combinations of alternatives may be an effective way to gain sufficient freshwater supplies

- Systems modelling concern is expressed that (a) the impacts are assessed only with an inflow of 896 GLyear to SA other scenarios with lower inflows need to be considered (b) salinity is only modelled for one year (c) impacts of the weir on water temperature

and turbidity are not addressed sufficiently - Soil chemistry risks associated with Acid Sulfate Soils

upstream of the weir and potential impact on the potability of water around pumping stations should be given greater attention there are several questions

Supplementary EIS for the temporary weir near Pomanda Island -165shy

Submission no

Submission from Submission Summary

about Acid Sulfate Soils for example what is the likelihood that the building of the weir itself will lead to a pH crash

- Management and mitigation a number of concerns are raised about what monitoring enforcement mitigation and review procedures will be applied

Suggestions - that the Draft EIS for Pomanda Island be rejected on the grounds that it does not comply with the Guidelines - that the SA Government take into account the changed use of the weir (from a means of securing water supply only to also acting as a barrier to ingress of saline or polluted water into the river) and then resubmit an EIS which covers this broader scope - that the Draft EIS fails to support the construction of a weir at Pomanda Island on the following grounds

1 The proposal does not consider alternatives sufficiently particularly combinations of alternatives

2 That the draft fails to distinguish adequately between impacts of the scenarios with and without the weir

3 There is a risk that the water quality in the weir pool may be poor because of algal blooms

4 There is insufficient attention given to the problem of Acid Sulfate Soils and measures taken elsewhere to solve this problem

5 The proposal should be integrated with other proposals eg the proposal to allow seawater into the Lower Lakes

6 The treatment of EPBC-listed species is superficial and lack plans for mitigation of negative impacts

- that the Draft EIS fails because it does not take into account views of the Ngarrindjeri - that Ngarrindjeri Native Title Rights are affected by the proposal and a number of points are made in relation to this claim

PTW00047

PTW00048

PTW00049

Mr Andrew Milazzo Executive Director TSD DTEI

This submission details the requirements for technical aspects of commissioning the weir according to DTEI regulations Examples are the inclusion and positioning of warning lights on the structure and signage The submission notes that there was no mention in the Draft EIS of the operation of the Narrung Ferry

Ms Jacqui Showell Suggests Adela id e s wa ter supp ly is the main d river for the weir Questions if enough alternatives are being investigated Concerned that decommissioning criteria will never be met Suggests ecological effects downstream will also occur upstream affecting the whole country Believes the system should be treated as a whole Suggests acid and heavy metals will affect regions and Ad ela id e s d rinking wa ter Concern for flora fauna (particularly southern bell frog Murray cod and migratory birds) and Ramsar obligations

Ms Cecily South Over-allocation and human activities need to be addressed The Eastern Mount Lofty Ranges flows into Lake Alexandrina mitigate ASS and heavy metals Further water savings are possible if households have allocations rather than timing restrictions There is water upstream get it Crops that cannot be sustained with irrigation should be

Supplementary EIS for the temporary weir near Pomanda Island -166shy

Submission

no Submission from Submission Summary

abandoned - change to sheep and cereals Reference to technical paper written by Brooks and South The barrages all lead but must be kept closed The SA Government and SA Water should stop pumping from Lake Alexandrina into Adelaide storages Landowners are losing 2-3 metres of lakefront pa The author is opposed to seawater incursions

PTW00050

PTW00051

PTW00052

PTW00053

Ms Ruth Beach Solicitor Environmental Defenders Office (SA) Inc

Points on matters of national environmental significance relating to the EIS

- this submission argues that the proposed weir will be permanent rather than temporary because the conditions for its removal are not likely to be met and that it will be physically very difficult to remove the weir as such the proposed weir should be assessed under the Development Act and the Draft EIS should take into account permanent effects on the environment in the CLLMM region including the Ramsar-listed wetlands and associated fauna and flora

- proposes that the construction of the weir is in contravention of legislation (State and Federal) and international conventions (Federal EPBC Act Water Act Murray-Darling Basin Act State Development Act River Murray Act Natural Resource Management Act Environment Protection Act)

- it is argued that the Draft EIS and proposed weir should be considered alongside other current and planned interventions in the CLLMM region

Concerns - that the EIS has not given sufficient consideration to

alternative sources of water - that other relevant Government reports are still in

preparation Ms Silver Moon Suggests EIS should and fails to be about the impact of an

action Suggests there is deficient understanding of the environmental processes and interactions in the Coorong and Lower Lakes Suggests climate change needs to be addressed Contributes considerable researchedreferenced information on various fauna and suggests they should be included as matters of NES Indicates the significant impact weir construction will have on wildlife and the system Suggests Australia has agreements it must abide by Suggests Chapter 15 is vague and lacking substance Suggests the weir does not meet principles of environmentally sustainable development and calls for action in addressing water allocation in the Eastern Mount Lofty Ranges including Finniss catchment

Mr Rex Hunter Confidential submission

Mr Tim Drew CEO The Coorong District Council

The Council points out - Tha t muc h of the CLLMM area is within the Counc il s boundary and details the population and main land uses - That the area is of particular significance to the Ngarrindjeri - That the Coorong and Lower Lakes were listed in 1985

as a wetland under the Ramsar Convention and that

Supplementary EIS for the temporary weir near Pomanda Island -167shy

Submission no

Submission from Submission Summary

a req uirement is to manage the a rea in a way tha t mainta ins [its] ec olog ic a l c harac ter

- That the Coorong and Lower Lakes are icon sites under the Living Murray Initiative - That as a response to the situation it has established the Lower Lakes and Coorong Infrastructure Committee (2007) - That it is opposed to the construction of the weir at Pomanda Island and any other new man-made structures in the River Murray

Points on matters of national environmental significance relating to the EIS

- the submission points out that there is a Ramsar wetland just upstream of the expected weir site at Pomanda Island and that this needs to be corrected in the Draft EIS - there is concern that there will be significant algal blooms after weir construction and that this will have a negative impact on native fish stocks

Concerns - that the present situation has been brought about by over-allocation of water resources across the MDB rather than by drought - the economic and social impacts of the situation (low water levels and flows) are very serious - that the weir will intervene in the natural river system and have a negative impact as a result - that the Draft EIS Chapter 26 includes the topic of maintenance of water levels for pumping purposes and that this was not included in the original referral to the Federal Government - that the modelling in Chapter 2 is in error because the forecast figures used for levels of L Alexandrina considerably understate the winter rainfalls of 2008 - that the modelling in Chapter 2 may be unreliable because it relies on estimates - that the triggers for removal of the proposed weir need to be more clearly defined and more realistic (the current conditions for removal are not likely to occur for another decade) - that there is a significant risk of blue-green algal blooms in the weir pool - that there is a risk of heavy metal release and acidic soils if the weir is built and potential impact on wildlife - that the weir will lead to the build-up of water with low oxygen concentration with risk to fish populations - that the significance of wind movement (wind seiche) is underestimated in the Draft EIS

PTW00054 Prof Diane Bell Committee Member River Lakes amp Coorong Action Group Inc

The Draft EIS should be rejected because it is inconsistent with the Guid elines for the Content of a Draft Environmental Impact Statement on the Proposed Temp ora ry Weir a t Pomand a Isla nd The p roposa l

- is not a stand-alone document - should properly be considered as part of a larger plan - lacks detail to support plans for construction operation and removal - has no staged and costed short mid and long-term plans for mitigation of NES - fails to investigate alternatives

The proposal will not achieve its stated goals because the

Supplementary EIS for the temporary weir near Pomanda Island -168shy

Submission no

Submission from Submission Summary

- triggers for removal are unrealistic - construction is problematic - water quality above the weir will be poor

The proposed action is likely to have significant impacts on internationally protected wetlands and species that the Federal and South Australian governments are obliged to protect The proposed weir is not the solution to the crisis in the Lower River Murray and Lakes The SA Government should be required to submit a Referral which takes all proposed actions into account and explores all options Part 1 the status of the EIS procedural points Summary It is their contention that the Draft EIS is significantly flawed and should be rejected by the Minister under Section 133 EPBC or alternatively the Minister should require that new Draft Guidelines ones that accurately reflect the situation and the needs of Adelaide for a secure water supply be prepared by the SA Government A number of points require further consideration

1 There is no longer a crisis of water security Minister Maywald has announced she has bought water for next year Acidification and increased salinity are now significant issues but were not when the Guidelines were published Given that both quantity and quality issues have changed the Guidelines should be varied or a new Referral written

2 Since the proposed temporary weir referral there have been a number of other proposals which impact on the quality of water (a weir rationale) The EIS is (therefore) flawed because it is not a stand-alone action and is in violation of the Guidelines

3 The author asserts that the triggers for removal cannot be achieved and there is no long-term plan that explains how they might be achieved

In other points the writer expresses a desire for access to related documents greater clarity and certainty less repetition in the draft EIS and for supplementary reports to be ava ilab le In a d d ition the EIS outlines c onsulta tion whic h has been inadequate ineffective and non-responsive to pub lic questions Part Two Chapter commentaries substantive questions The a uthor s summary sta tesThe EIS is tentative incomplete lacks detail and refers important matters to further supplementary reports and EIS The author states that the SA Government should be req uired to make d eta ils of the freshwa ter solution available as part of the EIS process She asks for a stronger d efenc e of the weir as the only feasib le op tion Referring to Richards she indicates that over-allocation and poor management continue on the Finniss and other tributaries today and asks who makes decisions about critical human needs and under what conditions On wetlands she states that the EIS cannot be considered competent and on seepage and run off the EIS does not give due consideration and states that the criteria for removal are unrealistic and unlikely to be met The Draft EIS displays little or no understanding of the imp ortanc e of c ultura l flows to the Nga rrind jeri

Supplementary EIS for the temporary weir near Pomanda Island -169shy

Submission no

Submission from Submission Summary

Chapter 2 comments as for submission by K McFarlane Chapter 3 comments this consists of pages 7 and 8 of the EDO submission which sets out reasons for non-approval of the Draft EIS under various legislative and regulatory processes Chapter 4 comments this is a combination of K Mc Farla ne s sub mission with a few c ha nges with the addition of the suggested Government freshwater purchase options (staged over three years) from C Ba g ley s submission Chapter 5 Proposed works to be undertaken The author contributes local knowledge about aspects of the Causeway which indicate that it is a dynamic area and that the development of the Causeway will create new flow patterns during floods Comments included

- there is no staged plan for the period of the weir pool filling to manage water issues and consequences below and above the weir - there is insufficient detail describing weir construction methods - insufficient is known about embankment materials and potential to pollute

Concern is expressed about - the amount of weir material which will sink or be washed downstream - the lack of an Environmental Management Plan - the lack of a fish passage - unrealistic weir decommissioning triggers and lack of detail in decommissioning planning

Relevant aspects of the submission by Liz Yelland are then included Chapter 6 comments replicate those submitted by Silver Moon in her submission Chapter 7 comments replicate those submitted by Silver Moon in her submission Also included is a portion of Anne Hartnetts submission (80409 page 5) The first section asserts Australias seemingly low honouring of Jamba Camba Kowamba and the Ramsar agreement and refers to the effect of the weir on migratory birds and the significance of weir placement at a meeting of waters Further Hartnett references (page 5) are made in relation to water levels and the need for spelling out of the effects of MAJOR interventions to remedy the result of these that

would be felt by all other biota Chapter 8 comments this is essentially taken from the submission by B Allnutt and T Giles with an additional comment expressing concern about the risk of habitat loss which in turn leads to species extinction Chapter 10 comments this section contains almost all of B Allnutt a nd T Giles submission (exc ep t for the summa ry of c omment for EIS p lus a paragrap h referring to C Bag ley s submission (questions about salt mobilization when sufficient ra in fa lls) two c omments from K Walker s sub mission (concerns about algal blooms upstream of the weir and acidification of wetlands upstream of the weir) and pages 3 to 5 of L Yella nd s sub mission a b out wind seic hing Chapter 11 comments this includ es N Shillabeer s submission one page (pa ge 4) of A Ha rtnett s submission (the effect of the weir on upstream water quality) and two

Supplementary EIS for the temporary weir near Pomanda Island -170shy

Submission no

Submission from Submission Summary

paragra p hs from S Ric ha rd s sub mission (wa ter qua lity) Chapter 13 The criteria for removal are unrealistic and unlikely to be met This underlines the lack of a long-term rec overy p lan and c asts d oub t on the tempora ry na ture of the weir Chapter 14 comments raise the absence of the Milang Snipe Sanctuary from the draft EIS Page 67 contains the list of birds also contributed by Silver Moons submission (Moon S un-numbered page re section 77 Summary) Commentary on Chapter 15 Environmental safeguards and mitigation measures raises

- Lack of fish passage - Diminution of freshwa ter hab ita t for two mentioned fish spec ies - c omment tha t a rg uements tha t the impac t of the weir c onstruc tion a nd opera tion a re minima l a re misguid ed and fa ils to rec ognise the p rob lem

Further Chapter 15 inclusion replicates in full questions raised by Liz Yelland (submission PTW 34 pages 1-2)

PTW00055 Mr Tim Milne Scientific Officer Nature Conservation Society of SA

Issue 1 Suggests the weir will exacerbate water level reduction and potential problems increasing need for remedial action Also suggests EIS does not address remedial action required Solution 1 examine the impacts of actions to increase water levels in the Lake as these are a direct consequence of weir construction and operation Issue 2 Risks to species associated with increased salinity and acidity Solution 2 EIS should examine impacts of accelarated incareases in salinity and acidity of the water Issue 3 Shortcomings in the environmenetal assessment of construction in Ramsar wetlands Solution 3 Full range of florafauna species need to be examined Issue 4 Lacking accurate information on period of operation and predictions of removal triggers Solution 4 EIS should assume the weir to be permanent to mitigate matters of NES in case this occurs

PTW00056 Ms Gillian Whiting Project Coordinator Murray-Darling Basin Authority

This submission is in the form of the letter addressed to the Director CLLMM Projects under the signature of the Chief Executive Rob Freeman Murray-Darling Basin Authority The letter notes that the proposed temporary weir must be assessed and approved under the Water Act 2007 (Cth) The MBDA requires more details than already provided in the EPBC Act referrals The MBDA asks for clarification and expansion of a range of issues - flow use control and quality of water The MBDA requires information and data relating to hydrology design flow assumptions water balance (inflows storage outflows) assumed water volumes design flood assumptions Hydraulics design details relating to flood surcharge and Water Quality flow cessation into Lake Alexandrina and seawater introduction and acidification thresholds The authority seeks additional information in order to make an Environmental Assessment on fish passage and disconnected wetlands below Lock 1 Weir plans must be submitted to the Authority for

Supplementary EIS for the temporary weir near Pomanda Island -171shy

Submission no

Submission from Submission Summary

consideration and approval Information is required about the capacity of the weir crest to resist erosion More detail is required in relation to weir removal in relation to definitions of normal time required to remove method of removal if a flood Other issues in relation to increased salinity in Lakes Alexandrina and Albert the effect of potentional increase in heavy metals and salinity and increased acid production It is anticipated that the Authority will require at least six weeks to undertake its approval processes

PTW00057 Mr David Winderlich Member of the Legislative Council Leader of the Australian Democrats

The author suggests that the cost of the weir be put into buying water bioremediation and assisting communities experiencing hardship due to low flows In his opinion the Lakes ecosystem and relevant matters of NES will not tolerate the impacts of the construction of the proposed weir The author advocates a natural freshwater system

PTW00058 Ms Kathryn Rothe Project Manager Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

Background this submission is on behalf of the Mannum to Wellington Local Action Committee and the Mypolonga Highland Land and Water Management Committee This submission relates in some aspects to the submission by Ruth Trigg Points on matters of national environmental significance relating to the EIS - lack of a fish passage across the weir is pointed out - concern about loss of important habitat Concerns - that the weir is only a bandage solution and that a strong integrated plan is needed that encompasses the environmental as well as social and economic survival of the Lower Murray and the CLLMM region - the submission does not support the construction of a weir and argues that alternative measures must be used especially the purchase of freshwater upstream for the CLLMM and Lower Murray region - that over-allocation of water is an important cause of current problems - that alternative water supplies have not been given sufficient consideration - that there have been and are many plans and reports about the situation but there does not seem to be a holistic or integrated plan - tha t g rowth in the Sta te s pop ula tion will put even more pressure on water and other resources - the allocation of water to different users needs to be reassessed by the MDBA in a holistic way and with food production as a priority - that the weir will be unstable Suggestions - that freshwater be brought downstream to SA where evaporation rates are much less than at the Menindee Lakes - that bioremediation of Acid Sulfate Soils is already occurring - that the new MDBA should start emergency actions in the region as soon as possible - that alternative sources of water and water conservation and re-use measures be put in place The author points out that the task of preparing this

Supplementary EIS for the temporary weir near Pomanda Island -172shy

Submission no

Submission from Submission Summary

submission was daunting and that it took a lot of time effort and community spirit to prepare This submission endorses the submissions of approx 18 other individuals and groups

PTW00059 Ms Karyn Bradford The writer highlights long connection with the CLLMM extensive knowledge and a long list of achievements in the region The submission contains additional references The writer is concerned that there has been a lack of effective public consultation and that government ministers and their employees chose to dismiss the knowledge skills and expertise freely offered by members of the community many of whom have intimate and generational knowledge of the Lakes and Coorong environment EIS coverage The writer believes that the EIS should be rewritten to include all proposed action for the CLLMM region Language used EIS la nguage is c ritic ised a s [c asting] d oub t on the qua lity and veracity of the informa tion p rovid ed and a s having very few d efinitive sta tements

Seiching A very strong possibility that un-potable water could travel down the river and be trapped behind the weir is identified as a flow on effect of interruption of wind seiching Fish passage The lac k of a llowa nc e for a fish passage is sta ted as not meet(ing) one of the three key ecological objectives of the Murray-Daring Basin Commission Environmental Management Plan 2007-2007 for the CLLMM Icon Site River and Lakes system complexity not understood The writer states that the EIS shows that the proponent does not understand the complexity of the interactions between the River Murray Lakes Alexandrina and Albert its tributaries and the Coorong Ramsar principles breached The author submits that the Ramsar wise use tenet and the precautionary principle are breached by the weir at a time when over-allocation and drought have already done c onsid erab le ha rm to the environment The writer endorses submissions of other named persons A table is used to identify and address issues applicable to specific sections of the EIS including - Executive Summary Purpose

Questions whether full information is available No discussion of bad water coming down Murray Seawater option outside this EIS Alternatives to EIS proposal named

- Executive Summary Introduction Possibility that weir will contribute to algal growth if mixing is impeded

- The original referral Lack of fish passage contradicts Murray-Darling 2007shy2007 Management Plan objectives

- Draft EIS section 737 References to Angus and Bremer Rivers are omitted d esp ite signific a nt b iod iversity va lues partic ula rly a t their c onfluenc e with La ke Alexa nd rina

- Draft EIS section 7-5 Why were only 9 of the 68 listed threatened species discussed in detail

Supplementary EIS for the temporary weir near Pomanda Island -173shy

Submission no

Submission from Submission Summary

Short and Long necked turtles and the Japanese Snipe are of particular interest to local people

- Appendix 15 Raises concern with levels of confidence in 64Confidence in impact assessment Suggests that further information is required

- Selections from the EIS The uncertainty expressed by the use of qualifiers in the EIS language is raised as a concern Question Is there enough evidenc e for this p rop osa l to proceed without further study of all aspects of the p roposa l

- Section 121 A sta tement is mad e tha t the weir will not may interact with the ecological values of the Lower River and Lakes

- Section 141 An attachment provides a record of migratory birds sighted in the area The definition of regularly sighted birds in the EPBC Act is questioned and a Web address supplied at which a local record of birds sighted is kept httpwwwmilangorgauMilanghtm

PTW00060 Mr Mike South Attachment Brooks B amp South M Discussion Paper 19 August 2008 Applying a localised water balance approach to estimate losses from Lake Alexandrina and Lake Albert for the years 1970 to 2006 The author suggests that the models used for the virtual weir should be used with caution and a range of further scenarios need to be modelled A clarification is offered in relation to weir pool levels and pumping SA Water pumps can access water at minus 30m therefore there is no need to maintain levels at +1m AHD The a uthor d isc usses in d eta il sec tion 452 Red uc ing Evapora tive losses of the d ra ft EIS and d isputes the statement that 70 of evaporative losses occur in the Lower Lakes He concludes that long-term evaporation for the Lower Lakes is an over estimate and that the apportionment of losses inappropriately biases the Lakes

PTW00061 Mr Jonathan McPhail Inland Fisheries Management Officer PIRSA Fisheries

The proposed weir will increase pressure on fish stocks and fish habitats which will have significant environmental impact on commercial and recreational fishing Habitat above the weir water will be more stable than currently The changed flow regime will better support European carp and negatively impact on spawning recruitment and migration of Murray cod Murray hardyhead and Yarrra pygmy perch This will work contrary to the MDBC Native Fish Strategy Water quality Removing saline water above the weir will d iminish na tive fishes c omp etitive a d vantage Potentia l decreases in salinity and increases in nutrients and sedimentation will also favour European carp and Mosquito fish and potentially increase the threat of blue-green algae blooms A fish passage is required to support migration of species upstream and downstream and to support upstream fish movements as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline

Supplementary EIS for the temporary weir near Pomanda Island -174shy

Submission no

Submission from Submission Summary

In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river The proposed temporary weir will have severe negative impacts on the available fish habitat and water quality and affect the environmental sustainability of commercial fishing

PTW00062 Mr Glenn Williams Natural Heritage Manager Natural Heritage Trust

The writer has 4 areas of key concern with the EIS 1 Failure to take an ecosystem approach

- The imp a c t of adding a further 5200 hectares to the tens of thousands of hectares of fringing reed-bed habitat that have already dried out and degraded along with their micro and macro invertebrate populations has been stated but not properly assessed in the EIS

- The EIS tends to b e qua lita tive ra ther tha n quantitative both of the proposed weir construction and the altered water regimes across ecosystems A clearer quantitative estimate of potential impacts upon na tive vegeta tion is need ed An example is given relating to impact of rock acquisition on native vegetation

- The writer states that the impact on wetland vegetation and (specifically) samphire plant communities should be quantified more accurately

- The writer is concerned that the EIS does not address over-allocation of water and states that no water allocation has been made for the Ramsar site Irrigation and upstream allocations are referred to

- It is asserted that the weir will withhold even more flow including 350MLday to flush out salt emanating from upstream water-using activities

- EIS is considered to give insufficient attention to the potential implications for the Coorong and the hydrological links between the Lower Lakes the Goolwa Channel and the Coorong particulalry during the period of filling the weir

- The writer believes that the Draft EIS lacks context and overview of the range of other feasible actions that might have been taken as well as those needed with the construction of the temporary weir

2 Failure to seriously examine pursue and commit to fund ing other rea sona b le a nd p rud ent a lterna tives

- The writer argues that human needs have been given priority with minimising of environmental impact being a secondary objective

- The writer asserts perceived lack of action by the state government to decrease reliance on Murray giving examples of water allocation from the Murray to the Clare Valley the BILL scheme Port Lincoln and a Port Hughes golf course

- The writer sta tes tha t the p roponent s EIS ob liga tion to exa mine p rud ent a nd fea sib le a lterna tives has

not been fulfilled by the failure to seriously address - Harvesting of stormwater and more substantial flows

from the short west-flowing creeks of the Mt Lofty Ranges

- Promoting water tanks - Increasing Adelaides water restrictions - Pricing water more competitively particularly for

Supplementary EIS for the temporary weir near Pomanda Island -175shy

Submission

no Submission from Submission Summary

industry and irrigation - The writer considers that the movement of the

pumping stations to above Lock One is a better alternative to the weir

3 Failure to adequately address impacts on EPBC Act-listed fish and frog species

- The writer sta tes tha t the EIS ignores c ond itions below the weir and only concentrates on higher water levels above the weir

- The writer notes that there is no commitment to building a fishway to address the impact on Murray hardyhead and Murray cod caused by disconnectivity between the Lake and River and further sta tes tha t the EIS seems to g loss over the very serious impacts that the iconic Murray cod will suffer from reduced water levels and wa ter qua lity

4 Failure to address geotechnical structural problems with the weir

- Refer section 55 and Executive Summary and Appendix 6

Specific issues raised refer to - poor foundation conditions except for the eastern

half of Getochnical model 1 - low sheer strength indicating slope instability - continuing movement and settling of clays - seepage and possible development of piping - impact of earthquakes on foundation sands

Other concerns addressed in short are - The temporary weir being left in place for a longer

period - writer s rec ommend a tion tha t a c tive-adaptive

processses be adopted for bio remediation of Acid Sulfate Soils and a need to clearly identify the indigenous plants to be used

- lack of information on impacts of temperature changes in the Lakes water column

- failure to address the oxygenation of the River water through wind seiching

PTW00063

PTW00064

Ms Beryl Belford Writer supports a one river and whole of basin approach to ecological management of the River and Lower Lakes The writer believes that - water is available in the basin to save the River system - the federal government must take responsibility for equitable distribution of water - state government should regulate water held in stock and domestic dams in Eastern Mt Lofty ranges to ensure environmental flows to the Lower Lakes

Ms Elizabeth Hobbs Points on matters of national environmental significance relating to the EIS - the author is alarmed that the potential impacts of the weir on the Coorong are referred to so little - states that the list of endangered species in the EIS is too narrow and argues that as both species and habitats are interconnected they should not be split up for the purpose of the EIS - emphasizes the need to have healthy waterways in the region due to its ecological importance Concerns - the author is concerned at the cost of the weir and other interventions in the CLLMM region and quotes from other

Supplementary EIS for the temporary weir near Pomanda Island -176shy

Submission no

Submission from Submission Summary

submissions on this point - from first hand experience at seeing sediment build up due to low water flows the author is concerned that this will occur at the weir site and there will be an impact of this silting up - that the weir is a technical solution for problems that should be solved by other means - that the proposed weir needs to be considered as part of the larger set of interventions occurring and being planned in the CLLMM region - that over-allocation of water rather than drought is the reason for major problems occurring Suggestions - the author proposes that there are alternative measures that should be put in place and expanded to reduce Ad ela id e s relia nc e on wa ter form the River Murray - an interconnected systems solution needs to be developed to protect the area listed under the Ramsar agreement

PTW00065 Dr Talina Vizard The writer questions Can local springs be channelled into the river (eg from Victor Harbor) Would redirecting storm water into the system help Have views of Ngarrindjeri been considered Can the use of bore water be policed and how can farmers be educated to the effect of taking water from the c ommon store

Writer Comments Time for comment too short Writer supports the submissions of Liz Yelland (PTW00034)

PTW00066 Ms Carlsa Carter The author states that the South Australian Government ignores the serious environmental condition of the Coorong and Lower Lakes and withholds minimum environmental flows The author states that there is a lack of thorough information about EPBC-listed species and species of the freshwater ecosystem and states that the loss of reed beds and habitat during the period of weir construction is trivialised Attention is drawn to a bird survey by Dr Kingsford of Newcastle University (2009) which shows greatly reduced numbers of water and wading birds over a short period

PTW00067 Ms Julie Pettett CEO Conservation Council of South Australia

The CCSA opposes the construction of a weir near Pomanda Island while accepting that the provision of drinking water is critical CCSA states that the impact of the weir will have unacceptable impacts on several matters of NES and the idea that the weir will be temporary is strongly contested CCSA argues that the EIS is seriously deficient and that the EIS for the proposed temporary weir should be reshyconsidered in conjunction with a referral EIS and public consultation about the introduction of seawater into the Coorong and Lower Lakes The CCSA is concerned about the impacts of a weir on Southern bell frogs Murray cod Murray hardyhead and Yarra pygmy perch and may be able to provide a supplement to the submission about these concerns at a later date CCSA states that the construction of a weir will destroy and degrade more than a hectare of Ramsar wetlands flora

Supplementary EIS for the temporary weir near Pomanda Island -177shy

Submission no

Submission from Submission Summary

and reed beds and have consequent impacts on listed threatened species and migratory fauna Construction of a weir is likely to contaminate the Lake and impact on Ramsar wetlands threatened species ecological communities and migratory species Triggers for removal are discussed CCSA states that the weir will exacerbate acidification of the Lower Lakes and thus the weir will need to be permanent In addition CCSA states the Hume and the Dartmouth storages have not been at normal operating levels for ten years and achieving the prescribed salinity level is unrealistic These factors suggest a permanent weir CCSA believes more consideration needs to be given to the Federal government purchasing water and structural adjustments under the Water for the Future Program Stormwater harvesting aquifer storage and recharge and wastewater re-use would be less environmentally harmful options than a weir

PTW00068 Ms Paula Horbelt Secretary Goolwa District Ratepayers amp Residents Association Inc

This submission urges the State Government to consider water alternatives as Salisbury Council has done It is suggested that Cheltenham could be similarly used as a water capture site The Association encourages rainwater tank policy but questions the energy intensity costs of desalination The Association is concerned that a weir will increase salinity levels in Lake Alexandrina and that Ramsar sites of significance will not be protected The Association understands that water quality between Lock One and a weir at Pomanda island would inevitably deteriorate due to inadequate wind seiching In conclusion the submission states We support the purchase of water rather than weirs temporary or otherwise

PTW00069 Mr Keith Scobe The writer is a member of the Ramsar Taskforce His submission expresses a preference for securing water from upstream He refers to submergable floating booms as a method managing water (instead of a weir) He expresses uncertainty about the no flow period over the weir and expects weir construction costs will escalate He expresses hope that the MDBA will manage the Murray Darling Basin well in future

PTW00070 Ms Ruth Russell The writer is opposed to the construction of a weir and argues for a sustainable freshwater long-term management plan for the Murray-Darling Basin overall The author contributes to Adelaide University Frog Census work and has engaged with CLLMM issues in the region She urges a well researched long-term freshwater solution so that there is a postive outcome for future generations The writer urges - better use of a range of water alternatives - accessing water from the temporary water market through the Water for the Future Program - adoption of the precautionary principle - rejection of this EIS in favour of a more holistic and systematic EIS acknowledging complexity and interdependency The writer understands that the weir will be destructive of nationally listed species and suggests a fish passage should be included She fears algal blooms due to ineffective wind seiching as well as acid soils impacts on water qulaity The

Supplementary EIS for the temporary weir near Pomanda Island -178shy

Submission Summary

writer also fears that the weir will not be temporary PTW00071 Mr Ken Jury and

Mr Mike Young The authors are critical of the unrealistic timeline for consultation They propose a permanent weir which prevents loss of freshwater above and allows an esturine environment in the Lakes below This environment would support wader birds and improve tidal access to the north CoorongThe River Lower Lakes and Coorong must now be regarded as a human-altered environment and managed to suitThe authors argue that it is important not to allow the mobilisation of acid from soils into water as this will corrode the barrages They believe the only option is to inundate the Lakes with seawater and query the freshwater science presented A diversion pipeline is suggested from Morgan and questions are raised about loss of River water into aquifers

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -179shy

Government of South Australia

  • Table of Contents
  • Part Two - Community Consultation Report ndash Appendices
Page 2: Supplementary Environmental Impact Statement

Permissive Licence

This document may be reproduced in whole or part for the purpose of study or training subject to the inclusion of an acknowledgement of the source and to its not being used for commercial purposes or sale Reproduction for purposes other than those given above requires the prior written permission of the Department for Environment and Heritage

Disclaimer

While reasonable efforts have been made to ensure the contents of this publication are factually correct the Department for Environment and Heritage makes no representations and accepts no responsibility for the accuracy completeness or fitness for any particular purpose of the contents and shall not be liable for any loss or damage that may be occasioned directly or indirectly through the use of or reliance on the contents of this publication

Reference to any company product or service in this publication should not be taken as a Departmental endorsement of the company product or service

Acknowledgements

The South Australian Government acknowledges the Ngarrindjeri People as traditional owners within the lands where the temporary weir is proposed

The Department for Environment and Heritage would like to express appreciation to the Lower River and Lakes residents organisations and community groups and the numerous people who gave their time and expertise to the development of this report A large number of people contributed in the overall development process including through participation in working groups submissions Community Information Sessions and Targeted Group Information Sessions

Submissions received during Public Consultation

This Supplementary Environmental Impact Statement (Supplementary EIS) addresses the issues raised that are within the scope of the Guidelines for the content of the Draft Environmental Impact statement on the proposed temporary weir at Pomanda Island near Wellington South Australia published on 30 August 2007 in written submissions during the period for Community Consultation The Draft EIS was submitted to the Australian Minister for the Environment Heritage and the Arts in early Marc h 2009 Written submissions from any person or organisation who believes they can improve refine correct inaccuracies or generally add value to the draft Environmental Impact Statement on the proposed temporary weir near Pomanda Island were invited during the period of pub lic c onsulta tion from 12 Marc h 2009 to 9 April 2009

All submissions received are on the website at wwwenvironmentsagovaucllmmtemporaryshyweirhtml except where the respondent requested confidentiality

ISBN 978-1-921466-91-5

Printed July 2009

copy Department for Environment and Heritage

Format of Supplementary EIS

This Supplementary EIS is in two parts

Part One is the Supplement to the Draft EIS It provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report This Report over views and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Proponent s details

South Australian Government represented by

Name Peter Croft

Title Director Coorong Lower Lakes and Murray Mouth Projects

Department Department for Environment and Heritage

Address GPO Box 1047 ADELAIDE SA 5001

Proponent s environmental record

The South Australian Department for Environment and Heritage (DEH) is responsible for South Australias nature conservation heritage conservation and animal welfare

DEH collects and provides information and knowledge about the states environment

DEH manages the states public land including national parks marine parks botanic gardens and the coastline

DEH also advises on environmental policy

DEH is part of the Environment and Conservation Portfolio and reports to the South Australian Minister for Environment and Conservation DEH delivers the Governments environment policies d irectly and through partnerships These are with other government agencies including the Department of Water Land and Biodiversity Conservation (DWLBC) the Environment Protection Authority (EPA) Zero Waste SA Natural Resources Management Boards and Primary Industries and Resources SA as well as a wide range of non-government environment organisations industry bodies and the community

DEH s work is determined by its ob liga tion to ac hieve rela ted ta rgets in South Austra lia s Strategic Plan to administer legislation dedicated to the Minister for Environment and Conservation and to respond to the needs of South Australians

Table of Contents

PART ONE SUPPLEMENT TO THE DRAFT EIS 1

1 Introduction to the Supplementary Environmental Impact Statement (EIS) 2

Overview of Supplementary EIS structure 2 Purpose 2 DEWHA issues 2

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region 3

Submissions received and responses 3

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir 5

Submissions received and responses 5 Murray-Darling Basin Authority submission 5 The time required to remove the temporary weir 5 Floods 5 Phytophthora at the temporary weir construction site 6 Weir Causeway 7 Weir Site 7 Weir Construction and Environmental Management Plans 7 Weir Materials 8 Weir Crest 8 Pumping 8 Permanent Weir 8 Triggers for Removal 9 Salinity measuring locations 10 Decommissioning 11 Modelling 11 Virtual Weir 13

4 Supplementary comment on expected impacts of the temporary weir on soils and water 14

Introduction 14 Submissions received and responses 14 Acid Sulfate Soils (ASS) 14 Water quality 16 Wind seiche 16 Impacts upon Coorong and Lake Albert 17 Dredging of Murray Mouth 18 Water quality impacts near Narrung Narrows 18 Algal blooms 20 Summary of water quality impacts 21 Connectivity of Surface and Ground Waters 22 Surface Waters 22 Groundwater 23

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels 24

Introduction 24 Upstream impacts 24 Impacts of altered water regime in weir pool 24 Impacts to Pelican Lagoon and Nalpa Station 25

Weir Footp rint Impac ts 25 Impacts of Habitat LossDegradation 25 Impacts upon fish migration 26 Impacts of noise upon wetland birds 27 Monitoring during constructiondecommissioning 27 Timing of construction and presence of migratory species 28 Downstream impacts 28 Impacts of water level changes upon aquatic vegetation 28 Impacts of temporary increase in salinity upon aquatic biota 28 Impacts upon tributary wetlands 31 Impacts upon the Milang Snipe sanctuary 31 Impacts upon primary determinants of ecological character 32 Impact upon keystone species 32 Impact upon habitat availability 32 Impact upon salinity 33 Impact upon turbidity and sedimentation patterns 33 Impact upon water levels 33 Impact upon water regime 33 Impacts upon migratory shorebirds 34 Impacts upon Australian Painted Snipe 34 Impacts upon Orange-bellied Parrot 34 Impacts upon Great Egret Cattle Egret and Caspian Tern 35 Impacts upon pelagic birds 35 Impacts upon bush birds 35 Impacts upon Mt Lofty Ranges Southern Emu Wren 36 Impacts upon White-bellied Sea Eagle 36 Issues of scope adequacy and definition 36 Adequacy of species and communities examined 36 Current status of waterbirds 37 Adequacy of EPBC Act threatened species and communities lists 37 Adequacy of discussion of EPBC Act-listed species 37 Omitted flora and fauna records 37 Definition of keystone spec ies 38 Spec ies c onsidered of partic ula r signific anc e 38 Adequacy of description of different wetland types 38 Regional importance of the Coorong Lower Lakes and Murray Mouth 38

6 Notes on significant issues outside the scope of the draft EIS For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities 39

Ngarrindjeri People 39 Social and economic issues 39 Climate change 40 Dust and health 40 Other themes 40

7 Suggested text changes errata additions clarifications and references 41

References 53

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA) 54

General comments 54 Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth 54 More specific comments 61 Water supply 68 Removal triggers (pg 1-6) 70 Wetlands 72 Re-wetting of upstream wetlands 75 Threatened and migratory species 77 Fishway 81

PART TWO COMMUNITY CONSULTATION REPORT 85

1 Introduction 86

2 Community Information Sessions 86

3 Targeted Meetings 89

4 Overview of media articles (see Appendix VII) 89

5 Receiving submissions and developing the Supplementary EIS 90

PART TWO COMMUNITY CONSULTATION REPORT - APPENDICES 93

Appendix I - Submissions received Individuals 94

Appendix II - Submissions received Organisations 96

Appendix III - Participants and notes from Targeted Meeting Sessions 97

Appendix IV - Organisations that participated in Community Information Sessions 109

Appendix V - Participants and notes from Community Information Sessions 110

Appendix VI - Advertising copy used in the consultation process 127

Appendix VII - Media generated by the consultation process 146

Appendix VIII -Summary information of enquiries and submissions for provision of the proposed temporary weir 148

Appendix IX - Table of submissions 149

Executive Summary

The purpose of this Supplementary Environmental Impact Statement (EIS) for the temporary weir near Pomanda Island is to address Issues of National Environmental Significance (NES) (as defined in the Environmental Protection and Biodiversity Conservation Act 1999) arising from written public submissions and government comment during the period of public consultation for the Draft EIS

Part One is the Supplement to the Draft EIS provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report provides an overview and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Part One of the Supplementary EIS is divided into 6 key sections

Section 1 contains an overview of the document

Section 2 considers the role of the temporary weir within the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth Region These comments are made in response to a number of submissions that suggested that the temporary weir was being considered in isolation

The sec tion outlines the Government s multi-faceted strategy to combat the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region

This strategy includes both long and short-term plans including worst-case scenario measures that would only be implemented as an option of last resort should a fresh-water solution not be found

Section 3 considers submissions relating principally to Chapter 5 of the Draft EIS Proposed Works to be Undertaken

The Murray-Darling Basin Authority (MDBA) submission outlined the approvals necessary under the Commonwealth Water Act 2007 and in particular under clause 49 50 and 63 of the Murray-Darling Basin Agreement

The South Australian Government submitted a detailed application to the MDBA on 15 May 2009

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process however the Authority sought details on the method of removal of the temporary weir in the event of a flood coming down the River

As the flood scenario was not discussed in the draft EIS it is addressed in the section 3 of the supplementary EIS

Any flood moving down the River is most likely to have originated in the upper reaches of the river system and can take up to six weeks to reach the temporary weir location During this time an assessment will be possible as to the appropriate method of management of the temporary weir structure

A significant cluster of submissions were made regarding triggers for removal or decommissioning of the temporary weir

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria stated in the Draft EIS remain appropriate

Other submissions considered in Section 3 relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the proposed temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir A number of submissions also raised concerns about modelling

By way of response section 3 outlines the environmental management framework for the temporary weir including an Environmental Management Plan which ensures management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Section 4 provides an overview of submissions relating to expected impacts of the temporary weir on soils and water

A number of submissions raised concerns regarding acid acidity and Acid Sulfate Soils (ASS) These submissions support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible

ASS field investigations and modelling will enable key information gaps to be addressed and be fed back into the ongoing planning and measures undertaken

Wind seiche and its impact on water quality also formed the basis of several submissions as did possible increases in algal blooms within the weir pool itself

While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes

Some submissions sought clarification regarding the interaction between surface and ground waters

Section 5 Submissions discussed in Section 5 relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

A process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Another issue of concern raised in many submissions is the potential impact of increased salinity within the Lower Lakes upon aquatic biota By way of response Section 5 adds considerable detail regarding predicted salinity changes and the likely biotic response

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Section 6 briefly overviews issues raised in submissions which lie outside the scope of the Supplementary EIS In some cases ideas were contributed which are worthy of note

There is a suggestion about the importance of consulting with and recognising the Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

Another submission argues for having more than one scenario when drafting the EIS (not only d rought but a lso c limate c hange) and another c ontextua lised the c urrent p red ic ament of

the Coorong Lower Lakes and Murray Mouth in ideologies about unsustainable growth

A number of submissions outlined the current social and economic conditions of the Coorong Lower Lakes and Murray Mouth region indicating that there is considerable social and economic suffering attributable to drought and over-allocation of River water

Many submissions expressed discontent with over allocation of water resources and a significant majority expressed opposition to the temporary weir A minority supported the temporary weir and some indicated a preference for seawater flooding of the Lower Lakes (rather than a limited incursion)

There was almost no comment about water security issues for Adelaide and the majority of South Australian country towns

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part OnE Supplement to the Draft EIS

1

1 Introduction to the Supplementary Environmental Impact Statement (EIS)

Overview of Supplementary EIS structure

Rather than replacing the Draft Environmental Impact Statement (EIS) this Supplementary EIS d iscusses those issues raised in submissions Thus most of the tables and figures from the Draft EIS are not repeated Section 7 of the Supplementary EIS lists a range of text changes (corrections deletions additions and minor clarifications)

Note This Supplementary EIS needs to be read in conjunction with the Draft EIS for the proposed temporary weir near Pomanda Island There is no re-written version of the Draft EIS

Purpose

The purpose of this Supplementary EIS for the temporary weir near Pomanda Island is to address issues relating to Matters of National Environmental Significance (NES) that are within the scope of the guidelines arising from written submissions lodged during the period of public consultation for the Draft EIS

DEWHA issues

The Commonwealth Department of the Environment Water Heritage and the Arts (DEWHA) raised a number of issues with the South Australian Department for Environment and Heritage (DEH) Many of these issues are pertinent to the Supplementary EIS and a copy of the response to these issues is provided in Appendix 1

Supplementary EIS for the temporary weir near Pomanda Island -2shy

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region

Submissions received and responses

A number of submissions suggested that the temporary weir was being considered in isolation and several suggested that there should be one encompassing environmental impact statement for actions being considered in the Coorong Lower Lakes and Murray Mouth (CLLMM)

The scale and complexity of the problems associated with lack of inflows to South Australia suggests that there must be a well coordinated set of solutions The South Australian Government has developed a multi-faceted strategy in response to the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region This involves development of a short-term strategy to protect the quality and access of major public water supplies to protect the local and regional environment from irreversible damage and to minimise adverse impacts on infrastructure and the regional community It also involves the development of a long-term management p lan Refer to tab le Summary of SA Government Projec ts in the Lower Lakes Coorong and Murray Mouth in Append ix 1 Question 3

Water security involves water quantity and quality to ensure a potable water supply to Adelaide and Regional South Australia The drought and anthropogenic1 uses have drastically reduced inflows to South Australia and water levels have dropped below Lock 1 (near Blanchetown) increasing salinity and exposing Acid Sulfate Soils (ASS) in the Lower Lakes The oxidation of ASS upon drying can result in acidic water and mobilised metals some of which are toxic to humans above certain concentrations The temporary weir aims to ensure adequate weir pool level for operation of the pumps supplying water to Adelaide and regional South Australia in addition to presenting a physical barrier to acidic andor saline water migrating upstream towards the pump stations from the Lower Lakes

The temporary weir is not considered the only solution to issues in this region The South Australian Government is writing a long-term p lan the initia l version entitled The Coorong Lower Lakes and Murray Mouth Directions for a healthy future This was released for pub lic comment during May 2009 Following a period of public consultation community feedback and with scientific input the final version of the long-term plan will be completed in October 2009 and submitted to the Australian Minister for the Environment Heritage and the Arts (MEHA) as required under the Murray Futures Funding Deed

In addition to the long-term plan the South Australian Government has had to take a number of emergency measures which while separate in their own right form part of a strategy of inter-connected short-term actions

The South Australian Government has referred five proposals to the MEHA for consideration under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) These are

A referral to establish a temporary weir near Pomanda Island (EPBC 20073484) which was determined to be a controlled action in July 2007 (the subject of this EIS process) The South Australian Government has stated that this temporary weir would only be constructed as a last resort and that the Government is continuing to pursue options for a freshwater solution The weir if approved and constructed would be a temporary weir aiming to protect the water supply of Adelaide and many country towns The draft EIS was released for public comment on 12 March 2009 This Supplementary EIS is prepared in response to public submissions that closed on 9 April 2009

A referral to upgrade the Pomanda Peninsula causeway to allow access to the temporary weir embankment site on Pomanda Island (EPBC 20084674) was referred to the MEHA on 23 December 2008 The Minister decided on 23 January 2009 that this p roposa l was not a c ontrolled ac tion

1 of relating to or resulting from the influence of human beings on nature

Supplementary EIS for the temporary weir near Pomanda Island -3shy

A referral to open the barrages that separate the Lower Lakes from the Coorong (EPBC 20084618) as a last resort should this prove necessary The aim of this proposal is to allow the controlled entry of a limited amount of seawater to maintain the water level in the Lower Lakes above the critical trigger level of acidification The proposal has been deemed a controlled action The final guidelines for the Content of a Draft Environmental Impact Statement were released on Friday 13 March 2009 (Note that The Murray-Darling Basin Ministerial Council approved a Real time management strategy to avoid acidification in the Lower Lakes (November 2008) involving the introduction of seawater through the Barrages when certain trigger points are reached The Council recognised the threat of acidification and approved this strategy essentially as a last resort)

A referral to construct a below ground pipeline that is capable of delivering 30 GL annually from the River Murray (at Jervois) to the Langhorne Creek and Currency Creek landowners was submitted on 18 February 2009 (EPBC 20094743) The pipeline will deliver irrigation water to communities and industries in the region that are currently reliant on the Lower Lakes for their water supplies This was assessed as not being a controlled action if undertaken in a particular manner and completion is scheduled for late 2009

An emergency first response referral to mitigate the multiple adverse impacts of Acid Sulfate Soil exposure in the Goolwa channel and its tributaries (Finniss River and Currency Creek) was submitted on 6 April 2009 (EPBC Reference No 20094833) This involves the construction (1) a temporary environmental flow regulator within the Goolwa Channel near Clayton (2) a temporary low-level regulator in the mouth of the Finniss River (3) a temporary low-level regulator in the mouth of Currency Creek The referral also involves pumping water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel This was assessed as not being a controlled action if undertaken in a particular manner

If more fresh water could be secured to flow into South Australia and Acid Sulfate Soil managed to mitigate impacts on water quality then the temporary weir would not be needed

Supplementary EIS for the temporary weir near Pomanda Island -4shy

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir

Submissions received and responses

Submissions discussed in this section generally relate to the content contained in the Draft EIS Chapter 5 titled Proposed Works to be Undertaken The major sections of that Chapter include weir location design parameters and time constraints construction environmental constraints and site selection alternative design options operation decommissioning and removal

Written comment received on Chapter 5 from the public and government agency respondents raised a wide range of issues A gap relating to the temporary weir and the effect of flood was identified and there was a significant cluster of submissions related to triggers for removal or decommissioning the temporary weir

Other submissions relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir

Murray-Darling Basin Authority submission

A submission from the Murray-Darling Basin Authority (MDBA) stated that approval for the construction of the temporary weir was required under clause 49 50 and 63 of the Murray-Darling Basin Agreement and detailed exactly what was required as part of the approval process The South Australian Government subsequently wrote to MDBA (15 May 2009) seeking approval for the construction of the temporary weir

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process However many of the details requested are relevant to the temporary weir

The MDBA sought details on

Quantifiable triggers for removal

The time required to remove the temporary weir

The method of removal if a flood is travelling down the river when the level of Lake Alexandrina is low

The effect of increased salinity levels

The effect of the potential increase in heavy metals and

The effect of an increased sediment rate of acid production around Pomanda Island

On 30 June 2009 the MDBA approved plans for the proposed weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

The time required to remove the temporary weir

Refer to discussion on floods below

Floods

The MDBA submission has requested information about the removal of a temporary weir during a flood

Response

Given the exceptionally low storage levels in the Murray-Darling Basin system it would take considerable rain over a prolonged period of time and throughout a significant proportion of the Basin to generate a flood of sufficient flow resulting in all the decommissioning triggers

Supplementary EIS for the temporary weir near Pomanda Island -5shy

specified in section 58 the draft EIS being met Should a flood event signal the achievement of the weir decommissioning triggers the decommissioning and removal would only proceed after the flood has passed

Nevertheless advice has been sought from relevant authorities regarding both the specific level of rainfall necessary to create flood conditions in the Murray-Darling Basin catchments and the lead time available to remove the temporary weir in the unlikely event of a flood

Any significant flood moving down the river is most likely to have originated in the upper reaches of the river system and therefore can be expected to take up to six weeks to reach the location of the temporary weir During this time an assessment will be possible as to the appropriate method of management of the structure of the temporary weir

The temporary weir contains a spillway which is designed to pass 15 GL a day with a minimal rise in the upper weir pool level This flow rate was given by the MDBA as a nominal upper flow limit for normal river management and represents a 15 fold increase from the current flow past Wellington of approximate 1 GL per day A design for higher flood events was not included in the draft EIS due to the expected very low probability of occurrence plus the expectation that if flood event were occurring then the river system would have recovered and the temporary weir would not be required

The impact of flood flows over the temporary weir are being reviewed and initial indications are that flows much greater than 50GL per day could be passed without the upper weir pool level rising above the normal full supply level (FSL) of 075m AHD

In the unlikely event of a significant flood two reactions are available Firstly the flood could be allowed to pass over the temporary weir or secondly a breach in the temporary weir could be made to assist passage of the additional flow

The choice of the best option depends on the flood flow size the water level in Lake Alexander and the degree to which it could be flushed by the flood and the likelihood that the temporary weir will still be required after the flood (ie whether the conditions for weir removal have been met)

If the temporary weir is required after the flood then breaching the weir is unlikely to be a preferred option If the flood is allowed to pass over the temporary weir the likelihood of significant damage will depend on both the size of the flood flow and the downstream water level It is expected that flood damage should be low due to the width of the spillway (This is still to be confirmed by additional design analysis)

In a worst case situation a sufficiently large breach in the temporary weir could be done in the available time The method of removal remains the same however the work method will need to control all risks associated with different upstream and downstream water levels that may exist

The South Australian Government will work with the MDBA to develop a weir flood management plan Given the current exceptionally low water levels throughout the Murray-Darling Basin system it would take considerable rain over a prolonged period and over a significant proportion of the Basin to generate a flood of sufficient flow to require removal of the temporary weir The low water levels in storages and the River system also provide the opportunity to regulate a large percentage of high flows

Phytophthora at the temporary weir construction site

One submission claimed that impacts of weeds and pests such as Phytophthora cinnamomi were omitted and that therefore the weir construction could potentially have a significant environmental impact

Response

The Draft EIS (chapter 15) provides details on the environmental management framework for the temporary weir including Environmental Management Plan (EMP) to ensure management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Supplementary EIS for the temporary weir near Pomanda Island -6shy

Once a contractor has been selected the contractor is expected to manage the temporary weir project in accordance with best practice mitigation measures to effectively reduce the environmental risks and avoid adverse impacts associated with site level impacts during the construction operation and decommissioning of the temporary weir

It is recognised that weeds and pests if not managed appropriately can present a long-term threat and impact on the native plant communities in the area

Consequently weed and pest management in general and the specific management of Phytophthora a re a c ritic a l element of the c ontrac tor s Environmenta l Management Plan (EMP) Selection criteria for contractors also include specific environmental compliance and best practice evidence

As part of this project detailed weed assessments will be conducted as part of the risk assessment in the Construction Environmental Management Plan (CEMP) via desktop studies (especially for Phytophthora) weed surveys and expert advice Project-specific mitigation measures are then included in the EMP and a specific (during and post-construction) weed management plan Specific measures may include but are not limited to

Avoidance of weed-infested areas for land-based construction activities (for example by relocating stockpile areas etc)

Construction activities restricted to approve construction corridors only

Weed management plan endorsed by the South Australian Murray-Darling Basin Natural Resource Management Board (SA MDB NRMB)

Wash-bay areas established according to weed management plan

Record kept of hygiene measures conducted prior to entering the site (for example plant trucks materials working clothes shoes boots etc)

Phytophthora cinnamomi distribution is contained to the wetter areas of the state It is highly unlikely that this fungus would be spread at the temporary weir site

For more information see httpwwwenvironmentsagovaubiodiversityplantsshyanimalsdiebackhtml

Weir Causeway

A submission claimed that as the level of the causeway would be higher than the temporary weir this would form a barrier and create new flow patterns

Response

There is no evidence that a flow path across the causeway exists with normal water level conditions The existing causeway and beach area on the western side contain no wash ways On the contrary there is evidence that only minor amounts of water in storm-driven waves have moved over the causeway

Weir Site

A submission from the SA MDB NRMB requests a better explanation of why this site is the preferred site

Response

This is explained through extensive studies summarised in Section 56 of the Draft EIS which concluded that no other feasible site exists down stream from Murray Bridge

Weir Construction and Environmental Management Plans

Some submissions criticised the lack of an EMP

Response

Specific mitigation measures will be developed in consultation with State environmental agencies to ensure that they are consistent with the relevant Acts and regulations (for example the Environment Protection Act 1993 (SA) the Natural Resources Management Act 2004 (SA))

Supplementary EIS for the temporary weir near Pomanda Island -7shy

The EMP is reviewed and endorsed by a number of agencies before any works can be carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) for the overarching EMP SA Water Corporation and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Weir Materials

One submission states that information about sourcing of material is not complete and raises doubts as to whether materials can be transported Will pollutants be introduced to the water

Response

The draft EIS (section 542) addressed the first two issues raised

The issue of pollutants to the Lake from the embankment material is covered in the requirements for an EMP and CEMP in the Draft EIS

One submission claims that mud waving will create a structure fault where the weir embankment fingers join It also claims that the structure will slip

The possible impact of mud waves on the structure is recognised and is one of the key elements in the c ontrac tor s c onstruc tion method The stab ility of the struc ture is a norma l design issue that is mitigated by using a design review process

The EIS provides all the available knowledge on material sources As the contracting method leaves the material source decisions to the contractor no further information will be available until a contract is awarded

Weir Crest

The MDBA requires confirmation that the temporary weir crest can resist erosion from flow

Response

Specific details for the temporary weir crest design were incorporated in an application sent to MDBA on 15 May 2009 This is not related to the draft EIS or the Supplementary EIS

Pumping

One submission claimed that the option of relocating the pump stations would involve a short timeframe and thus avoid the environmental impacts of constructing a temporary weir

Response

The option of re-locating pump stations is stated in the Draft EIS to involve a risk of continuity of supply The submission has also not recognised that the timeframe for moving a pump station individually upstream of Lock 1 (near Blanchetown) is similar to building a larger pump station upstream of Lock 1 and laying the required connecting pipeline Both options would require feasibility studies and engineering designs as well as the necessary State and Commonwealth approvals and assessments Should an EIS be required for these options it is envisaged that the projects would not be in place to ensure a potable water supply to Adelaide and Regional South Australia within the next two years

Permanent Weir

One submission claimed that impacts of permanent weirs are severe and therefore another weir should not be built on the River Murray

Supplementary EIS for the temporary weir near Pomanda Island -8shy

Response

The impacts have been examined and reported (See for example Draft EIS Section 831) taking into account the temporary nature of the proposed weir The Draft EIS concludes that the impacts of not building the temporary weir when critical trigger points are reached are more signific ant as muc h of South Austra lia s wa ter sec urity is threa tened

Triggers for Removal

A number of submissions claim that triggers are inappropriate because they specify conditions that have not prevailed for more than a decade and that they lack detail and are unlikely to occur within the next decade References are made to water levels in Murray-Darling Basin storages salinity in Lake Alexandrina and general water quality risks in Lake Alexandrina

Response

Triggers

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria as agreed by the Water Security Council and accepted by the MDBA and stated in section 58 of the Draft EIS remain appropriate

Removal of the temporary weir is highly dependant on the seasonal conditions as well as decisions by Murray-Darling Basin Ministerial Council on water sharing water recovery and water allocation policies The South Australian Government has selected a nominal 3 year life for the temporary weir as indicative

Stages

The graph below is available on the MDBA website and shows that storage levels dropped below the long-term average in 2002 and have not exceeded this since that time The time to recover storages to these levels is primarily dependent on inflows and while based on historical data it might take a series of years to recover to average inflows equally it could be much quicker in a single year with high inflow For this reason the life of the temporary weir has been referred to as nominally 3 years

Supplementary EIS for the temporary weir near Pomanda Island -9shy

Salinity in Lake Alexandrina

Similarly the graph below shows historical salinity levels in Lake Alexandrina where the salinity did not increase above 3000 EC (Electrical Conductivity) until 200708 This graph shows salinity averaged at four sites - A4261157 (Milang) A4261158 (West Pomanda Point) A4261133 (Beacon 90) and A4261156 (West Point McLeay)

Water quality in the Lakes is unlikely to improve until additional freshwater flows down the river to either dilute the Lake water or flush it to the sea The third trigger has been purposely expressed as water quality rather than salinity to allow for possible acidification impacts and associated mitigation measures

As fresh water flows eventually increase the salinity level in Lake Alexandrina will initially fall due to dilution and the Lake will fill with freshwater Salinity levels will then fall further as lake water is flushed to the Coorong and the ocean The extent of flushing required to reach the trigger level is dependent on how long the higher flows persist

Salinity measuring locations

One submission suggests that the target of 3000 EC lacks detail on where it is to be measured Another submission suggests that the target on storages should be replaced with a target on-flow to South Australia

Response

The 3000 EC trigger is intended to be a general salinity measurement in Lake Alexandrina Specifying a single measurement location is not appropriate because there can be areas of localised higher salinity and some of the sites where salinity has been measured over many years are now out of the water The intent is to take a rolling 7 day average over the four representative existing sites (Milang Mulgundawa Poltallock and Raukkan) Data from these sites have been collected for many years and existing protocols will be continued As part of these protocols the sampling sites have moved to accommodate the shift in shoreline

The flow to South Australia comprises a combination of ordered water (and South Australias entitlement flow of 1850 GL is in this category) and unregulated flow which is water that cannot be captured in Murray-Darling Basin (MDB) storages normally due to rainfall in the

Supplementary EIS for the temporary weir near Pomanda Island -10shy

lower parts of the catchment It is therefore possible to get high flows in any single year but the MDB storages could still be empty at the end of the year

It is only when the Hume and Dartmouth reservoirs have returned to normal operating levels (and other decommissioning triggers specified in section 58 the draft EIS have been met) that the South Australian Government can have confidence that the temporary weir would no longer be required The MDBA state that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

Decommissioning

A respondent questions how a structure designed for 3 years can be reconciled with a possible continuing drought and the removal triggers

Response

The temporary weir is designed to a nominal three year structural life and is expected to be removed when current drought conditions abate sufficiently with confidence that the improved River Murray flows are sustainable Detailed information on the triggers for decommissioning are specified in section 58 the draft EIS

As indicated in chapter 4 of the draft EIS the Murray-Darling Basin is six years into the worst drought on record It has led to low water River Murray flows over the border No-one knows when the drought is expected to end or how much water is expected to become available so it is necessary to plan for the worst scenario

Modelling

A number of submissions raised concerns about modelling

Water level forecasts may be incorrect due to assumptions about net evaporation There were questions about whether drought is the fundamental cause of the problem considering recent rainfall history in the Murray-Darling Basin

Modelling is only carried out for a period of 3 years despite the unknown length of the proposed operation

That modelling is only reported for an allocation to South Australia of 896 GL

That there is a lack of modelling results for temperature turbidity and acidification

That the temporary weir will cut off low water inflows

That water level modelling is flawed and underestimates local winter inflows

That the temporary weir will stop salts moving into Lake Alexandrina and these salts will be forced back into the River channel and

Further modelling particularly related to a virtual weir was sought

Response

The following graph (Department of Water Land and Biodiversity Conservation 020709) shows the drop in water levels in Lake Alexandrina over recent years The falls are quite uniform and the projections are consistent with recent history The models used have been accurate in projecting water levels to date

Supplementary EIS for the temporary weir near Pomanda Island -11shy

_

Lake Alexandrina Level

-26

-24

-22

-2

-18

-16

-14

-12

-1

-08

-06

-04

-02

0

02

04

06

08

1

0100 0600 1100 0401 0901 0202 0702 1202 0503 1003 0304 0804 0105 0605 1105 0406 0906 0207 0707 1207 0508 1008 0309 0809 0110 0610

Date (monthyear)

Lake

Ale

xand

rina

Wat

er L

evel

(m A

HD

)

Modelling projections have only been made for a period of 3 years because of the low probability of a continued period of extended drought and increasing uncertainty about future management responses Modelling using 896 GL flow over the South Australian border was used as it reflected the water sharing agreement for South Australia This figure is considered the worst case flow into South Australia

Flows to the Lower Lakes are currently determined by the minimum River flow needed to ensure that the maximum salinity at Murray Bridge remains within potable limits The temporary weir will not cut off flows to the Lower Lakes and once the pool behind the temporary weir is filled water will flow over the temporary weir into Lake Alexandrina at the rate of at least 350GL per annum

Modelling does not support the contention that the temporary weir will not prevent saline water from moving upstream into the River channel This is fully described in the Draft EIS

The Draft EIS acknowledged limitations with the model used to predict the movement of saline water in the Lakes but also notes that it provides the best information available and was based on numerous model runs (Refer also to section 443 of the Draft EIS) It is considered that running the models for a broader range of scenarios would not substantially alter the advice on impacts of the temporary weir The salinity model cannot be calibrated to a high level of certainty simply because there is no historic reference The current conditions are outside the bounds of normal lake operation

An adaptive approach will be required for managing the filling process for the pool upstream of the temporary weir to ensure that there is an appropriate balance between the various competing interests This will need to take into account issues such as technical constraints related to the construction program potential environmental impacts on Lake Alexandrina during the period of no flow or low flow to the lake flow requirements for the proposed fishway through the temporary weir and possible impacts on wetlands reclaimed swamp areas levee banks and the river bank as the water level rises upstream of the temporary weir Some of these issues will only become clear as the water level rises and the filling process will need to be adjusted in response to these impacts

It is apparent from the early contractor engagement process that the initial construction method adopted for the modelling described in the draft EIS will be slightly modified due to

Supplementary EIS for the temporary weir near Pomanda Island -12shy

technical constraints In addition a fishway will be provided through the temporary structure As a result of these factors the basic refilling process has been modified from that proposed at the time the draft EIS was published

The current proposal (assuming the inclusion of a fishway through the temporary weir) is to have a minimum dilution attraction flow of 200 MLday past the structure at all times during refilling An initial period of refill of some 2 to 3 weeks is proposed when level will be raised from -15m AHD to -12m AHD and the flow past the temporary weir would be limited to the 200 MLday This will be followed by a period of approximately 25 to 3 months when the level is held at -12m AHD and the passing flow will be approximately 1500 MLday Finally there will be a period of approximately 2 to 25 months as the temporary weir is refilled from -12m AHD to the nominal pool level of +01m AHD and the passing flow will be limited to approximately 200 MLday

However it is proposed that this refill strategy will be modified in response to any impacts arising from the refilling process as identified above

Virtual Weir

A submission suggests models need to be used with caution and asks whether models have been run at lower levels and with salinities less than seawater and what flow past Wellington would be needed to make a virtual weir work

Response

It is agreed that the model used to predict the movement of saline water from Lake Alexandrina to the River channel needs to be used with caution There is limited data with which to calibrate the model

The value of the model is to better understand the mechanisms of how saline water moves upstream and how it is dissipated This information is included in section 443 of the Draft EIS

The model indicates that current flow rates are too low to ensure mixing of fresh and saline water and prevent a saline layer making its way up the River Murray The modelling indicates that flows would need to increase by a factor of 5-10 times before this issue could be resolved As indicated in the draft EIS if this volume of water was available then no saline water would enter the river channel

Since the release of the Draft EIS the MDBA engaged WBM-BMT to undertake further hydrodynamic modelling to investigate the potential for and risks associated with a virtual weir Modelling will incorporate several months of new data and involves a number of new scenarios in respect of water levels lake salinities and wind strength direction and duration

It is anticipated that the outcome of this work will be available progressively during July and August 2009 and will further inform the technical feasibility of implementing a virtual weir

Supplementary EIS for the temporary weir near Pomanda Island -13shy

4 Supplementary comment on expected impacts of the temporary weir on soils and water

Introduction

The draft EIS involved discussion of soil and water quality impacts within many sections of most chapters The chapters specifically detailing soil and water quality impacts were

Chapter 8 Potential impacts of the proposed temporary weir

Chapter 10 Changes in water levels and salinity

Chapter 11 Soil and Water quality impacts

A significant number of submissions and government responses to the draft EIS included comments related to soil and water quality Government agencies such as the Environment Protection Authority (EPA) the Department of Water Land and Biodiversity Conservation (DWLBC) MDBA and the SA MDB NRMB have suggested changes in the light of new data or further information DEWHA has requested further clarification

Submissions received and responses

The major points raised by the submissions are detailed below along with responses involving a discussion and conclusion in regard to the points raised

Acid Sulfate Soils (ASS)

Submissions raised the following questions and concerns

Who is completing monitoring for alkalinity in Lake Alexandrina and where is monitoring data being stored Can the public or other agencies access this data

The lack of information about rates of acidification and potential release of metals (and metalloids) the mobilisation and flushing of acidity and associated contaminants (for example metals nutrients) to the water and the impacts of ASS and acidification on the ecology and ecological processes for example risks to species

The need to make more use of the considerable experience from elsewhere when dealing with ASS

The need to study acidity risks and environmental impacts associated with rewetting of wetlands upstream of the temporary weir

The need for information and data on hydraulics relating to flow cessation into Lake Alexandrina and sea water introduction and acidification thresholds

Not enough information on immediate and long-term implications of building the temporary weir (for example medium to low confidence in modelling of tipping point for acidification)

The need for additional modelling of acid and metal release

The need to address remedial actions necessary in the Lakes because of the accelerated decline in water level

Quantification of the risk of acid mobilisation upon re-wetting of River channel wetlands upstream of the weir site in general more consideration is needed to be given to these water bodies and

What are the mitigation measures planned if alkalinity levels reach 25mgL CaCO3

Response

As indicated below independent advice from leading international and Australian ASS scientists has been sought in order to increase knowledge on sulfide oxidation rates generation of contaminants (for example metals and nutrients) transport mechanisms and neutralisation dynamics

In 2008 the South Australian Government commissioned several reports into acidity metal mobilisation and water quality risks for the River Murray and Lower Lakes and it is further

Supplementary EIS for the temporary weir near Pomanda Island -14shy

prioritising investigations to assist with ASS mitigation and management options such as bioremediation

Such investigations can take from several months to years but once more information is available the models underpinning acidity and metal mobilisation impacts for this region can be better refined

Since August 2008 the SA MDB NRMB has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (for example sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (Report 1 March 2009 Available May 2009 wwwepasagovau) The EPA also compiles the raw data in a spreadsheet available to South Australian Government agencies

Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on the potential impact refilling wetlands will have on water quality of the Main River channel and the ecological impact of further acidification of wetlands

The

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes

Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the Murray-Darling Basin Authority Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from a DEH project identifying acidification remediation options for the Lower Lakes

Construction of regulating structures and other on-ground works for remediation at priority wetlands

Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRMB is managing the Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t with a steering c ommittee of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRMB DEH DWLBC MDBA SA Water Corporation EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of +01m AHD An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of the wetlands will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island for example wetlands providing important aquatic refuges

Conclusion

In conclusion it is agreed that the impact to River channel wetlands is an important issue that needs to be managed This is true irrespective of whether a temporary weir is constructed or

Supplementary EIS for the temporary weir near Pomanda Island -15shy

not Measures are already in place to minimise the risk to water quality in the River channel Refilling these wetlands will provide important aquatic refuges

The submissions on acid acidity and ASS support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible and be fed back into the ongoing planning and measures undertaken

In the meantime it is noted that there is extensive experience in dealing with ASS elsewhere Leading international and Australian ASS scientists with industry specialists have been contacted to provide independent advice and an ASS risk workshop involving many of Austra lia s soil and hyd rology sc ientists was rec ently held for the Lower Lakes If a lka linity levels reach 25mgL CaCO3L immediate mitigation measures such as limestone slurry dosing of the water in affected areas are expected to be undertaken

Recent information on ASS bioremediation and dust issues for the Coorong Lower Lakes and Murray Mouth reg ion is ava ilab le from the South Austra lian Government s Environment web page httpwwwenvironmentsagovaucllmmfaqs-acid-sulfate-soilshtml

Water quality

Wind seiche

There were a number of submissions in regard to wind seiche impacting on water quality at the pump intakes Concerns included

Some suggested that the remaining area of the Lake above the temporary weir (weir pool) would still be large enough to allow significant wind seiching to occur Due to low inflows and a large weir pool surface area salinity would increase in the weir pool and these seiching events would still have the capacity to drive the saline water within the weir pool upstream to the pump intakes

It was suggested that the temporary weir will effectively impede if not completely stop the wind seiche effect across Lake Alexandrina and into the River thus stopping the mixing of the water in the River and substantially increasing the risk of algal blooms

It was suggested that the impact of wind seiche in the weir pool is not fully understood and

Concern was expressed about cutting off seiche events into the lower Murray providing nutrients and oxygenated water from Lake Alexandrina Seiching events also allow transport of pollutants to the Murray Mouth and may build up in the weir pool when there are inadequate seiche effects

Response

Wind seiche is believed to be an important part of the ecosystem within the lower reaches of the River Murray It is a transport mechanism for both up and downstream transporting oxygenated nutrient rich water from Lake Alexandrina into the lower reaches of the River and allowing flushing from the channel of excess nutrients and salt Additionally it provides variability in water levels important for the life cycles and habitat of some native species

If the River system and Lower Lakes were experiencing normal flows and water levels then the temporary weir would reduce the effects of seiche events At the proposed trigger level to install the temporary weir (-15 m AHD) the connection of Lake Alexandrina to the River channel will be minimal reducing the effects of wind seiche As indicated in section 443 of the draft EIS this is partly due to the natural bathymetry of the river channel where it connects to Lake Alexandrina

Modellers have incorporated the effects of winds seiche including those modelling scenarios with a temporary weir in place There are also real world examples The draft EIS made a comparison between seiche effects above and below Lock 1 and noted that the effects were less pronounced above the lock Additionally BMT-WBM modelling indicates that by December 2010 under ongoing low flow conditions both scenarios with and without a temporary weir show a marked drop in the effects of wind seiche and there is little difference between the two scenarios

The draft EIS also stated that the effects of wind seiching are expected to be reduced by approximately 50 with the temporary weir This is because the temporary weir will decrease

Supplementary EIS for the temporary weir near Pomanda Island -16shy

the effects of wind seiche within the River channel by disconnecting it from Lake Alexandrina which supplies a large amount of momentum for water seiching up the lower River Murray

Any water from Lake Alexandrina that did manage to travel up channel will also be highly saline acidic and have high concentrations of metals Currently water does not flow over the barrages and out the Murray Mouth and would not at the trigger level of -15m AHD The shoreline of much of Lake Alexandrina would in fact be kilometres north of the barrages by this stage

With a temporary weir in place flows over Lock 1 will continue supplying a constant source of freshwater in the weir pool helping to keep salinity low within that pool Additionally the temporary weir will prevent the transport of saline acidic water from Lake Alexandrina into the River channel These effects along with the reduction in wind seiche will ensure salinity and contaminants at the pump intakes are minimised However the reduction is unlikely to remove all wind seiche effects creating enough movement to reduce the risk of algal blooms and oxygenate the water

Conclusion

The effects of the temporary weir need to be considered in the context of what the situation will be when it is proposed that the temporary weir will be installed that is at a water level of -15 m AHD in Lake Alexandrina While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes Some effects such as blue-green algae formation and potential reduction in oxygen levels upstream of the weir pool (due to reduced flow velocities over the temporary weir itself) whilst undesirable can be managed by the treatment plant whereas other poor water quality (such as metal releases due to acid sulphate soil effects potentially created in the Lakes) would be more difficult to treat Oxygen levels may fall within the weir pool due to the reduction in seiche events and a lack of oxygenated water from Lake Alexandrina however some seiching and wind action will still occur within the wide weir pool reducing the likelihood of anoxic conditions from occurring

Impacts upon Coorong and Lake Albert

A number of submissions raised questions about the impacts on the Coorong and Lake Albert from the temporary weir

Response

These submissions are noted however the proponent contends that the Draft EIS contains sufficient evidence that conditions in Lake Albert and the Coorong will be unaffected by construction of the temporary weir The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170 mm only occurs during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD (including Lake Albert and the Coorong) is not a direct impact of the temporary weir It is therefore beyond the scope of the draft EIS

The draft EIS considered that impacts of the temporary weir on the Coorong and Lake Albert were not considered significant This is because at the time of the weir closure the surface water elevation of Lake Alexandrina will be below sea level preventing any movement of water to Lake Albert and through the barrages to the Coorong The introduction of a temporary weir will not change this situation

Since May 2008 water levels in Lake Albert have been maintained artificially at an approximate height of - 05 m AHD by pumping from Lake Alexandrina Continued low River Murray flows have made this practice unsustainable and funding for pumping ceased on 30 June 2009 as noted by the MDB Ministerial Council on 12 June 2009 The cessation of pumping in June 2009 will lead to a gradual lowering of the level of Lake Albert The introduction of a temporary weir will not change this situation

Supplementary EIS for the temporary weir near Pomanda Island -17shy

Conclusion

At the trigger level for the construction of the temporary weir the Coorong and Lake Albert waters will be disconnected from Lake Alexandrina so changes to soil and water quality are not significantly impacted on by the temporary weir

Dredging of Murray Mouth

The issue of whether the dredge at the mouth of the Murray will remain there if the temporary weir is put in was raised

Response

The Murray Mouth is the only site where water contaminants such as silt salt and nutrients can exit the Murray-Darling Basin There has been no significant release of water from the Lower Lakes via the barrages since November 2005 and connection at the Murray Mouth has been dependent on dredging

The dredging program should only be regarded as a temporary measure Increased environmenta l flows a re the Murray s only solution in the long term if we are to keep the mouth open and maintain the health of the Coorong

Water quality impacts near Narrung Narrows

Submissions suggested that conclusions on water quality impacts from the construction of a blocking bank at the Narrung Narrows need revising in the light of additional monitoring data

Response

The construction of the blocking bank took 16 days to closure after commencing on 16 April 2008 Water quality parameters were monitored before during and after construction but revealed little impact with fluctuating turbidity levels likely due to the effects of wind as shown historically in figure 11-5 of the draft EIS There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid once water levels rose Alkalinity concentrations showed little change during and after the construction

Turbidity

The EPA has undertaken monitoring at locations around Lakes Alexandrina and Albert since the commencement of the construction of the Narrung Narrows blocking bank EPA water quality monitoring reports p repared for the b loc king bank p rojec t s steering c ommittee noted tha t some localised turbidity impacts were observed but this did not translate into widespread impacts in Lake Albert Figure 11-7 (below) shows turbidity readings for five locations and demonstrates that there is little correlation between the installation of the blocking bank the subsequent pumping and turbidity in both Lakes The variability in turbidity is principally related to climatic conditions at the Lakes For example the Lakes are shallow and the area experiences wind events which regularly create turbulence which is able to mobilise sediments thus increasing turbidity The spike at Meningie in December 2008 is not likely to be related to the blocking bank as it is nearly six months after construction

Supplementary EIS for the temporary weir near Pomanda Island -18shy

Turbidity at Monitoring Stations near the Narrung Narrows

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120408 70508 10608 260608 210708 150808 90908 41008 291008 231108 181208 120109 60209 30309 280309

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Lake Albert - 1km offshore Meningie jetty Lake Albert - Near narrows 3km NE of Reedy point

Lake Albert - Near water level gauge 11km N of Meningie Lake Alexandrina Poltalloch

Lake Alexandrina - Beacon 90

Figure 11-7 Turbidity (NTU) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Acidity

Water column pH has remained relatively constant with readings predominantly between 86 and 89 (Figure 11-8 of the Draft EIS) There was a pH drop in Lake Albert at the time of completion of the blocking bank with the closest monitoring point recording a pH of 79 These lows were recovered to normal levels within the month after pumping commenced

These results show there may be some localised effects to pH through the exposure of sulfidic sediment However the buffering capacity of the water and the quantity of exposed sulfidic sediment reduce the risk to the effects of pH to the Lake as a whole

pH at Monitoring Stations near the Narrung Narrows

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120408 10608 210708 90908 291008 181208 60209 280309 170509

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-8 pH at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Supplementary EIS for the temporary weir near Pomanda Island -19shy

Alkalinity

All stations with the exception of the Lake Albert station closest to the blocking bank have had relatively constant alkalinity concentrations The largest decrease in pH did not correlate with a reduction in alkalinity however later reductions in pH in August and November 2008 and January 2009 did Due to the continued exposure of sulfidic sediments over this time it is unlikely the effects are due to the blocking bank construction

Alkalinity at Monitoring Stations Near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-9 Alkalinity (mgL) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Conclusion

Water quality parameters were monitored before during and after the construction of the Narrung Narrows blocking bank and monitoring revealed little impact with fluctuating turbidity levels likely due to the effects of wind There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid Alkalinity concentrations showed little change during and after the construction

Algal blooms

There were many concerns about possible increases in algal blooms within the weir pool through reduction in flows and nutrient fluxes impacting on water quality

Response

The risk of algal blooms in the River is influenced by a number of interacting factors including weather conditions flow and turbulence and nutrient supply It is therefore not possible to precisely predict the extent and intensity of blooms However it is generally accepted that blue-green algae are favoured by waters with reduced turbulence reduced turbidity and increased nutrients A change to turbulence only increases the risk if sufficient nutrients are present to support the bloom The reduced flow in the River as a result of the drought will increase the likelihood of algal blooms The temporary weir will also reduce the flow and turbulence during the weir pool filling period and may therefore also tend to increase the risk of algal blooms Precise prediction of the frequency and intensity of algal blooms is not possible but it could be expected to be similar to the permanent structures upstream

Supplementary EIS for the temporary weir near Pomanda Island -20shy

There is a range of information mainly from studies overseas that lakes and rivers that experience frequent andor prolonged algal blooms display an array of ecosystem properties that may have impacts on water quality biological communities and ecosystem services

Some impacts of algal blooms may be direct including possible effects of toxins on fish invertebrates and other aquatic fauna or indirect including a reduction of submerged plants when plankton biomass becomes very high and changes in fish community structure due to hypolimnetic anoxia In lakes with dense blooms of blue-green algae accumulation of organic material in lake sediments and increased bacterial activity also may lead to anoxic conditions that alter the structure of benthic macro invertebrates Despite numerous case studies and a vast literature on species specific responses community level effects of blue-green algal blooms are not well understood

It must be noted however that these potential changes are associated with highly eutrophic environments that have frequent and persistent and often massive algal blooms These conditions are relatively extreme and unlikely to be encountered for extended periods in the River provided projected flows are maintained

The lower River Murray and other surface water storages within the Murray-Darling Basin regularly experience minor algal blooms due to seasonal stratification and periods of low flow These blooms have not been associated with the types of potential environmental effects that occur in the degraded systems with persistent blooms A case in point is the recent short-lived but highly visible bloom in the River Murray in NSWVictoria downstream of Hume Dam

It is not possible to make a precise prediction of the impact of the temporary weir on the risk of blue-green algal blooms However it is expected that the impacts will not be significant and will be similar to those in the permanent structures up stream

The water treatment plants in South Australia all have the capacity to remove algal cells and the toxins taste and odours that they produce and are able to mitigate any detrimental effects of algal blooms on water supplies

Summary of water quality impacts

One submission highlighted that the summary of water quality impacts in Chapter 11 of the draft EIS did not include all of the impacts to water quality particularly salinity

Response

The construction of the blocking bank at the Narrung Narrows was examined to determine what impacts on water quality if any were identified during and after construction of the blocking bank Using the blocking bank as an example it is expected that the construction of a temporary weir near Pomanda Island may have impacts on water quality both up and down stream

Water quality issues which may result within the weir pool include a reduction in flow velocity an increase in temperature and evaporation and a decrease in dissolved oxygen levels and in the effectiveness of wind seiche events to provide mixing and transport of salt nutrient and contaminants This may lead to temperature and salinity stratification and an increase in blue-green algal blooms in the weir pool It is expected that these impacts will be similar to those relating to the permanent structures that already exist in the River Murray up stream from Lock 1 and that the potential environmental risks will therefore not be significant

The construction of the temporary weir itself will create localised sediment waves as material placed in the River channel displaces sediment This sediment wave is likely to contain sulfidic materials that will oxidise and form acid Based on the experience of the Narrung Narrows blocking bank the provision of mitigation and management measures as outlined in the CEMP is adequate It can be expected that there will be localised impacts to turbidity pH and alkalinity but minimal effect at a distance

Once the weir construction is complete there will be a reduction in inflows to Lake Alexandrina while the weir pool is filled (see page 13 -14) Modelling indicates that during this time there will be a temporary increase in salinity in the waters of Lake Alexandrina However it has indicated that in the long-term the d ifferenc es in sa linity between the weir and no weir op tion under continued low inflows become insignificant

Supplementary EIS for the temporary weir near Pomanda Island -21shy

The reduction of flow during the filling of the weir pool (see page 13-14) predicts the volume of water in the Lake such that a further 5200 ha of sulfidic soils are exposed in Lake Alexandrina under the worst case scenario This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage ASS will need to be implemented across the Lake in this case

When these impacts are compared to the conditions likely to be present when water levels reach triggers for the temporary weir to be installed at viz 15 m AHD it is likely that the impacts of the temporary weir on water quality in Lake Alexandrina will be an increase in salinity for up to 3 months and bringing forward a potentially rapid pH reduction in Lake Alexandrina by 2 to 3 months For a detailed discussion of likelihood of Lake Alexandrina acidifying during the no flow period refer to Appendix 1 Question 7

For a detailed discussion of reasons underlying the 25 to 3 month disconnect of Lake Alexandrina refer to Appendix 1 Question 9

Connectivity of Surface and Ground Waters

Surface Waters

A few submissions questioned what the tributaries of Lake Alexandrina were and when they would disconnect

One submission was received stating that the drop in water level predicted to occur as a result of building the temporary weir should not have been expressed as an average but as a range

Response

There are four tributaries from the Eastern Mount Lofty Ranges (EMLR) to Lake Alexandrina namely

Angas River

Bremer River

Currency Creek

Finniss River

The surface waters of these tributaries will be disconnected at -15m AHD from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into the Lake and were the first to disconnect at a water level between +01 m and + 03 m AHD The Angas and Bremer have been disconnected since 2007

At times of medium to high outflow from these tributaries there is likely to be some reconnection of surface water with or without the temporary weir

The South Australian Government commenced construction of a temporary environmental flow regulator at Clayton in June 2009 The Goolwa Channel (and Currency Creek and the Finniss River tributaries) will be disconnected from Lake Alexandrina during construction of this regulator (EPBC Reference No 20094833)

The figures in Chapter 10 of the draft EIS show a selection of graphs of predicted water level impacts of the temporary weir From these the greatest reduction in water level during the weir pool filling phase in the first year is shown to be approximately 210 mm near the tributaries (points 63 and 64 Figures 10-13 and 10-14)

Conclusion

All tributaries except the Goolwa Channel are now disconnected from Lake Alexandrina and will remain so with or without a temporary weir

The construction of an environmental low flow regulator at Clayton will disconnect Currency Creek and Finniss River from Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -22shy

Reconnection of surface water in Angas and Bremer Rivers with Lake Alexandrina is likely at times of medium to high outflow from these tributaries This situation is unlikely to change with the construction of the temporary weir

Groundwater

A few submissions questioned the detail on surface waters and groundwater interactions

Response

In terms of groundwater connection it is assumed that the sediments in the tributaries and Lake Alexandrina will have some hydration from groundwater even at water levels of less than -28 m AHD

During development of the EIS DWLBC hydrogeologists were consulted on whether the p red ic ted dec rease in Lake Alexandrina s water level of 210 mm near the tributa ries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the drought induced water level drop which has already occurred

Conclusion

Tributaries are likely to remain connected to Lake Alexandrina through groundwater at levels less than -28 m AHD and the 210 mm difference in water level induced by the construction of a temporary weir is unlikely to have a significant impact on groundwater flux

Supplementary EIS for the temporary weir near Pomanda Island -23shy

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels

Introduction

Submissions discussed in this Section relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir as outlined below The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

Another issue of concern raised by many submissions and respondents is the potential impact of increased salinity within the Lower Lakes upon aquatic biota The following discussion adds considerable detail relating to predicted salinity changes and the likely biotic response endeavouring to provide greater breadth and clarity around this issue

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Upstream impacts

Impacts of altered water regime in weir pool

Several submissions argued that conditions in the weir pool created upstream of the temporary weir would favour exotic species such as Common Carp and disadvantage native species including EPBC Act-listed species such as Murray Cod Such an impact would be contrary to the goa ls of the MDBA s Native Fish Stra tegy

There was also a concern that flora species such as the common reed cumbungi and willows (an introduced species) in the riparianlittoral zones might respond in a way that could impact on matters of NES

Response

aspec ts of the p roposed temporary weir tha t interac t with ray-finned fishes of NES (page 15-13) should be expanded to include The list of

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

The list of potential impacts of the temporary weir upon aquatic fauna (Section 15415 pages 15-24) should be expanded to include

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

Advice from the South Australian Research and Development Institute (SARDI) Aquatic Sciences is that mitigation of improved spawning conditions for Common Carp in the Pomanda Island weir pool is not practical due to the scale of the issue Similarly measures to promote spawning of Murray Cod in the weir pool are not practical The potential impacts of the temporary weir upon EPBC Act-listed fishes in the River Murray channel upstream of the

Supplementary EIS for the temporary weir near Pomanda Island -24shy

temporary weir due to altered hydrology and increased exotic fish abundance appear to be unavoidable

The following aspec ts of the temporary weir tha t interac t with ripa rian flora such as Phragmites (common reed) Typha (cumbungi) and willow (introduced species) in the upstream wetlands and consequent effects on matters of NES (fauna) should be taken into consideration

The vegetation type and distribution in the upstream wetlands is expected to change due to the change in water level from (historic) +05m AHD - +08m AHD to a new level of +01m AHD and reduced wind seiche noting that current water levels are substantially lower than this

The change to a shallower wetland regime is expected to favour Phragmites and Typha which are invasive

The impact of changed vegetation pattern on matters of NES (EPBC-listed fish and birds) is expected to be negligible considering their preferred habitat

The impact of changed vegetation pattern on the EPBC-listed Southern Bell Frog is expected to be either to maintain or improve the preferred habitat for breeding

Impacts to Pelican Lagoon and Nalpa Station

Several submissions raised concerns regarding Pelican Lagoon and wetland habitats on Nalpa Station Pelican Lagoon is a large fringing wetland located directly upstream from the temporary weir site Previous surveys at the wetland and the Nalpa property have determined the area to be a biodiversity hot-spot hosting significant species such as the southern bell frog southern pygmy perch white-bellied sea eagle golden-headed c istic ola Lewin s ra il Australasian shoveler and various aquatic plant species As the wetland has been dry since early 2007 there is an inherent assumption that these species are lost therefore the impact of the temporary weir can be negated However further impacts upon these species are possible

Response

It would be desirable to resurvey the area particularly the small inundated area from which stock and domestic water are accessed to determine which species of significance remain and what measures can be taken to protect them

The local landholders have also shown an interest in undertaking management actions for the betterment of the wetland environment Support could be provided in the form of a wetland management plan for the site to determine the most effective way to manage the wetland

Weir Footprint Impacts

Impacts of Habitat LossDegradation

Several submissions argued that potential impacts to flora and fauna due to the clearance or disturbance of vegetation at the weir construction site were understated or unclear These flora and fauna included EPBC Act-listed species Among the fauna of concern were the Southern Bell Frog Orange-bellied Parrot La tham s Snipe (Gallinago hardwickii) White Bellied Sea Eagle and Great Egret Flora of concern included Phragmites australis Typha domingensis Senecio longicollaris Shrubby Groundsel (Senecio cunninghamii var cunninghamii) purple Loosestrife (Lythrum salicaria) and a range of samphire species

Response

A native fauna and flora survey of the approach works footprint and the subaqueous weir footprint was conducted by ecological consultants in SeptemberOctober 2008 (Ecological Associates 2008) Habitat impacts in the immediate weir footprint area were identified to be minimal

It is highly likely that the temporary weir will cause the loss of some of the reed beds at or near the construction site through physical disturbance

Supplementary EIS for the temporary weir near Pomanda Island -25shy

Impacts of mud disturbance upon salinity

One submission claimed that mud disturbance around the temporary weir site during construction would turn the water saline and impact on all fish species

Response

There is no available data which suggest that disturbance of submerged sediments can lead to an increase in the salinity of surface water

Impacts upon fish migration

A significant number of submissions argued that the temporary weir may impede upstream and downstream movement of juvenile and adult fish including EPBC Act - listed species and that this is an unacceptable impact upon upstream and downstream ecosystems and commercial fishing activities

Response

Due to concerns raised in submissions about the lack of a fishway (fish passage) a process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species

SARDI has indicated that it has sufficient knowledge to be able to design a fishway without the need for further site survey work SA Water Corporation is working with SARDI to design a suitable fishway into the temporary weir

SA Water Corporation is progressing a concept design for a fishway in the temporary weir with URS Australia

The concept design for the fishway is expected to be completed in July 2009 and a draft Concept Design Report should be available before the end July 2009 The report will include sketches of the concept and will also show the impact on the temporary weir design

The concept (although still to be finalised and confirmed) is for a rock ramp fishway in the centre of the temporary weir at the western end of the spillway This position places the fishway as close as possible to the deep channel to the west near Pomanda Island The rock ramp would be around 50 metres wide and slope downstream on a 130 gradient The deep centre section would be a metre deep (at full pool level) and the sides of the ramp would slope upwards to provide shallower and slower paths for smaller fish Stop logs at the top of the ramp will allow dewatering of the fish passage

Although the impacts on the temporary weir design will not be certain until the concept design is finalised the indicative impacts of such a concept include the following

The fishway hydraulic design will maintain an upper weir pool water level of 00m AHD with a flow of 600 MLday

A small auxiliary spillway is needed adjacent to the fishway to provide an attraction flow and this will pass 360 MLday the remainder of the average daily flow of 960 MLday (350 GLyear)

At a flow of 960 MLday the upper weir pool will be +01 m AHD with the fishway open (ie identical to the no fish passage design)

At a flow of 1200 MLday the upper weir pool will be +017 m AHD with the fishway open

For automatic operation the bottom of the auxiliary spillway will be inclined from +01 m AHD to +02 m AHD between the fishway and the main spillway

The main spillway crest will be raised to +02 m AHD to ensure that average daily flows remain confined to the fishway and auxiliary spillway Initially a spillway level of +01 m AHD had been established as the upper pool level to be retained by the weir

Supplementary EIS for the temporary weir near Pomanda Island -26shy

However the desire to have a ll flow pass through the fishway during norma l river flow that is 960 Mlday with the upper pool level maintained at +01 m AHD necessitates a reconfiguration of the main spillway of the temporary weir

The main spillway will be slightly shorter (around 1150m wide instead of 1200m wide) so that the fishway can be constructed on the western edge of the better foundation material

To ensure that water entering the downstream pool from either the fishway auxiliary spillway or main spillway remains continuous and provides an attraction path to the fishway the centreline of the auxiliary spillway and main spillway will be moved slightly downstream between the fishway and the eastern abutment

The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Impacts of noise upon wetland birds

One respondent sought clarification on the level of noise the weir construction is anticipated to create given that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB as stated in the Draft EIS

Response

There are no wetlands on the eastern side near the abutment It is anticipated that any areas around Low Point populated by birds will receive noise levels similar to that from a busy highway The same will apply to the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels which would presumably cause them to move further north into the wetland area

Monitoring during constructiondecommissioning

A number of submissions questioned how the Monitoring of EPBC-listed spec ies referred to on page 15-24 of the Draft EIS will ensure that construction operation and decommissioning activities do not impact on EPBC-listed species More information was sought on the fauna inspection to be carried out in the construction area before any vegetation clearance (Table 15-9 on pp 15-2526 of the Draft EIS)

Response

Monitoring during operation of the temporary weir will be coordinated as part of the SA MDB NRMB s na tura l resource condition monitoring program It will include additional monitoring efforts as per expert advice

of the EPBC-listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life and breeding cycles The monitoring focus will be of an observational nature in regards to compliance monitoring This is to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by the Commonwealth and the South Australian Native Vegetation Council) and that the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora and fauna expert advice if warranted In addition the Contrac tor s EMP will identify based on a risk assessment whic h spec ific mitiga tion and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations needs to be recorded

It is rec ognised tha t the monitoring

A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water Corporation and DEH (Ecological Associates 2008) This knowledge has been considered by the Commonwealth More specific instructions on how this can be used will be included in the CEMP The project will ensure that expert advice is available throughout the duration of the construction phase

Supplementary EIS for the temporary weir near Pomanda Island -27shy

Timing of construction and presence of migratory species

One respondent commented that the Draft EIS did not appear to consider the interaction between the timing of construction and the presence of migratory species eg Orange-bellied Parrot potentially present from March to early November

Response

The Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to help protect Orange-bellied Parrots might however impact on other species Migratory shorebirds for example return in late August and spend the entire summer at the site

Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coorong_S urvey_lowpdf

Downstream impacts

Impacts of water level changes upon aquatic vegetation

A respondent noted that in Section 1246 on page 12-11 of the Draft EIS under the heading Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion are

considered insignificant as many of these species reproduce sexually and through wind or bird-d riven seed d ispersa l This is only a c onsidera tion of impac ts upon rep roduc tion not a consideration of whether the plants will even survive to reproduce

Response

Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately +035 m AHD At a water level of -15 m AHD (when the temporary weir would close) this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the water body and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long-term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the Lake be refilled with freshwater to its pre-drought level (+05 to +08 m AHD) while the below-ground storage organs remain viable

Impacts of temporary increase in salinity upon aquatic biota

A significant number of submissions raised concerns regarding the impact of the temporary weir upon salinity in the Lower Lakes and consequent impacts upon biota There were also concerns that not all Matters of NES potentially impacted by the temporary salinity increase caused by the temporary weir had been adequately addressed One submission predicted the salinity increase would cause a mass die-off of Common Carp which would lead to poor water quality in Lake Alexandrina

Response

The scope of the EIS dictates that it consider the impacts of the temporary weir upon biota that are listed as threatened under the EPBC Act or that contribute to the ecological character of the Coorong Lakes Alexandrina and Albert Ramsar site These include all of the freshwater diadromous and estuarine fish species of the freshwater units (Lower Lakes) as well as a large number of bird taxa many of which are piscivorous (Phillips and Muller 2006) Taxa other than fish and birds need only be considered by the EIS if impacts upon them are likely to be transferred into a significant impact upon fish or bird communities

Supplementary EIS for the temporary weir near Pomanda Island -28shy

The impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake (Fig 10-5 in the Draft EIS) The salinity of Lake Alexandrina is predicted to be higher than both the limits of acceptable change (700 EC (Phillips and Muller 2006)) and the typical seasonal maximum (1500 EC) from January 2010 onwards at all loc a tions under both the weir and no weir sc enarios Modelling shows tha t the d ifferenc e in salinity in Lake Alexandrina (modelling assuming continued pumping to Lake Albert however on 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009) under the weir and no weir sc enarios va ries with location At all sites modelled salinity is similar in early 2011 one year after weir construction under both the weir and no weir sc enarios (Sec tion 10) However immediately following weir construction a temporary increase in salinity three to five months in duration is predicted at most sites The magnitude of the salinity increase varies between sites but is pronounced at several sites

A salinity threshold that is important in terms of the maintenance of ecological character is the salinity tolerance of the resident native freshwater fish species of the Lower Lakes Salinity tolerance varies between species but for the temporary weir to have no significant impact upon native fish species its construction should not cause salinity to exceed the tolerance of the most salinity-sensitive species

Several species of rare or threatened small-bodied native freshwater fish that are resident in the Lower Lakes under pre-drought water levels (+04 to +08 m AHD) are unlikely to be present in Lake Alexandrina at a water level of 15 m AHD Yarra Pygmy Perch have probably become locally extinct in the CLLMM as a consequence of the current low water levels (Bice and Ye 2009) Mountain Galaxias Murray Rainbowfish and Southern Purple-spotted Gudgeon are all very rare possibly extinct from the CLLMM with no records for a number of years (Bice and Ye 2009) All of these small-bodied species are associated with fringing aquatic vegetation They are unlikely to be present in Lake Alexandrina when water levels have declined to the extent that all fringing aquatic vegetation has become disconnected from the water body

Prior to the drought the only part of the Coorong Lower Lakes and Murray Mouth where River Blackfish had been recorded were the upper reaches of the Eastern Mt Lofty Ranges tributaries that enter Lake Alexandrina (Bice and Ye 2009) The species prefers permanently flowing freshwater streams with cool clear water where it is strongly associated with the in-stream cover habitats provided by undercut banks and boulders (Khan et al 2004) It is unlikely to be present in the open water habitat of Lake Alexandrina that is disconnected from fringing aquatic vegetation and other forms of cover

A number of short-lived (lifespan generally 3 years or less) small-bodied native freshwater fish species could potentially be present in Lake Alexandrina when the water level reaches

15 m AHD These species are dependent upon fringing or benthic aquatic vegetation during part of their lifecycle particularly egg and larval stages (Lintermans 2007) with the exception of Australian Smelt which is a more pelagic species Therefore conditions in Lake Alexandrina are likely to be unfavourable for their persistence due to the disconnection of fringing vegetation and the water body Although unlikely it is possible that these species may persist providing important remnant populations that could potentially increase in abundance and repopulate the Lake when water levels return to pre-drought levels Due to their brief lifespans the salinity tolerances of all stages of the life cycle are relevant to the potential impacts of the temporary weir upon them Egg and larval stages typically have the lowest salinity tolerance (Bice and Ye 2009) Because breeding occurs in spring and summer for most of these species (Lintermans 2007) the summer-autumn timing of the short-term increase in salinity levels caused by weir construction could have implications for breeding success and thus persistence of these short-lived species in the Lower Lakes The species and salinity tolerances of their most salinity-sensitive lifestage are Southern Pygmy Perch (15500 EC (adult tolerance - egg and larval tolerance not known)) Murray Hardyhead (80000 EC (low confidence)) Carp Gudgeon complex (9800 EC) Flat-headed Gudgeon (19200 EC) Dwarf Flat-headed Gudgeon (10800 EC) Australian Smelt (92200 EC (adult tolerance - egg and larval tolerance not known)) and Unspecked Hardyhead (68300 EC (adult tolerance - egg and larval tolerance not known)) (Bice and Ye 2009)

The large-bodied native freshwater fish of Lake Alexandrina all have a lifespan of at least several years Thus a short-term (three to five month) increase in salinity that exceeds the tolerance of eggs or larvae does not represent a significant impact to the species if adults are unaffected and can subsequently successfully reproduce when salinities return to tolerable

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levels for sub-adult life stages Large-bodied native freshwater fish species potentially present in the Lake Alexandrina at a water level of 15 m AHD and their respective adult salinity tolerances are Murray Cod (24 500 EC) Silver Perch (25 000 EC) Eel-tailed Catfish (28 000 EC) Golden Perch (Callop) (51 500 EC) and Bony Herring (54 500 EC) (Bice and Ye 2009)

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9) Thus construction of the temporary weir causes salinity to shift from tolerable to intolerable for the eggs or larvae of Carp Gudgeon complex Dwarf Flat-headed Gudgeon and possibly Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead Although the period of intolerable salinity is temporary it will lead to declines in their abundance in the Lower Lakes There are no modelled sites at which salinities will shift from tolerable to intolerable for large-bodied species

Carp Gudgeon complex Dwarf Flat-headed Gudgeon Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead

Declines or complete loss of small-bodied native freshwater fish

from Lake Alexandrina if this occurs is anticipated to be temporary All of these species occur in the River Murray channel and their downstream migration past the temporary weir (which is to feature a fishway) into the Lower Lakes is anticipated to recommence following the period of reduced flow (see page 13) during weir construction Therefore any declines in abundance due to the short-term increase in salinity levels associated with weir construction are likely to be temporary

Adult Common Carp have a salinity tolerance of ~23 500 EC (Bice and Ye 2009) Modelling indicates that the temporary increase in salinity levels caused by weir construction will not cause salinity to increase from tolerable to intolerable for adult Common Carp at any site Most of Lake Alexandrina will remain below the salinity threshold for this species Therefore the temporary increase in salinity caused by the temporary weir is not anticipated to cause a mass die-off of Common Carp or associated water pollution

Recently collected data puts the above discussion into context Fish surveys conducted during weeks 13 17 April 2009 in the Goolwa channel (between Clayton and Goolwa barrages) indicated the obligate freshwater fish community of this area of the Lower Lakes was composed primarily of three species Australian Smelt Flat-headed Gudgeon and Bony Herring (SARDI unpublished data) Salinities at Clayton during the same period ranged from ~18000 to ~24000 EC (DWLBC 2009) These three species are clearly able to persist in the Lower Lakes despite loss of connectivity with fringing aquatic vegetation and elevated salinity Their persistence indicates that both their habitat and feeding requirements are met When the water level in the main body of Lake Alexandrina falls to 15 m AHD triggering weir construction it is likely that the obligate freshwater fish community will be comprised primarily of these three species The temporary increase in salinity levels anticipated will not lead to salinities in excess of those that these species are currently experiencing in the Goolwa channel

The above discussion illustrates that the temporary increase in salinity levels caused by the construction of a temporary weir near Pomanda Island is unlikely to have a significant impact upon the resident native freshwater fish species of the Lower Lakes The temporary increase in salinity levels will cause salinity in Lake Alexandrina to shift from tolerable to intolerable for a small number of short-lived small-bodied native freshwater fish species However at the time of weir construction these species are likely to be in decline or absent due to other factors primarily the loss of fringing aquatic vegetation habitat unrelated to weir construction Additionally the unfavourable salinities caused by weir construction are predicted to be temporary and repopulation of the Lower Lakes via downstream migration from the River Murray channel is anticipated to occur following weir construction Ongoing fish monitoring of the lower lakes will provide further information regarding impacts to native freshwater fish

The above discussion has focussed primarily upon obligate freshwater fish of the Lower Lakes However a number of diadromous and estuarine species are also common in the Lower Lakes (Phillips and Muller 2006) The salinity tolerances of these species are much higher than those for obligate freshwater fish species (Bice and Ye 2009) and the temporary increase in salinity levels due to weir construction is not anticipated to have a significant impact upon diadromous or estuarine species

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It is likely that the impacts of the temporary weir upon fish in the Lower Lakes will be transferred to piscivorous birds Given that the temporary weir is unlikely to have a significant impact upon obligate freshwater diadromous or estuarine native fish species a significant impact upon piscivorous birds due to declines in native fish abundance is also unlikely Therefore piscivorous birds are not anticipated to be significantly impacted by weir construction

The impact of the temporary increase in salinity levels upon the invasive polychaete tubeworm Ficopomatus enigmaticus should be examined in the light of the research being undertaken by Dr Sabine Dittmann for the SA MDB NRMB The tubeworm itself has not been identified as a Matter of NES however changes to its abundance may impact upon Matters of NES

The Long-necked Tortoise is not listed as threatened under the EPBC Act nor is it considered a Ramsar-significant species or a primary determinant of ecological character for the CLLMM (Phillips and Muller 2006) The Long-necked Tortoise population of the CLLMM is therefore not a matter of national environmental significance and the impact of the temporary weir upon it is outside the scope of the EIS

Impacts upon tributary wetlands

A number of submissions were received regarding the impacts upon the ecosystems of the tributary wetlands of disconnection of surface waters and groundwater interactions caused by construction of the temporary weir

Response

The Swamps of the Fleurieu Peninsulas geographic distribution include swamps fringing Currency Creek Finniss River Goolwa Channel and Lake Alexandrina near Milang These swamps have already disconnected from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into Lake Alexandrina and were the first to disconnect at a water level of approximately +03 m AHD

The Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton (EPBC Reference No 20094833) The South Australian Government commenced construction of the regulator in June 2009 This regulator is expected to be completed in August 2009 and will result in the Goolwa Channel Currency Creek and Finniss River being disconnected from Lake Alexandrina

The Hindmarsh Island channels disconnected at approximately +01 m AHD These well-vegetated water bodies were significant habitat for the EPBC-listed Yarra Pygmy Perch and thus a captured breeding and recovery program has been implemented to ensure that the populations survive the current drawdown and can be released once water levels and habitat conditions improve

In terms of groundwater connection it is assumed that the tributaries and Lake Alexandrina will remain connected through groundwater at water levels less than -28 m AHD and thus could potentially be impacted upon by construction of the temporary weir During development of the EIS DWLBC staff were consulted on whether the predicted decrease in the Lake Alexandrina level of 210 mm near the tributaries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the water level drop caused by drought and over-allocation already experienced

Impacts upon the Milang Snipe sanctuary

One submission argued that the Draft EIS had not adequately addressed impacts upon the Milang Snipe Sanctuary

Response

The Milang Snipe sanc tuary is a very signific ant refuge for Japanese (La tham s) Snipe a recognised migratory species under the EPBC legislation and a listed species under the China Australia Migratory Bird Agreement (CAMBA) Japan Australia Migratory Bird Agreement (JAMBA) and the Republic of Korea Australia Migratory Bird Agreement (ROKAMBA) In

Supplementary EIS for the temporary weir near Pomanda Island -31shy

addition the presence of mature aquatic vegetation and the mosaic of ponds have provided excellent habitat for a suite of other waterbird species

The Japanese Snipe requires freshwater wetlands and vegetated meadows and preferably seasonal or semi permanent freshwater swamps Under a different hydrological regime the inundation frequency of the wetlands will change and the habitat will no longer remain optimal This site is a very good example of a wetland that may become compromised by altered hydrology

The Milang Snipe sanctuary is inundated when water levels in the Lower Lakes are high The site is currently dry The temporary weir is not anticipated to impact upon the water regime at the Milang Snipe sanctuary and therefore no significant impact upon the ecosystem of this site is predicted as a consequence of weir construction and operation

Impacts upon primary determinants of ecological character

One respondent noted that the summary of ecological impacts upon the primary determinants of ecological character (pg 12-20 section 126) appears to relate more to current drought-related ecological impacts and not specifically to the additional (likely to be small in comparison) ecological impacts of temporarily reducing flow to Lake Alexandrina

Response

This is agreed Additional comment is as follows Section 12-6 of the Draft EIS summarises the predicted impacts of the temporary weir upon the primary determinants of ecological character of the CLLMM Ramsar site It covers impacts to two primary determinants keystone aquatic plant species and habitat availability However it does not address the other four primary determinants outlined in the ECD It also fails to clarify the difference between drought impacts and weir impacts upon the primary determinants The following changes are proposed

In Section 12-6 pages 12-20 under the dot point Hab ita t ava ilab ility add the following four dot points

Salinity assigned a red light highlighting that conditions in 2006 were leading to loss of species (including keystones) and that salinities in the saline-estuarine units needed to be reduced urgently in order to maintain ecological character

Turbidity and sedimentation patterns assigned an orange light assessment highlighting that knowledge was poor and improved flows were required in 2006

Water levels assigned an orange light assessment highlighting that the regime in 2006 was counter-seasonal to the natural one and too static to support the full complement of the Lakes b iota and

Water regime particularly flow patterns in relation to inflows from the River Murray assigned a red light assessment highlighting that change to the ecological character of the site is largely a consequence of reduced flows from the River Murray

Additionally the first paragraph on page 1221 of the Draft EIS should be replaced by the expanded discussion under the six sub-headings which follow

Impact upon keystone species

Keystone aquatic plant species and assemblages in the Lower Lakes and tributary wetlands have become disconnected from the water body threatening their ongoing persistence Disconnection occurs at water levels below approximately +035 m AHD and is a consequence of the drought and upstream diversions Modelling indicates that disconnection will continue indefinitely under anticipated low flow conditions (see Section 10) with or without the weir in place The temporary weir will not alter the duration of disconnection between the keystone aquatic plant species and the water body The impact of the temporary weir upon this primary determinant of ecological character is therefore considered insignificant

Impact upon habitat availability

Habitat availability (particularly spatial and temporal connectivity) has been dramatically reduced by the drought due to the disconnection between the various parts of the system Key water levels for disconnection include

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+05 m AHD disconnection between the freshwater and saline-estuarine units occurs (permanent barrage closure is required to prevent seawater incursion into the Lower Lakes)

+035 m AHD disconnection between fringing aquatic vegetation of the Lower Lakes and the water body

03 m AHD disconnection between Lake Alexandrina and Lake Albert occurs and

12 m AHD disconnection between the Goolwa channel (and associated tributary wetlands) and Lake Alexandrina occurs

Water levels of lt 15 m AHD will persist for the 2010-2012 period (the nominal lifespan of the temporary weir) should low flows continue (896 GLyr at the SAVic border) whether the temporary weir is built or not (Section 10) Thus the temporary weir will have no impact upon connectivity within the Ramsar site connectivity having already been lost due to the drought However the temporary weir will have an impact upon connectivity between the River Murray channel upstream and the Coorong Lakes Alexandrina and Albert Ramsar site downstream The impact upon this loss of connectivity upon fish and potential mitigation measures is discussed in Section 1353 of the draft EIS

Impact upon salinity

As discussed on page 31 the impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9)

Impact upon turbidity and sedimentation patterns

The turbidity and sedimentation patterns in the Ramsar site are not predicted to be significantly impacted by the temporary weir The impact of current and ongoing low water levels upon this primary determinant of ecological character is anticipated to overwhelm any additional impact caused by the temporary weir The potential for temporary increases in turbidity during the construction phase of the temporary weir will be addressed by mitigation measures discussed in Sections 114 and 115 of the draft EIS

Impact upon water levels

The impact of the temporary weir upon water levels is discussed extensively in Section 10 of the d ra ft EIS Under both weir and no weir sc enarios wa ter levels in the Lower Lakes will be well outside those recommended by Phillips and Muller (2006) ie +01 to +08 m AHD Modelling shows that the temporary weir leads to lower water levels in Lake Alexandrina than would occur if it were not constructed but that the effect is reduced as time post construction increases (Table 10-7) Of particular note is the impact of weir construction upon the timing of exposure of sulfidic sediments in Lake Alexandrina Construction of the temporary weir is anticipated to lead to the critical water level of 15 m AHD which is expected to lead to acidification of the Lake being reached earlier than would occur if it were not constructed However modelling indicates that such water levels will be reached irrespective of a temporary weir being constructed should low flows continue Measures to avoid acidification are discussed in Sections 1126 and 15412 of the draft EIS

Impact upon water regime

The impact of the temporary weir upon water regime particularly flow patterns is considered insignificant

As indicated on page 32 the Angas and Bremer have been disconnected since 2007 and the Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton

Lake Albert was disconnected with the cessation of pumping from Lake Alexandrina on 30 June 2009

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By mid to late 2010 the water level in Lake Alexandrina will be at approximately 15 m AHD Thus the Lake will be disconnected from all other parts of the Ramsar site (ie the Coorong)

Thus any impact of the temporary weir upon water regime affects only Lake Alexandrina and the small area of the Ramsar site located upstream of the weir site The impact upon Lake Alexandrina is a temporarily increased rate of water level decline with various consequences discussed above The impact of increased water level upon the area of the Ramsar site upstream of the temporary weir and upon the River Murray channel upstream of the Ramsar site is considered to be positive provided acidification can be avoided or mitigated

Impacts upon migratory shorebirds

A number of submissions argued that the potential impacts of the temporary weir upon migratory shorebirds had not been adequately addressed Additionally several submissions expressed concern that by limiting the discussion of impacts to regularly recorded migratory shorebirds important impacts could be overlooked It was argued that species recorded infrequently and in low numbers should be a priority for protection as it is likely that they are more susceptible to localised impacts

Response

The temporary weir is unlikely to impact negatively upon the abundance of migratory shorebirds using Lake Alexandrina Under previous management arrangements the Lake was surcharged with water each year and only small areas of exposed mudflat were useable by shorebirds Over the past 18 months the wa ter line has rec eded and the Lake s edges have a t times been used preferentially (compared with the Coorong) for foraging purposes (Wainwright and Christie (in press))

Section 14 of the Draft EIS examines the likely interactions should the temporary weir proceed All migratory shorebirds are listed as matters of NES under the EPBC legislation The separation of seven spec ies into a group desc ribed as regula rly rec orded rela tes to the abundanc e of these species in comparison with any other migratory shorebird and tern species that have been observed a t Lake Alexandrina The regula rly rec orded group a re a t least two orders of magnitude more common Waterbird data collected monthly from 16 sites (2003 to current) around Lake Alexandrina informs this thinking

Impacts upon Australian Painted Snipe

A number of submissions argued that the Draft EIS should have addressed impacts upon the Australian Painted Snipe

Response

The Australian Painted Snipe is nomadic and adopts wetlands opportunistically It requires freshwater and well vegetated wetlands with internal complexity Recent records from Lake Alexandrina are scarce (Letch 2007) presumably because the recent drought has eliminated all suitable habitats However historic records suggest that the fringing habitats around Lake Alexandrina when intermittently favourable have been frequented by the species Recent information suggests that the Australian Painted Snipe may be present close to the site of the temporary weir

Low water levels in the Lower Lakes appear to have led to a significant loss of habitat for the Australian Painted Snipe However given the suggestion that it may be present in the vicinity of the temporary weir construction area it should be considered in the EMP to be prepared for weir construction

Impacts upon Orange-bellied Parrot

One respondent noted that discussion of the Orange-bellied Parrot did not mention the importance of samphire habitat to this species One submission argued that potential impacts upon the Orange-bellied Parrot had not been properly addressed in the Draft EIS

Response

Within South Australia the Orange-bellied Parrot appears to be less dependent than previously suspected on samphire vegetation Recent observations in South Australia suggest that the

Supplementary EIS for the temporary weir near Pomanda Island -34shy

species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

The Orange-bellied Parrot is critically endangered and interactions with proposed weir operations are considered possible The species is known to use a range of habitats including highly disturbed areas Accordingly it is a subject discussed in Chapter 13 of the draft EIS

Impacts upon Great Egret Cattle Egret and Caspian Tern

One respondent expressed concern that the Great Egret Cattle Egret and Caspian Tern are not dealt with satisfactorily One submission noted problems with the nomenclature concerning egrets

Response

The two Egret species being discussed in Section 761 are the Great Egret Egretta (Ardea) Alba and the Cattle Egret Ardea ibis Both species are listed migratory species under the EPBC legislation The Cattle Egret is listed as a migratory species using the binomial Ardeola ibis The reference in Section 77 to the White Egret for consistency should read Great Egret Both are recognised English names for the species Egretta (Ardea) Alba

The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in south-eastern Queensland and north-eastern New South Wales (Marchant and Higgins 1993)

The movements of Caspian Tern are poorly understood they are partly resident partly dispersive and possibly partly migratory (Marchant and Higgins 1993) The species is commonly observed on fresh and marine waters foraging on the wing for fish

Impacts upon pelagic birds

One submission argued that potential impacts upon pelagic bird species had not been properly addressed in the Draft EIS

Response

Pelagic bird species listed in the draft EIS (including all listed Albatross species Blue Petrel Giant Petrels and the Soft-plumaged Petrel) are all oceanic species that have no dependence on Lake Alexandrina for food or habitat Their presence at the site is fortuitous Records are mostly of ocean beach-washed specimens or live animals temporarily blown inland during storm events The weir construction has no effect on their endurance

Impacts upon bush birds

One submission argued that potential impacts upon bush bird species had not been properly addressed in the Draft EIS

Response

The Black-eared Miner Red-Lored Whistler Malleefowl and Regent Parrot are all species that require mallee or woodland habitats that are now largely absent from the edges of Lake Alexandrina These bird species are now locally extinct from the Lakes area because of landscape scale changes to adjacent woodland and mallee habitats Recent observations of these spec ies in the reg ion (as c ited in The Natura l History of Stra tha lbyn and Goolwa Distric ts 2000) are from locations that support very different habitats to those immediately adjacent to

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the Lakes It is highly unlikely that any of these species would be affected by the temporary weir

The Spotted Quail-Thrush is now considered extinct in the Mount Lofty Ranges and Fleurieu Peninsula

Impacts upon Mt Lofty Ranges Southern Emu Wren

Several submissions argued that potential impacts upon the Mt Lofty Ranges Southern Emu Wren had not been adequately addressed in the Draft EIS

Response

The Mount Lofty Ranges Southern Emu-Wren is recognised as an endangered species that inhabits fragmented wet and dry heath in the vicinity of the proposed weir site The nearest known rec ords of the spec ies (sourc e Biolog ic a l Da tabases of SA ) determined by extensive surveys are 35 kilometres from the temporary weir site at the top of the Finniss estuary It most unlikely that the temporary weir proposal would impact negatively on the species however it has been considered in the discussion about impacts in Chapter 13 of the Draft EIS

Impacts upon White-bellied Sea Eagle

One submission argued that potential impacts upon the White-bellied Sea Eagle had not been properly addressed in the Draft EIS

Response

The White-bellied Sea Eagle is regularly observed but not so commonly recorded in the Lower Lakes and Coorong area The species exploits the protected waters at both sites for fishing A recent sighting of a juvenile bird suggests that local breeding also occurs The implications of the temporary weir on this species are outlined in Chapter 14 of the draft EIS

Issues of scope adequacy and definition

Adequacy of species and communities examined

There were a significant number of submissions on this issue and one respondent who argued that the Draft EIS was inadequate in its assessment of ecological impact because the range of species and communities examined was too limited The Draft EIS assessment was constrained to the Matters of NES listed in the EPBC referral documents Submissions raise the criticism that all components of the Ramsar site should be assessed not just nominated Matters of NES because they are interconnected and interdependent

Response

This statement is true in terms of defining changes to ecological character of the Ramsar site And if the temporary weir were to be built under normal operating conditions all ecological components would have been assessed However the impacts of the temporary weir per se were restricted to those ecological components that would occupy the Ramsar Type O (permanent freshwater lakes) wetlands at a water level of -15 m AHD because this will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir

It is also assumed that at -15 m AHD there will be little or no aquatic vegetation in the Type O wetland because historical high turbidity and static water levels have precluded growth of plants that far out into the Lakes The water body that remains would generally be several kilometres from the existing aquatic plant seedbank and would remain very high in turbidity and experience high energy water movement Thus it is not predicted that keystone aquatic plant species will colonise this area before construction of the temporary weir The benthos was not assessed specifically and further research into the species and distribution of benthic fauna at very low lake levels would improve this draft EIS particularly given the dependence of EPBC-listed fish and bird species on benthic fauna

Impacts on other Ramsar Wetland Types (that is the rest of the Ramsar site) were not considered because the impacts of the drought and over allocation were considered to be the primary determinants of change in ecological character for those wetlands

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Current status of waterbirds

One submission noted that the current status of waterbirds and migratory shorebirds at the CLLMM had not been adequately stated and that recent research (Kingsford 2009) had not been referred to

Response

Most waterbird species are migratory to some degree Some species have predictable movements but most species respond opportunistically to climatic events that bring about favourable changes in habitat quality or food resources Local and continental rainfall patterns have a strong influence on the abundance of waterbirds using the Lower Lakes At the continental scale there were significant changes in the amount of rainfall (and subsequent change in area of wetland habitat) between November 2007 and early 2009 In late 2007 the Murray-Darling and Lake Eyre Basins were both drought affected During 2008 South-eastern Queensland and northern New South Wales received record rainfall and a 1-10 year flood occurred in the Lake Eyre Basin The entire populations of some species (Pink-eared Duck for example) respond to these events adopting the most favourable habitat available The large amount of variability in waterbird numbers is expected and it is a strategy waterbirds use to survive the natural variability in the Australian climate

Regular bird survey work at 23 sites around Lake Alexandrina during the last 12 months suggests that there are no detectable changes in the species richness of waterbirds using the Lower Lakes There are more obvious changes in abundance and as a generalisation waterfowl numbers have decreased while shorebird abundance has increased

Adequacy of EPBC Act threatened species and communities lists

One submission argued that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the Murray-Darling Basin including the CLLMM region are currently being evaluated for EPBC listing

Response

The scope of the EIS is confined to Matters of NES Only nationally listed threatened species or nationally listed migratory species or those that contribute to the ecological character of a Ramsar site are matters of NES Species and communities that are under evaluation for listing as threatened but not yet listed are not matters of NES

Adequacy of discussion of EPBC Act-listed species

One submission argued that the discussion of EPBC Act-listed species in the EIS is incomplete and superficial

Response

Additional detail regarding potential impacts to EPBC Act-listed species is provided in several chapters of this supplementary EIS

Omitted flora and fauna records

Natura l History of Stra tha lbyn and Goolwa Distric ts (2000) (Stra tha lbyn Natura lists Club Inc ) and the Tolderol Wetland Management Plan Severa l submissions mentioned tha t the

c onta in information on a number of EPBC Act-listed species that have been recorded in fringing wetlands of the Lower Lakes but were not discussed in the EIS

Response

Natural History of Strathalbyn and Goolwa Distric ts (2000) and the Tolderol Wetland Management Plan may revea l EPBC Act-listed species that have been recorded in the CLLMM in addition to those mentioned in the draft EIS However given the current disconnection of the wetland habitats of the area and the predicted absence of any impact of the temporary weir upon their water regime the temporary weir is not anticipated to cause a significant impact upon the wetland-dependent species of the fringing wetlands of the Lower Lakes

A more thorough examina tion of the litera ture foc ussing on the

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Definition of keystone species

Severa l submissions a rgued tha t the term keystone spec ies had been misused in the Dra ft EIS It was argued that all species that are critical to food chain processes in the Lower Lakes (ie keystone species) should be identified and discussed and that conceptual models detailing the importance of these key biota would help the reader to understand the processes

Response

The Ecological Character Description (ECD) for the site (Phillips and Muller 2006) describes the keystone species of the CLLMM The draft EIS uses the same language and examples of keystone species as does the ECD Correcting an incorrect ECD is beyond the scope of the EIS

Species considered of particular significance

One submission argued that Murray Hardyhead Yarra Pygmy Perch and Murray Cod should be on the partic ula r signific anc e list

Response

list (Section 7-5 of the Draft EIS) The impact of the temporary weir upon these species is examined in Chapter 13 of the Draft EIS

Murray Hardyhead Yarra Pygmy Perc h and Murray Cod a re on the partic ula r signific anc e

Adequacy of description of different wetland types

A number of submissions argued that the ecological information regarding each of the 15 wetland types of the CLLMM was inadequate to assess impacts of the temporary weir upon them

Response

The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170mm occurs only during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD is not a direct impact of the temporary weir and thus is beyond the scope of the draft EIS

Regional importance of the Coorong Lower Lakes and Murray Mouth

It was noted in several submissions that the Chowilla Ramsar wetland has been disregarded as it is greater than 200km from the Lower Lakes and Coorong The EIS needs to consider the regional implications of a degraded Lakes and Coorong and the use of aquatic habitats by migratory bird species If environmental water is not being delivered to the Lower Lakes and Coorong provision for suitable aquatic habitat needs to be made in other areas of the state as a minimum

Response

The proponent notes that both the CLLMM and Chowilla Ramsar sites are regionally significant and that adequate inflows to maintain the ecological character of both are required This issue is outside the scope of the Draft EIS

Australia s Ramsar obligations

A number of submissions raised the issue that Australia does not appear to be committed to wise use of the Coorong and Lakes Alexandrina and Albert Ramsar site and its obligations

under the Ramsar Convention in terms of proposing that this temporary weir be built

Response

The principal factor impacting on the Ramsar site is the low flow of freshwater to the site particularly over the last few years of drought and over-allocation across the Murray-Darling Basin ra ther than a lac k of c ommitment to wise use

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6 Notes on significant issues outside the scope of the draft EIS

For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities

Notes on social and economic issues raised in submissions

In this section a number of significant concerns and ideas detailed in submissions by individuals organizations and local government are canvassed

These concerns and ideas do not focus on Matters of NES protected under Part 3 of the EPBC Ac t and as suc h a re outside the sc ope of Guidelines for the Content of a Dra ft Environmenta l Impact Statement on the Proposed Temporary Weir at Pomanda Island near Wellington South Australia Environment Protection and Biodiversity Conservation Act 1999 (Reference Number 2007 3484) da ted 30 August 2007

However they are registered here because they reflect strong community positions

These concerns and ideas will be taken into consideration during the development of the long term plan for the Coorong Lower Lakes and Murray Mouth region The first step in developing the long-term plan was the release of the Directions for a healthy future document for public c omment during May 2009

Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

One submission raised concern that Ngarrindjeri People has to compete for attention in the consultation process

An additional concern is that the Ngarrindjeri People is not recognised as Traditional Owners

The Coorong District Council emphasized that the Coorong and Lower Lakes have particular significance to the Ngarrindjeri and

Another submission (supported by the River Lakes and Coorong Action Group) stated tha t the Dra ft EIS d isp lays little or no understand ing of the importanc e of c ultura l flows to the Ngarrindjeri

Social and economic issues

A number of submissions noted the lack of content in the Draft EIS on social and economic measures associated with the temporary weir

Generally submissions from individuals organizations and local government indicate that the current social and economic conditions in the Coorong Lower Lakes and Murray Mouth area (as a result of drought lack of fresh water River flows and over allocation of water resources across the Murray-Darling Basin) are very negative When putting forward these concerns submission writers did not usually make clear how the construction of the temporary weir will further contribute to enhancing negative social or economic trends

A submission from the Southern Alexandrina Business Association Inc claims that the boating industry in the region under current conditions is losing $200 million per annum

A detailed submission from the Boating Industry Association of SA Inc claims that business of the leisure tourism and recreational sector and those that support them are suffering enormously from the existing droughtover allocation conditions The

Supplementary EIS for the temporary weir near Pomanda Island -39shy

submission proposes that we need to replenish water stocks including water for the environment Water for the Community and water for the EconomyTertiary Sector

The Rural City of Murray Bridge is concerned that professional fishermen can move up and down the River

The Coorong District Council notes that the dairy industry irrigated horticulture fodder production and beef cattle production have been negatively impacted by lack of access to water Property values have declined by 50 per cent in some cases and most of the 17 dairies in the Coorong District have closed or relocated Council rate revenue is down and

One submission (endorsed by other submission writers) provides a researched and extensive argument about the predominance of contemporary social and economic ideas which favour growth for example of expansionary plantings of a variety of unsustainable crops and growth of human populations and notes the South Australian population expansion in the South Australia Strategic Plan The writer suggests that new ideas about limitations and replenishments are required as well as a move towards adoption of tools like the Genuine Progress Indicator rather than reliance on indicators like Gross Domestic Product

Climate change

One submission asked for a rethink of the Draft EIS based on additional scenarios to the d rought sc enario whic h preva ils in the d ra ft EIS This sc enario is based is the worst

case climate scenario to date

Dust and health

A number of submissions raise concerns about current health problems caused by excess dust being blown from the dry lake bed

Other themes

A number of submissions a rgued tha t the temporary would nec essarily bec ome permanent and some of these argued that a navigable Lock with fish passages would therefore be preferable

A number of submissions argued for a seawater solution rather than a limited inflow to control the possible risks associated with ASS

Some submissions especially from government agencies or Non Government Organisa tions (NGO s) pointed out tha t further approva ls will be required in add ition to those cited in the Draft EIS The MDBA advised that it will require at least six weeks to undertake its approval processes from the time that the additional details are provided On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

Supplementary EIS for the temporary weir near Pomanda Island -40shy

7 Suggested text changes errata additions clarifications and

references

Page Issue raised by submission(s)respondent(s)

Recommended changes

vi Page vi acid sulfate soils box last sentence should read See Chap ters 6 8 11 and 15 for d eta ils

Make suggested changes

115 Pg 1-16 section 152 Environment Protection Act 1993 The Environment Protection (Air quality) Policy could also be included in this section as it applies to potential dust and noise impacts

Reword sentence 1 paragraph 1 section 152 page 115 to read

The Environment Protection Act 1993 (the Environment Protection Act) and the Environment Protection (Air quality) Policy provide legislation for the protection of the environment and the establishment and definition of the powers and functions of the Environment Protec tion Authority (EPA) in South Austra lia

116

12

27

Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

Apparent inconsistency in water usage figures between Table 1-1 and pages 2-4 and 2-12

Pg 2-7 section 24 Red uc ed ra infa ll and

dec rea sed evapora tion should be increased evaporation (many of these inconsistencies throughout document)

Reference to Section 1554 should be changed to Section 15412 Acid Sulphate Soils Safeguards and Mitigation Measures and Table 15-6 titled Potential mitigation measures to manage acid sulphate soils

Appendix 1 question 91 provides clarification

Page 27 rep lac e text Red uc ed ra infa ll and d ec rea sed evapora tion with text Red uc ed ra infa ll and inc reased eva p ora tion

Supplementary EIS for the temporary weir near Pomanda Island -41shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

27 Issues raised concerning the accuracy of the data in Table 23 page 27

Update Table 2-3 to include the following

200607 Inflows

Total flow at the SA Border 1436 GL

Eastern Mount Lofty Ranges estimated inflow 39 GL

200607 Use and Loss

Net Loss(1) 1262 GL

SA Water pumped extraction(2) 245 GL

Irrigation Extraction(3) 377 GL

Total System Deficit -448 GL (4)

(1) Net loss is inclusive of evaporation seepage rainfall EMLR inflows unmetered diversions

(2) SA Water pumping from the River Murray includes 60 GL of water pumped to the MLR reservoirs for use in 200708

(3) note as in document

(4) Deficit is defined as Inflow at SA Border - losses - SA Water pumping - irrigation extraction and corresponds with the fall in water level in Lakes Alexandrina and Albert

2-13

213 219

215

References to 696 GLyr of dilution flow should be clarified

2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Pg 2-15 section 26 Current water level statement (-05m AHD) was incorrect at the time of EIS publication and should be updated and referenced

Appendix 1 questions 9 and 88 provide clarification

Reference to 940 GL on pages 213 and 219 should be changed to 896 GL

The water level in Lake Alexandrina is now at a new record low of -095 m AHD (reference Murray Darling Basin Authority Murray River System Drought update issue 18 APRIL 2009)

The MDBA drought upd a te sta tes tha t During winter in the absence of significant inflows reduced evaporative losses should allow the water level to remain fairly steady and even under a worst case scenario Lake Alexandrina is unlikely to reach the estimated acidification trigger of -15 m AHD prior to February 2010

Supplementary EIS for the temporary weir near Pomanda Island -42shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

215 The salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences

Delete Table 2-4 from the document It is not referred to in the text and therefore serves no purpose Add following text to section 26 para 3

Historic a lly Lake Alexand rina wa s a p red omina tely freshwater system with only brief periods of seawater intrusion during low outflow periods that did not extend beyond Point Sturt (Sim and Muller 2004) DEH is in process of contracting more work to The University of Adelaide to verify this understanding of the pre-European salinity regime of both Lakes Alexandrina and Albert by studying diatom species distribution in dated cores It is predicted that by May 2009 water in the Lake is expected to be at ~6000 EC (Figure 2-11) which is considered to be saline in terms of ecological func tiona lity (Williams 1986)

2-16 11-9 Section 1554 does not exist

The reference to section 1554 should read section 15412 Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant

334 Pg 3-34 Environment Protection (Water Quality) Policy 2003 The Environment Protection (Water Quality) Policy 2003 should be listed under legislation rather than policy section of this table

337 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

337 Pg 3-37 Table 3-5 The National Water Quality Management Strategy should be included in Table 3-5 as this is tool that is being utilised in this region for integrated catchment management to achieve improved water quality outcomes

349 Pg 3-49 Table 3-9 ASS and water quality the Centre for Water Research model should be grouped under this section together with EPACSIRO

4-4 Details and status of SA Water Corporation pump station upgrades

Update Table 3-4 beginning page 331 such that Environment Protection (Water Quality) Policy 2003 is listed under South Austra lian Leg isla tion instea d of und er Sta te Polic y and Pla nning Frameworks

In Table 3-5 Page 337 and anywhere else in the doc ument it is mentioned d elete referenc e to Na tiona l Ac tion Plan (NAP) and rep lac e with Caring for our Country (CFC)

Include National Water Quality Management Strategy in Table 3-5

In Table 3-9 inc lud e Centre for Wa ter Researc h a long with EPA CSIRO in row 3 c olumn 3

Upd a ted sta tus d eta ils of SA Wa ter Corp ora tion s pump station upgrades are provided in Appendix 1 question 14

Supplementary EIS for the temporary weir near Pomanda Island -43shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

442

5-8

510

517

61

Page 4-8 sta tes Costs for undertaking a similar ac tion for Ad ela id e s off takes from the Lower Murray are expected to be very significant (see table 4 3) and the implementation period would be approximately 3 yea rs from initia tion

58 states that once the water level exceeds +01m AHD the temporary weir will cease to serve any useful function

The last paragraph in section 542 should be rep la c ed with The fina l most viable solution may involve multiple rock types from multiple sources to achieve the optimum construction cost within the limited time frame Rock sources with clays fine silts and sands while suitably geotechnically may not be utilised to reduce the potential for environmental impact through turbidity and sedimentation

Insert the following for Section 563 Section 563 of the draft EIS only partially refers to the environmental safeguards and mitigation measures Section 563 should be ignored and Chapter 15 be referred to for safeguards and mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Management Plan (EMP)

Paragraph 1 page 6-1 needs to include rainfall on the Lakes as an input to the system

Delete reference to Table 4 3 from the document

Appendix 1 question 52 provides clarification

Page 510 make suggested changes

At the end of section 563 page 517 add the sentence

Chap ter 15 should b e referred to for sa feguard s a nd mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Ma nagement Pla n (EMP)

Reword sentence 2 paragraph 1 page 61 to read

Freshwa ter from the River Murray the Eastern Mount Lofty Ranges (EMLR) catchments Upper South East (USE) drainage scheme direct rainfall onto the lakes and from groundwater as well as salt water from the Southern Oc ea n a ll input to the Coorong a nd Lower Lakes site

Supplementary EIS for the temporary weir near Pomanda Island -44shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

61 Last paragraph of 61 needs to include a further condition in the list - that of the MDB before the advent of white people as that is the condition that has determined which species live amp belong here

For the sc ope of the d ra ft EIS the baseline c ond itions of the CLLMM are those that existed when the site was listed as a wetland of international significance under the Ramsar convention These conditions are discussed in the Ecological Character Description (ECD) for the site (Phillips and Muller 2006) The draft EIS correctly uses the ECD as a baseline regarding condition It should be noted that many parameters that describe the conditions of the CLLMM are currently beyond the acceptable limits of change as outlined by the ECD due to drought and over-allocation of water

63 Issue raised concerning wording of paragraph 4 page 63

63

65

Issue raised concerning impact of static water levels page 63

Issue raised concerning Barra ge Opera tion Page

65

Change text in paragraph 4 p 6-3 to read

Aquatic vegeta tion has sinc e declined due to static water levels such that only a fringing band of vegetation around the +03 to +06 m AHD water marks remains of the extensive submerged and emergent beds that extended several kilometres into the Lakes pre-European settlement (Sim and Muller 2004)

Remove first bullet point under Figure 6-1 d egra d ed shorelines in sheltered a rea s

Add text below as a new fourth and fifth paragraph under barrage operation (p 6-5)

The b a rrages impede ec o log ic a l c onnec tivity between the fresh estuarine and more saline parts of the Ramsar Of particular concern are the adverse impacts on fish migration and transfer of recruits from one part of the system to another Fish passages have been installed on some gates to facilitate fish movement during periods of barrage opening and the Barrage Operating Strategy seeks to optimise ecological outcomes with each barrage release

The Lower Lakes barrages have not been opened since October 2006 thus there has been no hydrological connectivity between the fresh and estuarinesaline a rea s of the Ramsar site sinc e then

66 Issue raised concerning Ripa ria n La nd

Ma nagement page 66

Add text below as second paragraph under Riparian land management (p6-6)

Inva sion of pest p la nts a nd a nima ls into the wetland s is also a major issue particularly given the close proximity of the agricultural land and the large expanses for wind and water borne weed s to b e d ispersed

69 Issue raised concerning keystone species listed on page 69

Change text in second bullet point under the keystone species for freshwater lakes include (p 6-9) to read

Assemb lages of emergent p la nts (eg Sc hoenop lec tus sp Baumea sp Phragmites australis) along the fringes of the lake and EMLR tributa ries

Supplementary EIS for the temporary weir near Pomanda Island -45shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

610 Issue raised concerning list of factors that influence aquatic plants bottom of page 610

Reword the statement at the bottom of page 6-10 of the Draft EIS with the following

Ganf (2000) identified four issues influenc ing the productivity distribution and community composition of macrophytes

salinity

turbidity

water regime and

wind and wave action

These factors combined mean that submerged aquatic plant growth is restricted to the littoral zone of the mod ern lake environment (Phillip s and Muller 2006)

612 Issue raised concerning wording of caption for Figure 66 page 612

612 Issue raised concerning section 63 page 612

614 A Respondent questioned page 6-14 section 65 of the Draft EIS determinants or drivers

72 73 Bool amp Hacks Lagoons are not upstream of this temporary weir as is implied in the text

74 Page 7-4 section 733 An error messages appears

75 736 Type M permanent rivers streams amp creeks -Lake Alexandrina also takes the flow from the Rivers Angas amp Bremer amp Mosquito Creek between Milang amp Langhorne Creek

Pg 6-12 Figure 66 c ap tion should rea d d rivers a nd levers (not d rivers and levels )

Section 63 shy Pg 6-12 Include the following text as sentence 2 of paragraph 3

Direc t ra infa ll on the lakes a nd evapora tive losses a re key components of local climate that have the potential to impact greatly on the resultant water reg ime of the site

Sec tion 65 first p a ra graph rep lac e The p rima ry d rivers for ecological character includ e with The p rima ry determinants of ecological character are (Phillips and Muller 2006)

Reword sentence 1 paragraph 2 section 73 page 72 as follows

Banroc k Sta tion Wetla nd Complex Riverland wetla nd s and Hattah-Kulkyne Lakes are located more than 200 km (minimum) upstream of Pomanda Island and are unlikely to be a ffec ted by the temporary weir

Following sentence 1 add additional sentence

Bool and Hacks Lagoons are located outside of the MDB and over 200 km from Pomanda Island and will therefore b e una ffec ted b y the temp ora ry weir

Rep la c e text Error Referenc e sourc e not found With text Figure 7-2

The Rivers Angus and Bremer and Mosquito Creek are classified as wetland Type N -seasonalintermittentirregular riversstreams and creeks These tributaries should be referred to in Section 737 of the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -46shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

731 756 Plant associations in close proximity to the temporary weir Only one of the 11 dot points is actually a plant association

Reword the sentenc e The p lant a ssoc ia tions in c lose p roximity to the temp ora ry weir site inc lud e to read

The d ominant or c o-dominant plant species in close proximity to the temp ora ry weir site inc lud e

Replace dot point Muehlenbeckia florulenta tall open shrub land with Phra gmites a ustra lis with two d ot points

Muehlenbec kia florulenta

Phra gmites austra lis

732 Page 205 - Table 7-6 should be checked for accuracy Cattle Egret is not EPBC listed migratory species

According to the EPBC Act website Cattle Egret is a listed migratory species therefore its listing in Table 7-6 is correct See

httpwwwenvironmentgovaucgishybinspratpublicpublicspeciespltaxon_id=59542`

Chapters 4 and 9

101

102

102

Text in the executive summary chapters 4 and 9 erroneously includes the use of toxins when the intended meaning is in fact toxicants Toxins are substances produced by living cells such as algal toxins etc whereas toxicants are a broader range of chemicals that produce a toxic response in living organisms

Correct the assertion in 102 Existing drought conditions that the dropping of Mungkuli (Lake Alexandrina) to below sea level for the first time in 7500 years is due to drought

Chapter 10 - Figure 10-1 -Lake Alexandrina water level 1962-2008 Full supply level = +075m AHD - EIS is incorrect

Tookayerta Creek is a tributary of the Finniss River and not Lake Alexandrina as stated Further the Finniss River and Currency Creek flow into the Lower Murray not into Lake Alexandrina

Delete the word toxins from c ha p ters 4 a nd 9 and rep la c e with the word toxic a nts

Change sentence to read

In rec ent times the wa ter level in the River Murray Coorong and Lower Lakes has been significantly lowered by the existing drought conditions and over-allocation of water associated with the entire MDB (Table 10 1)

It is the proponents understanding that +075 m AHD is referred to as full sup p ly level and tha t wa ter levels above this a re referred to as a surc ha rge

Reword sentenc e The EMLR tributa ries tha t d isc harge into Lake Alexand rina a re to read The EMLR tributaries that discharge into Lake Alexandrina and the Lower Murray a re

Delete d ot point Tooka yerta Creek from the bottom of page 10-2

Reword d ot point Finniss River to rea d Finniss River (inc lud ing Tookayerta Creek)

Supplementary EIS for the temporary weir near Pomanda Island -47shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

104

1013

1030

1030

Figure 10-3 Goolwa amp Lake Alexandrina Salinity Survey results - September 2008 EIS in error re the salinity level of Lake Albert This figure 10-3 states that 7300EC (which is approx

sea wa ter) is semi-saline

1035 - Predicted water level in Lake Alexandrina -water levels are also affected by rainfall which is not mentioned

To say that potable water supply is less than 2500EC is pushing the boundaries PIRSA documents state a salinity of 1000mgL (1666EC) is generally palatable to most tastes but up to 1500mgL (2500EC) can be acceptable in areas where better quality water is not available

The tolerable salinity limits for freshwater species needs to take into account peak levels not average levels

The d efinition of semi-sa line is p rovid ed in Tab le 2-4 of the draft EIS and refers to salinities between 5001 and 11666 EC Thus the document is consistent

Reword first sentence of Section 1035 as follows

Historic a lly wa ter levels in La ke Alexand rina have varied on a seasonal basis with water rising in winter through increased winter inflows direct rainfall and decreased evaporation and falling in summer through red uc ed inflows a nd inc reased eva p ora tion

This point is noted however it has no bearing upon the temporary weir since salinities in Lake Alexandrina are predicted to reach gt2500 EC throughout the lake during 2009 with or without the temporary weir

In Section 1043 (page 10-30) delete paragraph 3 since it has no biological or ecological relevance Revise paragraph 4 to read

Pea k or maximum sa linities a re most important ecologically because all aquatic species have salinity tolerances that if exceeded even briefly can be fatal Table 10-9 presents modelled peak salinities at points in Lake Alexand rina und er without weir and with weir scenarios during the first year of weir operation For all points modelled peak salinity in the first year is higher und er the with weir sc ena rio

10-32 Reference to 685 GL as extra water available is misleading

Agreed Clarified in Appendix 1 question 32

Supplementary EIS for the temporary weir near Pomanda Island -48shy

a ns

Page Issue raised by

submission(s)respondent(s) Recommended changes

1113 Pg 11-13 Figure 11-5 This graph could be updated to 2009 using current EPA data

Update Figure 11-5 on page 11-13 with the following which includes the most recent data

Turbidity Lake Alexandrina - Poltalloch Plains

20

40

60

80

100

120

140

160

180

200

24-Jul-98 6-Dec-99 19-Apr-01 1-Sep-02 14-Jan-04 28-May-05 10-Oct-06 22-Feb-08 6-Jul-09

Date T

u rb

id it

y (N

T U

)

Lake Alexandrina - Poltalloch pl i Ecosystem protection guideline (ANZECC)

0

121 Section 121 It is certain that the temporary weir will interact with ecological values of lower river amp lakes

121 Pg 12-1 section 122 Bottom of page 12-1 In general temporary wetlands have few animal species than permanent ones is this referring to abundance or richness or what Too general and incorrect in some circumstances

122 Chapter 123 - Ramsar listed wetland upstream of expected weir site near Pomanda Island - EIS incorrect amp needs amendment

Delete the word may from sentenc e 1 p a ra grap h 3 section 121 page 121

Bottom of page 12-1 delete the following sentenc e In general temporary wetlands have fewer animal species than p ermanent ones

On pg 12-2 rep lac e the text There a re no Ra msar-listed wetla nd s between Loc k 1 a nd the temp ora ry weir site with the following There a re no Ramsa r-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ra msar site

Supplementary EIS for the temporary weir near Pomanda Island -49shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

125 Issues raised concerning wording of Table 123 commencing page 125

In Table 12-3 make the following changes

For Cla ss M ad d text to sixth c olumn Inc reased hea d pressure may result in increased drainage to the lakes and reduced groundwater baseflow in groundwater depend ent ec osystems

For Class M seventh column change existing sentence to read there is no interac tion of the weir with the surfa c e wa ter in these wetlands

For Class M add sentence to third column that reads Inc reased head p ressure of up to 21 c m may result in

c hang e in ground wa ter b a seflow

For Cla ss 4 und er Imp a c t of p roposed tempora ry weir within Ramsar wetla nd s to existing text ad d whic h oc c urs a t wa ter levels gt 087 m AHD

For Cla ss Xf und er Existing c ond ition (a p p roxima tely shy05 m AHD) rep la c e No rec ord ed c ha nge with Not connected to the main body of the lake Will only be a ffec ted b y ongoing d rought

For Cla ss Tp c hange text in sixth c olumn to read Most disconnected but some reconnection and marginal improvement from winter ra infa ll and tributa ry inflows

Formatting issue in title of sixth column the negative is there in the column heading but there has been line split between it and 15 so it looks like +15 m AHD not -15 m AHD (should be latter)

1215 Issue raised concerning wording of Section 125 page 1215

Reword Section 125 (pg 12-15) in its entirety to read

As d eta iled in Sec tion 1241 a ll wetland hab ita ts downstream of the proposed temporary weir location are expected to be affected by the drought and by 2012 only Ramsar-wetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flows as described on page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

1216 Issue raised concerning potential positive impact of rewetting of acid sulphate soils

Section 1251 page 1216 remove reference to re-wetting of acid sulfate soils and pH drop to 2 (last dot point) from positive impacts list

Supplementary EIS for the temporary weir near Pomanda Island -50shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

12-20 Table 12-4 only lists predicted changes for 2 out of 6 primary determinants of ecological character

Update Table 12-4 to include the following

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts

(2010 2012)

Salinity Discussed extensively in Section 10

Water Level Discussed extensively in Section 10

Water Regime Discussed extensively in Section 10

Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

1310 Issue raised concerning comprehensiveness of Table 133 page 1310

To Table 13-3 insert two additional rows

1st c olumn Intera c tion 2nd c olumn Disrup t d ispersa l of tadp oles

1st c olumn Spec ies p referenc e 2nd c olumn Present upstream and downstream of site but dispersal requirements of d ifferent p op ula tions a re unknown

141 Section 141 What is the definition of regularly recorded amp by whom were they recorded

In sec tion 141 p a ge 141 p a ragraph 4 rep lac e (see Chapter 7) with (Letc h 2007)

1519 pg 15-19 section 15412 Performance criteria The acid sulfate soil trigger levels are given in Table 15shy6 not Table 15-5 as stated in the document

In d ot p oint a t bottom of page 1519 rep lac e Tab le 15shy5 with Tab le 15-6

1519 Remove Table 15-5 There are no cross-references to the table

Table 15-5 is referred to on page 1519 and should be retained in the document

162 The summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Additional comment o be inserted in Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir) after text

The ECD of the Coorong and Lakes Alexa nd rina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Nationally listed threatened and migratory species are addressed elsewhere in this table Other species are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetla nd s will persist

Supplementary EIS for the temporary weir near Pomanda Island -51shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

Throughout document

Throughout document

Throughout document

Australia operates on SI system of measurements amp this includes the millimetre metre units of measurement amp does not include centimetres

Convert centimetres to millimetres or meters as appropriate throughout the document

Correct injustice throughout draft EIS of identifying Ngarrindjeri merely as custodians community or people (112 164 165 171 1522)

Cha nge Ngarrind jeri c ustod ians and Nga rrind jeri c ommunity to Ngarrind jeri Peop le as ap p ropria te

throughout the document (as per submission PTW00046)

Text in the executive summary and throughout the document (chapters 1 2 4 8 11 12 13 15 and 16) refers to the use of the wording heavy metals when in fact this is misleading and should simply be referred to as metals

Rep la c e a ll referenc es to hea vy meta ls with meta ls

Supplementary EIS for the temporary weir near Pomanda Island -52shy

References

Bice C and Ye Q (2009) Draft Report - Risk assessment of proposed management scenarios for Lake Alexandrina on the resident fish community South Australian Research and Development Institute (Aquatic Sciences) Adelaide South Australia

DWLBC (2009) River Murray Data Department of Water Land and Biodiversity Conservation Adelaide South Australia httpdatarivermurraysagovau

Wellington Weir Site Flora and Fauna Assessment (South Australian Water Corporation Adelaide South Australia) Ecological Associates (2008) Draft Report

Ganf G G (2000) Aqua tic and ripa rian vegeta tion in A Jensen M Good P Harvey P Tuc ker amp M Long (eds) River Murray Barrages Environmental Flows An evaluation of environmental flow needs in the Lower Lakes and Coorong report to MDBC pp 30 34

Khan M T Khan T A and Wilson M E (2004) Habitat use and movement of river blackfish (Gadopsis marmoratus R) in a highly modified Victorian stream Australia Ecology of Freshwater Fish 13(4) 285-293

Lintermans M (2007) Fishes of the Murray-Darling Basin An introductory guide Murray-Darling Basin Commission Canberra ACT

Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks (Oxford University Press Melbourne)

Williams WD (1986) Conductivity and salinity of Australian Salt Lakes in Australian Journal of Marine and Freshwater Research 37177-182

Supplementary EIS for the temporary weir near Pomanda Island -53shy

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA)

General comments

1 Lots of inconsistencies particularly in figures Several of these are the result of some sections of the EIS having been updated to reflect the current environmental conditions but not others however some are just contradictions

Response Inconsistencies are corrected in the Supplementary EIS

2 In general at -15m AHD many wetland types will have already disconnected so the weir will not cause further impacts but it will slow down any potential recovery from drought impacts Please discuss and quantify these implications

Response The temporary weir will cause a 17cm drop in Lake Alexandrina water levels during the weir pool filling period under modelled worst-c ase sc enario however in the longer term there is little difference in the water levels and salinity values between weir and no weir sc enarios Quantific a tion of the amount of wa ter tha t would be

needed to refill desiccated Acid Sulfate Soils remains a knowledge gap that could be filled through field trials

3 There is a general lack of detail on what measures will be used to mitigate impacts on species (eg on pg 13-6 it says measures should be taken to ensure the wetland vegeta tion and assoc ia ted c ommunities a re not c ompromised without going into any further detail) Please review any proposed measures and provide details and commitments to undertake measurable actions

Response Detailed measures will be written in the CEMP OEMP and DEMP by SA Water The d ra ft EIS EMF and EMP outline wha t SA Water s EMP s should add ress

expec ted etc Please clearly state where you are committing to do something A table showing actual commitments would be useful

4 Vague and uncommitted language throughout the whole document

Response The South Australian Government is committed to the following actions in relation to the weir near Pomanda Island

Development of a CEMP OEMP and DEMP and submission of the EMP to relevant authorities including the SA EPA prior to any works being undertaken Incorporation of a fishway to suit large and small species A detailed submission to the MDBA for approval under the Water Act 2007 (Cwth) On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure Mitigation strategies and monitoring program as detailed in the EMP and in the amended Table 15-3 (see question 5 below) o The CEMP will be based on a risk management framework and an

environmental impact assessment (EIA) o Monitoring of water quality will be included in a water quality report to be

made available through the SA EPA

Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth

A summary of all projects follows Projects highlighted in green are completed or currently underway Orange highlighted projects are those currently being investigated and are likely but not certain to be undertaken Pink highlighted projects are those either in the early stages of planning and may be difficult to implement or are considered only a last resort solution due to other undesirable implications

Supplementary EIS for the temporary weir near Pomanda Island -54shy

Project StatusTiming Completed or Underway

Pipelines Potable Lower Lakes districts Irrigation Langhorne amp Currency Creeks

Potable construction completed January 2009 Irrigation EPBC referral (20094743) not controlled action if undertaken in particular manner due for completion October 2009

Feasibility study Long term management plan for adaptive management

30 March 2009 - Version 1 - under review prior to public consultation May 2009 Public Consultation on Version 1 30 June 2009 - Version 2 August - public consultation on Version 2 30 September 2009 - Final

Lake Albert Blocking bank in Narrung Narrows Pumping from Lake Alexandrina Lake Albert Future paper Pumping ceases 30 June 2009 Bioremediation

Blocking bank completed in May 2008 Pumping began 02 May 2008 Expert workshop held 8 April 2009 Paper prepared On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from the end of June 2009 and that a bioremediation program will be instituted

Dredging Murray Mouth Ongoing almost continuous operation since October 2002

The Living Murray (TLM) Icon Site management Icon Site condition monitoring Modelling Indigenous partnership Communications and consultation Water bids

Coorong planning document completed TLM progress report sea level impact assessment and alternatives to keep Murray Mouth open underway Condition monitoring ongoing Monitoring methodology plan completed sent to MDBA Modelling Stages 1 2A completed 2B December 2009 Interim modelling results for LLCMM due June 2009 Indigenous partnership program ongoing

Regulators Goolwa Channel Mouth of Finniss River Mouth of Currency Creek

EPBC referral submitted for public notice on 6 April 2009 Initial closure of the regulators 17 July 2009 Commencement of pumping water from Lake Alexandrina to Goolwa Channel 17 July 2009 Practical completion of the regulator within the Goolwa Channel 17 Sept 2009

Assessment of acid sulfate soils Rapid Risk Assessment Lock 1 to Wellington

Fieldwork for both completed Laboratory analysis underway completed for 24 priority wetlands below Lock 1 Survey work and modelling undertaken on inlets to 24 priority wetlands below Lock 1 Identification of priority sites creation of an action plan and application for funding underway

Lower Murray Reclaimed Irrigation Areas (LMRIA) Program

Completion of Program by June 2009 Completion of all mandatory works achieved 2008 Non-mandatory works nearing completion Post-program review to be instigated in near future

Upgrade of Pomanda Peninsula Causeway

EPBC Referra l not a c ontrolled ac tion 23 January 2009 Works currently underway in preparation should it be necessary to construct the temporary weir

Currently Being Investigated

Mitigation of acid sulfate soils using Mulch Revegetation Liming

Trials for all three currently underway Large scale application dependent on trial results and acidification time of the lower lakes

Supplementary EIS for the temporary weir near Pomanda Island -55shy

Project StatusTiming Increase inflows to Coorong South Lagoon REFLOWS Upper South East Drainage scheme (USED) water via Salt Creek Fairview Drain link

REFLOWS funding available REFLOWS cultural heritage underway REFLOWS native vegetation assessment almost complete REFLOWS landholder consultation complete REFLOWS community perceptions survey complete USED second stage feasibility study due 30 June 2009 USED 3 to 4 years to investigate and then implement Fairview initial landholder engagement commenced on hold until Reflows and Bald Hill decision made

Temporary Weir near Pomanda Island Draft EIS released for public consultation Supplementary EIS in progress Construction works to begin if Lake Alexandrina levels drop to -15 m AHD Could be avoided if sufficient freshwater flows obtained Early Planning Stages

Salinity build up in Coorong South Lagoon Dredging between north south lagoons Pump hyper-saline water to ocean

Both under preliminary investigation Pumping could only be done during autumnwinter to allow flows to replace pumped out water hence may not happen till 2010

Seawater intrusion into the lower lakes As a last resort to mitigate acid sulfate soils

EPBC referra l (EPBC 2008 4618) c ontrolled ac tion requiring EIS The final guidelines for the EIS released 13 March 2009 EIS targeted September October 2009

The projects can be divided into three categories

1 Long term plans looking to address the bigger picture with sustainable solutions Projects such as

Potable pipelines around lower lakes districts Irrigation pipelines Langhorne and Currency creeks Feasibility StudyLong Term Plan for Adaptive Management for CLLMM Lake Albert Future paper The Living Murray (TLM) programs Lower Murray Reclaimed Irrigation Areas (LMRIA) Program REFLOWS Upper South East Drainage scheme (USED) water into the Coorong via Salt Creek and Fairview Drain to Coorong link

2 Emergency measures designed to mitigate urgent issues with severe impacts Most are not long term and are designed to address a specific issue

Blocking bank in Narrung Pumping from Lake Alexandrina to Lake Albert2 Dredging Murray Mouth Goolwa Channel regulator Finniss River low level regulator Currency Creek low level regulator Pump water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel Rapid Risk Assessment of acid sulfate soils Assessment of acid sulfate soils from Lock 1 to Wellington Mitigation of acid sulfate soils

2 On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -56shy

o Bioremediation using mulch o Bioremediation using revegetation o Liming of exposed lake beds and o Liming of inflows

Salinity build up in Coorong South Lagoon o Dredging between north south lagoons and o Pump hyper-saline water to ocean

3 Last resort emergency measures only to be undertaken at critical trigger points when all other alternatives have been exhausted

Temporary weir near Pomanda Island Seawater intrusion into the Lower Lakes

Further details on each project are available if required

5 In several places throughout Chapter 15 monitoring is proposed as a mitigation measure by itself monitoring does not mitigate an impact it can only help inform when to implement a mitigation measure Please provide an actual mitigation response linked to monitoring

Response The Environmental Management Plan in Chapter 15 of the Draft EIS has been augmented in the Supplementary EIS SA Water is responsible for preparing the CEMP OEMP and DEMP Environmental Management Plan that will detail the mitigation strategies and monitoring program This will be written in conjunction with the contractor

SA Water will be responsib le to ensure tha t the c onstruc tion c ontrac tor s EMP inc ludes adequate monitoring protocols for water quality and other environmental issues throughout the construction phase The EPA DWLBC SA MDB NRMB NVC local council and other relevant agencies will be consulted on the content of any environmental risk assessment and mitigation measure In addition specific State approvals will be obtained these usually stipulate specific conditions to be included in an EMP or similar management tool

The Contractor EMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

See also 80

Table 15-3 has been amended

Table 15-3 Potential mitigation measures for water quality parameters

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Develop and implement a Soil Erosion and Drainage Management Plan in accordance with the Stormwater Pollution Prevention Code of Practice for Local State and Federal Government

Works are expected to be planned and carried out to minimise the effects of runoff and erosion on the site and downstream areas

Surface water quality

Ensure that erosion and sediment control measures are in place prior to commencing any earthworks

Supplementary EIS for the temporary weir near Pomanda Island -57shy

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Sediment control structures are expected to be established around all areas prone to erosion including stockpiles batters and drainage lines Careful placementremoval of embankment material to reduce turbidity

Scouring mud waves and bank slump are a potential consequence of installation of the temporary weir Scouring and mud waves may be reduced by controlling flows and spillway width while area of impact associated with bank slump is expected to be reduced by weir design and careful placement of embankment materials

Use of sediment curtains around weir placementremoval to limit effects of turbidity created with placement of material and subsequent mud-wave Stabilisation of River banks immediately following constructiondecommissioning Treatments may include

Revegetation

Placement of geofabric

Obtain EPA Endorsement of the proposed approach to surface water

Exception to allow placement of fill material to create weir structure

Wetland management Develop and implement a Wetland Management Plan to manage the change in flow patterns resulting from the construction operation and decommissioning of the proposed temporary weir

Develop and implement a Groundwater Management Plan for the project

Groundwater

Groundwater is expected to be monitored throughout the construction operation and decommissioning phases of the temporary weir project

Groundwater parameters which may require monitoring include

Confined and unconfined water levels

Salinity

Hydraulic gradient

Supplementary EIS for the temporary weir near Pomanda Island -58shy

Project PhaseParameter Potential mitigation measure

Monitoring is expected to take place both upstream and downstream of the temporary weir

Existing monitoring programs which may be relevant include

DLWBC OBSWELL database

RMCWMB groundwater monitoring program

CSIRO Water for a Healthy Country

Obtain endorsement of the proposed approach to groundwater monitoring from DWLBC andor the EPA

Develop and implement a water quality monitoring program based on existing programs and monitoring stations

Monitoring

If water quality parameters are exceeded the following measures may be implemented

Increase use of geofabrics and turbidity curtains to address inadequacies in turbidity management

Cease work if turbidity if triggers are exceeded until such time as the triggers return to desired levels

Aeration should monitoring indicate that oxygen is required

Mixing to prevent temperature stratification of weir pool

Mixing aeration to prevent temperature stratification of weir pool

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

6 The extent of the Ecological Character (EC) of the Ramsar site is greater than the fringing Wetlands It includes the bodies of water in the lakes the species in on and above Although the individual aspects of the EC are mostly noted in the EIS the summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Response Additional comment o be inserted in Errata Chapter Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir)

The ECD of the Coorong and Lakes Alexandrina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Those species that are not listed nationally are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetlands will persist

7 Is it likely that the water body of Lake Alexandrina will acidify during the no-flow period given the drop in water level If so how does SA propose to manage this Does this mean that the weir closure period will bring the real time management strategy water level acidification trigger forward

Response See page 22 and 23 of the Supplementary EIS

Supplementary EIS for the temporary weir near Pomanda Island -59shy

The South Australian Government is investigating and implementing a range of acid sulfate mitigation measure including application of limestone and bioremediation The possible use of seawater is also being examined (EPBC Act reference 20084618 and an EIS is currently being prepared Introduction of seawater will only be undertaken if the temporary weir is in place the acidification triggers are reached and relevant approvals in place

Water quality monitoring in Lake Alexandrina (eg at -10 m AHD) indicates alkalinity is high (between 170 and 250 mgL as CaCO3) which means the water has relatively good buffering capacity depending on the transport of acidity (fluxes) from exposed sediments During periods of no flow pulses of acid can be transported to the water by rainfall or seiching (wave action) events However given that sulfuric materials have already formed over large areas the higher risk of acidification comes with refilling of the waterbody when mineral salts can be dissolved and acidic porewater can diffuse into the water column (note some research indicates this could occur with freshwater or saltwater ingress)

Management trigger levels for alkalinity and pH have been developed and trends are being monitored fortnightly If any of the trigger levels are approached (ie at different alert levels) the Government of South Australia will instigate certain actions such as monitoring at a higher frequency or implementing limestone slurry dosing programs

The biogeochemical modelling points to waterbody acidification at either a pH less than 6 or water levels below -15 m AHD Further refining of the modelling and investigations of sulfide oxidation rates and acidity transport are being undertaken and early indications are that waterbody acidification is more complex than relating it just to water level As such the weir closure period may not necessarily bring forward Lake Alexandrina acidification

8 The EIS states there will be a number of plans that do not appear to be available yet it is difficult to assess the effectiveness of mitigation without seeing these plans When will these be provided

Response Development of plans and actions is ongoing Response to 4 above lists many of these including the Long Term Plan Many plans have been provided to DEWHA as they are prepared

9 The EIS indicates that disconnection is likely to occur for 2-35 months even though under worst case scenarios it could be up to 7 or 8 months (Table 10-6) The EIS assessment is based on no flow period of 3 months Is the reason for this because SA is currently receiving 896GL over the border and they anticipate getting at least this amount in the 2009-2010 water year and subsequent years Or is there other justification for the reasons for using 25-3 month disconnection This difference in time period could change the likely impacts on hydrology and water levels which are key determinants of ec olog ic a l c harac ter DEWHA s assessment will take into ac c ount the worst case scenario

Response South Australia is now guaranteed a flow of at least 896GL during 2009-10 as the 200GL required for Critical Human Needs has already been secured and is held in reserve Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream The estimated time for disconnection for the 696 GL scenario is not relevant

The Errata chapter includes replacement of references to 940 GL with 896 GL on pages 2-13 and 2-19 of the Draft EIS

The time required to fill the weir pool from approximately -15m AHD to +01m AHD will be approximately 25 3 months If it is necessary to fill the weir pool more slowly (eg to minimise damage to upstream wetlands banks and levees) the flow at Lock 1 will not be reduced and any additional water will be delivered into Lake Alexandrina through a by-pass structure

10 As specified in 1(g) of the EIS Guidelines can you please detail the interaction between this action and others in the CLLAMM

Response Discussed at 4 above

Supplementary EIS for the temporary weir near Pomanda Island -60shy

11 In Part 3 of the EIS Guidelines you are required to take into account the long-term options for the CLLAMM While the Department acknowledges the actions that are being undertaken to develop a long term solution how will this action limit long term options

Response As discussed in the Supplementary EIS South Australia considers that the weir if constructed will not limit long term options Long term options are being actively planned in the knowledge that the temporary weir may be constructed

12 Section 11 of the EIS Guidelines require the objectives of the EPBC Act to be addressed Can you please provide further information addressing these objectives

Response The Draft EIS endeavoured to address the Guidelines for the Proposed Temporary Weir This Supplementary EIS supplements this by the addition of the community consultation report and a detailed review of issues raised

The response to question 4 details all related actions that the government is taking in the Coorong and Lakes Alexandrina and Albert Ramsar site including the development of a comprehensive long term environmental plan that shortly will be released for community consideration

Objects of the EPBC Act

(a) In the face of unprecedented environmental degradation of the Ramsar site and matters of national environmental significance caused by low freshwater inflows we are undertaking substantial conservation and remediation work involving many South Australian Government agencies These are outlined in the Supplementary EIS

(b) (c) (d) Further specific actions to conserve natural resources and bio-diversity are likely to be announced shortly in conjunction with the Australian Minister for Climate Change and Water It is expected that majority of these actions will be undertaken by local government the community land holders and the Ngarrindjeri People

(e) As the South Australian agency responsible for the Environment and Heritage and one of the custodians of the internationally listed Ramsar site the Proponent seeks to c oopera tively imp lement Austra lia s interna tiona l environmenta l responsibilities

(f) (g) The South Australian Government acknowledges the Ngarrindjeri People as traditional owners within the area of their current Native Title Claim within the context of the Aboriginal Heritage Act 1988 The Ngarrindjeri People collectively and individually have been consulted and given an opportunity to comment on the Draft EIS along with all other stakeholders and members of the c ommunity The State Government is endeavouring to develop a formal overarching agreement with the Ngarrindjeri in relation to consultation and negotiation on a range of environmental and cultural matters of joint interest

Work with Aboriginal people to manage biodiversity cooperatively and contribute to the reconciliation of past actions

Comments on ESD are included at question 25

More specific comments

13 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

Response Noted Corrected in Errata

14 On pg 4-4 it says that 3 of the 4 pumping stations are complete with only Murray Bridge to be completed but in Table 4-4 on the same page and on pg 2-3 it says Swan Reach is the only pumping station still to be completed

Response Mannum and Tailem Bend are complete Swan Reach was completed late December 2008 Murray Bridge has 2 pumps modified for lower water level operation but we are delaying some work on one pump at Murray Bridge in order to test it (unshymodified) in order to be better able to confirm the lower limit of operation

DEH s Corp ora te Plan inc lud es the objective

Supplementary EIS for the temporary weir near Pomanda Island -61shy

15 Orange-bellied Parrot sec tion 752 doesn t mention samphire hab ita t

Response Firstly in the history of documentation relating to this EIS on the preferred habitat of the Orange-bellied Parrot There appears to have been some confusion over the use of the words saltmarsh and samphire

Samphire is used interchangeably in South Australia to describe

a) species in the genera Sarcocornia and Tecticornia (formerly Halosarcia and Sclerostegia) and

b) habitat dominated by such species

Thus saltmarsh and samphire are interchangeable terms to describe the same habitat

Food plants associated with samphire (or saltmarsh) habitat are certainly known to be used as feeding habitat by the Orange-bellied Parrot in the lower lakesupper Coorong with recent records from this habitat from the Snake Pit (Tauwitchere Point) and Sir Richard Peninsula (Beacon 19) in recent years (06-08) predominantly from Sarcocornia

However it appears that within South Australia the Orange-bellied Parrot is less dependent than previously suspected on samphire vegetation Recent observations in South Australia (2003-) suggest that the species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

While most records are within 10km of the coast Orange-bellied Parrots were recorded in winter in the Tolderol area (north-western shore of Lake Alexandrina) between 1981 and 1985 (John Eckert sightings lodged with Birds Australia) and there is an anecdotal record of this species foraging in the Wellington area at Nalpa Station

In the referral for the Pomanda Island causeway (EPBC 4676) it is stated that the Causeway upgrade could at worst disturb less than 014 ha of samphire shrubland With 1289 ha of this habitat within the Ramsar boundaries the maximum loss of samphire species would be 001 In addition Ecological Associates (2008) identify that samphire species regenerate relatively quickly after disturbance

16 The Great Egret Cattle Egret and the Caspian Tern are not dealt with satisfactorily (pp 7-3334)

Response The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in SE Qld and NE NSW (HANZAB3)

The movements of Caspian Tern are poorly understood partly resident partly dispersive and possibly partly migratory (HANZAB1) The species is commonly observed on fresh and marine waters foraging on the wing for fish

17 The potential decommissioning impacts (pg 8-7) says tha t The impac ts a re expec ted to be further assessed during the planning for the decommissioning p rojec t as the

3 Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks Oxford University Press Melbourne

Supplementary EIS for the temporary weir near Pomanda Island -62shy

decommissioning is part of the referred action details will need to be provided to determine what the potential impacts are

Response The nominal design life for the temporary weir is 3 years and therefore not all impacts of the decommissioning are able to be assessed at this point in time For example it is difficult to be able to identify projects where the removed rock can be usefully employed

There a re no Ramsar-listed wetlands between Lock 1 and the p roposed temporary weir site however the Coorong and Lakes Alexandrina and Albert Ramsar site extends someway upstream of the weir site

18 On pg 12-2 the EIS sta tes

Response The Coorong and Lakes Alexandrina and Albert Ramsar site extends approx ten kilometres upstream of the proposed weir site (at the apex) to a point that represents the confluence between Lake Alexandrina and River Murray proper The relevant sentence on Pg 12-2 has been reworded to say There a re no Ramsar-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ramsar site

19 On pg 12-15 the EIS says tha t the weir will ac c elera te d rops in wa ter level during the period of d isc onnec tion however all the downstream wetlands will supposedly have already disconnected due to drought conditions with the exception of wetland type O whic h is not expec ted to d isc onnec t It is not c lear what period of d isc onnec tion is being referred to

Response The period of disconnection being referred to is the time during which there will be reduced flow over the temporary weir from the River Murray channel into Lake Alexandrina nominally 25 3 months (as discussed under question 9 and page 13)

Reword Section 125 (pg 12-15) in its entirety to read

As deta iled in Sec tion 1241 a ll wetland habitats downstream of the temporary weir location are expected to be affected by the drought and by 2012 only Ramsarshywetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state

Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flow see page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

20 Throughout Chapter 12 the EIS refers to impacts on EPBC-listed flora and fauna species only but it should be considering all flora and fauna within the Ramsar site

Matters of Na tiona l Environmenta l Signific anc e as a matter of p riority however implic it in the EIS and in our Ramsar obligations are the impacts upon all flora and fauna within the Ramsar site Tortoises and Japanese Snipe are good examples of non-threatened species that have been or are likely to be affected by altered hydrology or water quality There is an infinite list of taxa that could be considered in detail some of which we know little about but much of this work falls outside the scope of the EIS

Response The EIS foc uses on threa tened spec ies and

The EIS refers to Matters of NES (eg EPBC- listed flora and fauna) that will still be occupying Type O wetlands which will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir Impacts on other Ramsar Wetland Types (ie the rest of the Ramsar site) were not considered because the impacts of the drought were considered to be the primary determinants of change in ecological character for those wetlands Further discussed in Supplementary EIS

Pred ic ted c hanges to p rimary determinants of ec olog ic a l c harac ter ) only lists the p red ic ted c hanges for 2 out of the 6 p rimary determinants

21 Table 12-4 (titled

Response Update Table 12-4 to include the following

Supplementary EIS for the temporary weir near Pomanda Island -63shy

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts (2010 2012)

Salinity Discussed extensively in Section 10 Water Level Discussed extensively in Section 10 Water Regime Discussed extensively in Section 10 Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

22 Sec tion 127 (Summary of Chapter 12) doesn t summarise the impac ts as a result of the weir only the impacts from the drought

Response Discussed in Supplementary EIS

23 There doesn t appear to be any c onsidera tion of the interac tion between the timing of construction and when migratory species will be present (eg no consideration on pp 13-78 of whether the timing of construction (potentially October-January) will impact on when the Orange-bellied Parrot will be there (potentially March-early November))

Response As indicated in chapter 13 of the draft EIS there is a low risk that construction will impact on OBPs Construction works are localised and OBP habitat is not affected The only impacts to migratory birds including OBP may occur during the actual construction phase (displacement and habitat loss) and are expected to be short lived

Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to minimise the impact on Orange-bellied Parrots may result in construction occurring when other migratory species are present Migratory shorebirds for example generally return in late August and spend the entire summer at the Lower Lakes

24 In Table 15-9 on pp 15-2526 it says that a fauna inspection will be carried out in the construction area before any vegetation clearance and that any fauna located within the construction area shall be either relocated or dealt with in accordance with recommendations made by the qualified persons more information is needed eg a decision tree flowchart

Response A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water and DEH This knowledge has been considered by the Commonwealth It is acknowledged that more specific instructions on how this can be ac hieved will be inc luded in the Contrac tor s EMP The p rojec t will ensure tha t expert advice is available throughout the duration of the construction phase

25 Please re-consider 163 ESD whole approach The purpose of the weir is to protect water supplies not to prevent degradation

Response They have become one and the same over the life of the project To secure water quality is to secure supply The emergence of acid sulfate soil threats has presented us with a major risk for the water to become un-potable

The transitory effects of the temporary weir are far less than the long term effects of low freshwater flows

Principles of Ecologically Sustainable Development Guidelines Attachment 1 Part 3A

(a) The social and economic consequences of a city of 12 million not having a secure water supply are incalculable

(b) The threats of serious or irreversible environmental damage are discussed extensively in the EIS Whilst there is no full scientific certainty we are continuing to undertake extensive measurements modelling trials and emergency actions to minimise environmental degradation caused both by low freshwater inflows and the short term impact of the temporary weir

with the purpose of the weir in mind Not South Austra lia s

Supplementary EIS for the temporary weir near Pomanda Island -64shy

(c) Both the construction of the temporary weir if required and the actions being taken throughout the Ramsar site will benefit the present and future generations

(d) Whilst the purpose of the temporary weir is to protect water supplies we will take all reasonable steps to minimise any impact of the temporary weir on biological diversity and ecological integrity For example we are now proposing to include a fishway

(e) South Australia is a buyer in the water markets as required and supports the COAG initiatives to improve water markets and trade water information and research and an enhanced urban water reform framework We see no specific application of the ESD principles of improved valuation pricing and incentive mechanisms in the case of the temporary weir

26 If pumping to Lake Albert was not continued beyond June 2009 how would this affect the projections for impacts on the site (water levels the no flow period ASS exposure salinity levels)

Response On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009

The potential for acidification in Lake Alexandrina is based on worst-case scenario rainfall and inflows during 2009 South Australia receives most of its rainfall in winter and spring so the extent of inflows and how trigger points may be favorably impacted by improvements will not be known until later in 2009 Over winter and into 201011 there will be some recovery in the water level (as has occurred each winter over the last three years of minimum flows) above the critical acidification level due to reduced losses and local rainfall Once losses increase during the warmer months the water level would again fall without any additional inflows

As described in the draft EIS under worst case conditions and with continued pumping to Lake Albert it was projected that the water level in Lake Alexandrina will reach the critical acidification water level of -15 m AHD at the beginning of January 2010

However with 220 GL delivered to Lake Alexandrina during 200910 the water level could be maintained above trigger level for the remainder of the 200910 water year 170 GL of the 220 GL requirement is now being secured by no longer pumping to Lake Albert The remaining requirement of 50 GL has already been secured by South Australia through the purchase of temporary water during the 200809 water year

The South Australian Government has assessed the potential savings that could be made by the decision to cease pumping to Lake Albert and how these savings combined with other water sources may delay the need to construct the temporary weir The 170 GL which now will be retained in Lake Alexandrina each year must still flow past Wellington to ensure that the salinity at the major pumping station at Murray Bridge remains below 1400 EC and therefore cannot be retained up-stream of Murray Bridge and used for other purposes

In conjunction with the additional 50 GL already purchased by South Australia (making a total of 220 GL for the full year) this will delay reaching the critical acidification level in Lake Alexandrina until mid to late 2010 maintain lake salinities at lower levels during this period than would occur if water levels continued to fall and maintain lower ASS exposure during this period

Updated model projections for both water level and salinity in Lake Alexandrina are presented below

Supplementary EIS for the temporary weir near Pomanda Island -65shy

_

Lake Alexandrina Level Forecasting from 16 May 2009

-24

-23

-22

-21

-2

-19

-18

-17

-16

-15

-14

-13

-12

-11

-1

-09

-08

-07

-06

-05

-04

-03

-02

-01

0

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Wat

er L

evel

(m A

HD

)

Projected Level w ith Maximum Net Evaporation (1982) Conditions

Level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Level

Critical Acidif ication Level (-15m AHD)

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Losses Maxmimum Net Evaporation (1982) Conditions

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 and no irrigation in 200910)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD unless stated

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank filled to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -66-

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Lake Alexandrina Salinity

Forecasting from 16 May 2009

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Sal

inity

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C)

Projected Salinity w ith Maximum Net Evaporation (1982) Conditions

Salinity w ith level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Salinity

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Salinity Salinity of Flow to SA varies from 200 to 350 EC (f low rate dependent)

Losses as stated

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 no irrigation 200910 onw ards)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank f illed to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -67-

Water supply

the weir is expec ted to have negligible effects on sa linity between Loc k 1 and Wellington

27 On pg 10-22 the EIS sta tes tha t then why is the weir needed to protect water

quality

Response The temporary weir will have minimal impact on water quality upstream of the temporary weir in terms of the inputs (particularly salinity) from upstream The primary purpose of the temporary weir is to prevent contaminated water from Lake Alexandrina being pushed into the River Murray channel upstream of Wellington through wind seiching Monitoring and modelling have demonstrated that even at the relatively low salinities in the lake currently incidents where water with a salinity in excess of the maximum target level of 1400 EC penetrates upstream to Tailem Bend may occur

28 Figure 1-3 (pg 1-4) shows a water level of -15m AHD (ie the critical acidification date) being reached in January 2009 What is the interaction between this and the proposed Clayton blocking bank which would bring the critical acidification date forward by at least 2 weeks into December 09

Response Pumping water to the Goolwa Channel will bring forward the time when the trigger water level of -15m AHD is reached by about 2 weeks however the critical acidification date will be delayed with the 220 GL delivered to Lake Alexandrina during 200910 (see response to question 26)

Should more than 896 GL year be ava ilab le [flowing ac ross the SA border] the potential effects of the proposed temporary weir are likely to be reduced in the Lower Lakes Does this mean that any water in excess of 896 GL will be allowed to flow into the lower lakes

29 On pg 10-7 it says tha t

Response Water allocated to South Australia in excess of 896 GL plus private and state carry-over will be allocated on a priority basis within the state Some of this may be allowed to flow to the Lower Lakes The application of any water in excess of 896 GL per year has not been determined and it is also dependent on the reason why there is exc ess wa ter For example unregula ted flows whic h a re flows tha t the MDBA is not able to capture a re likely to flow to the lakes while regula ted flows a re ava ilab le for allocation to support irrigation

30 The 201 GL critical human needs volume is based on level 5 water restrictions (pg 4-6) what is the plan for moving SA onto level 5 water restrictions considering only 896 GL is expected in 2009-10 (pg 1-3)

Response The total volume available to South Australia in 2008-09 is currently predicted to be at least 1140 GL Areas in South Australia reliant on River Murray water are currently on enhanced level 3 water restrictions The extra saving in moving to level 5 is 17 GL which is negligible in terms of the Lower Lakes

The Metropolitan Adelaide water supply is derived from two sources Inflows in the Mount Lofty Ranges during winter 2009 will impact on any decisions on water restrictions There is currently no plan to increase the restriction level from the current enhanced level 3 restrictions as the difference may be provided by additional MLR inflows

what is the increase in SA water use based on Population growth

31 Fig 2-2 on pg 2-5 shows 40 GL more being demanded than supplied by 2025

Response The 40 GL is the net effect of increasing demand further water conservation initiatives as described in the Water Proofing Adelaide strategy and reduction in available sources of water due to the impact of climate change

The weir is expec ted to a ffec t the amount of wa ter held between Lock 1 and Wellington and provide confidence that an extra [emphasis added ] 685 GL is ava ilab le for South Austra lians The 685 GL represents the amount of water needed to fill the weir pool from -15m AHD to +01m AHD but is not extra water that is available for extraction

32 On pg 10-32 the EIS says tha t

this needs to be clarified

Response Agreed The extra volume could only be available as a last resort and drawing down this weir pool would jeopardise water quality (salinity) as there would be no through flow to the Lower Lakes

Supplementary EIS for the temporary weir near Pomanda Island -68shy

33 On pg 2-2 the EIS states that roof run-off stormwater and recycled water are used for non-potable purposes how much Has this reduced reliance on Murray water Also mentions desalination plant will this reduce reliance on Murray water

Response Use of roof-runoff and stormwater particularly in the northern suburbs of Adelaide has provided additional water to reduce the demand on the traditional sources River Murray and the Mount Lofty Ranges Predominantly these have provided non-potable water for new development and as such are preventing increased demand from the traditional sources

It is clear that in critical periods of drought the 100 GL Adelaide desalination plant currently under construction will reduce reliance on the River Murray

While the desalination plant will reduce reliance on the River Murray this does not necessarily have a direct impact on the flow to South Australia required to maintain salinity at a satisfactory level (target lt1400EC at Murray Bridge) None of these nonshytraditional sources will remove reliance on the River Murray and it should be noted that a minimum flow to South Australia of about 900 GL per year is required to maintain salinity at Murray Bridge at less than 1400EC which is required for all potable use whatever the level of demand for Adelaide and regional South Australia

what is their estimated reduced reliance on Murray water Pg 4-17

34 Strategies 1 and 2 on pg 4-13 same question

Response Water conservation and recycling reduce the average water extracted from the River Murray and the recently released Water for Good plan quantifies this However in periods of extreme drought the same water savings are traditionally achieved through water restrictions and consequently these initiatives do not greatly reduce the need for River Murray water during critical periods

35 What is the safe operating height of SA Water pumping off-takes (pg 4-2)

Response Following modification to the pumps the safe operating level is currently -22m AHD Prior to the modifications the safe operating limit was around -04m AHD The estimates of the critical limits for the pumping stations have varied over time as the river level has dropped and the pumps could be tested outside of their normal operating ranges

36 If the pumps can pump down to -22m AHD then why is the weir pool at +01m AHD Does this factor in evaporation of the weir pool during times of low flow which would lower the water level Or is this considering the water quality of the lower lakes How can this be the case when the weir expected to have negligible effects on salinity between Lock 1 and Wellington

Response This level is set taking into account the requirements of the temporary weir during the recovery phase If Lake Alexandrina becomes saline the temporary weir needs to maintain a physical separation between the river and the lake as the lake level increases to allow the saline lake water to be flushed to sea

The level of 01m is a compromise While a higher level (up to 075m AHD or higher) would be preferred to facilitate flushing of lake water to the sea the foundation conditions for the temporary weir are not suitable for such a high weir if the lake levels continue to drop

c areful p lac ement remova l of embankment material

37 In Table 15-3 on pg 15-17 it says there will be what does this mean

Response Careful placement removal of the weir embankment material during constructionremoval will minimise both the area and quantity of disturbed bed material and hence minimise the immediate water quality impacts (mainly turbidity) and the inadvertent release of sulphuric acid from the sediments

38 SA has previously indicated it would legislate to ensure removal of the weir has this been done When will it be done

Response No The temporary weir will be removed when the decommissioning criteria (as agreed by the Water Security Council and accepted by the MDBA) are met

39 How will additional water secured through SA water security strategy and efficiency measures be managed ie will any be provided to Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -69-

Response See response to Q29

40 Are there any the implications of predicted future water demand in SA on the period of time that the weir is in place

Response This is not expected to be material during the expected life of the temporary weir

Predicted future demand for potable water for the major off-takes will have minimal impact on the time the temporary weir is needed The temporary weir is required to prevent saline or acid contaminated water from the Lower Lakes entering the river channel until such time as the quality in Lake Alexandrina no longer provides a threat to these water supplies whatever the demand

41 Will salinity increase behind the weir in the weir pool Given that saline water sinks the water overtopping the weir may potentially be fresher water Will salinity levels in the weir pool build up to a point where it might impact on the offtakes

Response Large quantities of salt flow down the River Murray every day but it is largely mixed and therefore will not separate and sink Therefore salinity levels in the pool between Lock 1 and the temporary weir are not expected to impact on the offtakes (Note that there are saline groundwater inflows to the river which can cause localised pockets of salinity but this occurs in normal river operation and is independent of the construction of a temporary weir These pockets of high salinity eventually mix and the salt is carried away in the general water body)

In the absence of a temporary weir when more saline water from the lakes is forced under wind seiche into the river it does sink to the bottom rather than mix with the less saline river water and the saline water then moves upstream This is exacerbated by the differing depths of the water at Pomanda Island and in the river channel upstream of Wellington

Modelling indicates an initial rise in upstream salinity during the weir filling period and then after that no major change in the long-term Provided there is no significant input of highly saline water from Lake Alexandrina (the purpose of the temporary weir is to stop this) the salinity gradients generated by evapoconcentration of the relatively low salinity river water will not be sufficient to resist the natural mixing as temperatures and wind conditions change This has been demonstrated by the natural break-up of the saline intrusions on the bottom of the river due to inflows from Lake Alexandrina which have been identified through monitoring over the past year

42 Can SA provide the modelling on the 696GL scenarios with and without the weir on water levels the no flow period ASS exposure

Response Refer to the response to Q9

The flow scenario proposed is unrealistic as South Australia is guaranteed a minimum flow of over 896 GL in 2009-10 (including the reserve for Critical Human Needs and private carry-over) Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream

The requested modelling results will be provided but should not be taken as representative of any realistic scenario

Removal triggers (pg 1-6)

norma l opera ting levels in rela tion to Hume and Dartmouth and what period of time these levels have to be sustained for

43 No definition of

Response The MDBA states that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

44 How long to fill Hume and Dartmouth Dams and how likely is this What is the worst case scenario Best case Is the filling and operation of these dams likely to be impacted by MDBstate water management

Response It is not possible to predict how long filling these storages to this level may take Hume storage in partic ula r is quite vola tile and c ould easily fill and spill within less than one year Dartmouth storage is more likely to take longer but the average end of season

Supplementary EIS for the temporary weir near Pomanda Island -70-

level is commensurately lower Under continuing worst case conditions the storages will not reach these trigger levels

The filling of these storages could be affected by decisions by all jurisdictions regarding the management of the Murray-Darling Basin including future sharing and reserve arrangements

45 Why was this trigger chosen rather than one focussed around water made available to South Australia from shared River Murray water or based on discontinuationreduction of dry-inflow contingency

Response These triggers were determined because they are open and transparent They are based on the best available technical advice

The triggers were agreed by the Water Security Council and accepted by the MDBA

need to meet a ll triggers Can SA provide any indication about the likely timeframe in which all triggers would be met

46 The timeframes on the removal triggers are unclear

Response Removal triggers are directly related to the drought and how much water is expected to become available It is not known when these triggers will be met

The MDBA notes that the specific timing of removal is highly dependant on the seasonal conditions at the time Lake Alexandrina next fills above +01 m AHD

no water quality impacts from Lakes water quality in the lakes is unlikely to improve with the weir in place so how realistic is this as a removal trigger If it is decided that seawater needs to be introduced to manage ASS this is likely to delay removal of the weir given the inability to meet this trigger

47 Regarding the 3rd removal trigger

Response Water quality in the lakes is unlikely to improve until additional fresh water flows down the river and either dilutes the lake water or flushes it to the sea If inflows to the lakes over the temporary weir exceed evaporation the water quality will begin to improve through dilution Major improvement in quality will not occur until there is a discharge of water from the barrages which cannot occur until the water level is restored to at least +05m AHD The critical salinity level in the lakes has been calculated at 3000 EC If inflows are predicted to reduce the lake salinity to less than this value the potential impact of lake water on major water supply offtakes is considered acceptable If seawater has been introduced to prevent acidification the volume required to dilute discharge salt to the extent that this target of lt3000EC can be met will be greater than if no seawater has been introduced However the volume of inflows required to improve lake water quality to an acceptable level if the lake has been allowed to acidify is likely to be even greater

This trigger has been purposely expressed as water quality rather than salinity because no decision has been made on whether seawater is to be used to manage acid sulphate soils (EPBC Reference 20084618) or whether an alternative strategy is to be adopted

If seawater is not introduced acidification may introduce a number of other water quality issues that need to be resolved before the temporary weir can be removed

48 In relation to the salinity trigger how much water is required to flow in to reduce salinity levels to below triggers stated What is the likely timeframe on getting this volume

Response The volume of water required to dilute salinity in Lake Alexandrina to meet the removal trigger will depend on the quality of water remaining in the lake and when the dilution occurs At the time of closure of the temporary weir it is predicted that the salinity in Lake Alexandrina will be approaching 10000EC Salinity will increase to about 28000EC within 12 months due to river inflows and evapo-concentration and will be significantly higher if seawater is introduced

Figure 211 in the Draft EIS shows how salinity in Lake Alexandrina continues to rise with continued low inflows The volume of fresh water eventually needed to reduce the lake water below the trigger level depends on how long the drought continues Typically the salinity of water in Lake Alexandrina will be diluted by 30 just by re-filling the lakes to 01m AHD

49 If the Australian Drinking Water Guidelines (2004) say that 275 to 550 EC is the acceptable salinity of drinking water (pg 10-4) then why is the removal trigger set at 3000 EC

Supplementary EIS for the temporary weir near Pomanda Island -71-

Response The desirab le sa linity ta rget for d rinking wa ter supp lies in South Austra lia has been identified as 800 EC based on AWRC and WHO guidelines Many supplies do not always meet this desirable limit The removal trigger for salinity in the lakes has been set at 3000 EC higher than the maximum limit set for Tailem Bend (1400 EC) and much higher than the desirable limit for drinking water of 800 EC because based on experience and from the modelling results the risk of water from Lake Alexandrina raising the salinity at the major water supply off-takes above the maximum target level of 1400 EC is acceptable

50 No definition of what the water quality risks are and how these would be measured

Response Refer to response to Q47

The primary water quality risk is salinity and this is dealt with comprehensively throughout the document Additional water quality risks arise from water moving upstream for Lake Alexandrina if the lake has acidified (heavy metals metalloids nutrients) These risks are closely monitored through existing water quality sampling programs associated with a major public water supply Algal blooms (potentially toxic cyanobacterial in particular) present an additional water quality risk that is addressed in the Supplementary EIS The presence of algae is monitored closely through a program established when lake and river water levels started to decline This program which is in addition to the normal sampling for public water supply purposes includes regular airborne videography and infrared photography with immediate ground truthing of any sites identified through the aerial survey work

It is not possible to quantify all of the water quality risks unless the management strategy for ASS is known in particular whether a preventive approach using seawater is to be used or a remediation approach The full impacts of these options are currently being investigated for the EIS to allow seawater into the Lakes

51 Fourth removal trigger is subjective what does this mean in practice Confidence is immeasurable this alleged removal trigger is more on outcome of the other removal triggers being met than a trigger in itself

Response The confidence required is in the consistency and robustness of River Murray water resource projections in relation to being certain we will not return to a similar situation of extreme low water levels as we are currently experiencing in the near future which may require re-instatement of the temporary weir

To some extent the comment that this trigger is an outcome of the first 3 triggers is correct However this trigger is intended to allow for the considerable uncertainty around the management regime for ASS and changes to operating rules in the MDB

52 58 states that once the water level exceeds +01m AHD the weir will cease to serve any useful function How will the structure of the weir albeit below water level change flow rates past the submerged weir

Response The temporary weir will have very limited impact on flows once water levels return to greater than +01m AHD in the lakes When the water level exceeds 01m AHD the temporary weir becomes drowned but it still provides a (partial) barrier to saline river water moving upstream

The submerged weir will still allow the prevailing flow to pass Should flow rates exceed the design of the temporary weir action would be taken to widen the flow path

Additional modelling will be undertaken to identify any backwater impacts from high flows in a situation where the temporary weir has not been removed (eg 50 000 MLday) The presence of the temporary weir would still provide some benefit in restricting any saline flows from Lake Alexandrina in to the River Murray channel even if the temporary weir was d rowned

Wetlands

53 In section 1246 on pg 12-11 under the head ing Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion is c onsidered insignific ant as many of these species reproduce sexually and wind or bird-d riven seed d ispersa l This is only a consideration of impacts upon reproduction not a consideration of whether the plants will even survive to reproduce

Supplementary EIS for the temporary weir near Pomanda Island -72-

Response Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately 035 m AHD At a water level of -15 m AHD this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the waterbody and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the lake be refilled with fresh water to its pre-drought level (05 to 08 m AHD) while the below-ground storage organs remain viable

54 In Table 12-3 on pg 12-6 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type O it says that the slightly quicker decrease in water levels as a result of the weir is expected to bring forward the exposure of some sediment (including acid sulphate soils) that would otherwise have been exposed within 9 months how much acid sulphate soils Is this the 5200 ha mentioned on pg 11-7

Response Yes it is 5200 ha and this is reiterated in the Supplementary EIS As discussed in the Supplementary EIS the reduction of flow during the filling of the weir pool reduces the volume of water such that a further 5200 ha of sulfidic soils is exposed in Lake Alexandrina This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage acid sulfate soils will need to be implemented across the Lake in this case

55 In Table 12-3 on pg 12-8 for wetland type XI how can there be no recorded change at shy05m AHD but complete disconnection at -15m AHD

Response Presumably the comment refers to wetland type Xf not wetland type XI In Table 12-3 for wetland type Xf under Existing c ond ition (app roximately -05 m AHD) rep lac e No rec orded c hange with Not c onnec ted to the ma in body of the lake Will only be a ffec ted by ongoing d rought

Covered in Supplementary EIS

56 In Table 12-3 on pg 12-8 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type 4 the EIS says the weir is not expec ted to further impac t the management of seasonally flooded agricultural land when are they seasonally flooded Are the 25-3 months following weir closure going to prevent this seasonal inundation

Response In Table 12-3 for wetland type 4 under Impac t of p roposed temporary weir within Ramsar wetlands to existing text add whic h oc c urs a t wa ter levels gt 087 m AHD At the trigger level for weir construction (-15 m AHD) water levels will be 237 m below those that lead to inundation of surrounding agricultural land With or without the temporary weir in place water levels will remain well below 087 m AHD for the 25 3 month period following weir construction if it proceeds

Covered in Supplementary EIS

57 In Table 15-1 on pg 15-2 in the row on acid sulphate soils the EIS says that contingency measures may be c onsidered if a lka linity dec lined to a spec ified level what is this level How and where will this be measured What contingency measures would be implemented

Response Table 15-1 refers to Table 15-6 Potential mitigation measures to manage acid sulfate soils which contains the levels (100 and 25 mgL as CaCO3) In Table 15-6 for dot point 2 it c ould be c hanged to If a lka linity c onc entra tions dec line to 25 mgL as CaCO3 then immediate mitigation measures such as limestone slurry dosing are expec ted to be undertaken

Since August 2008 the SA MDB NRM Board has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (eg sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC

Supplementary EIS for the temporary weir near Pomanda Island -73-

It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (report 1 March 2009) The EPA also compiles the raw data in a spreadsheet available to South Australian government agencies

58 How will the Wetland Management Plan (Table 15-3 pg 15-17) manage the change in flow patterns Does have any suggestions on how to mitigate the impacts of the no-flow periodfirst year reduced flows period

Response Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

59 In Table 15-3 on pg 15-18 it mentions several potential water quality protection measures including use of a turbidity curtain stabilisation of river banks etc Under what conditions would each of these measures be implemented Same for contingency measures for acid sulphate soils outlined in Table 15-6 on pg 15-20

Response The EPA has pointed out that the EMP scope should include monitoring and managing turbidity impacts during construction and any EMP should be approved by relevant authorities including the EPA prior to any works being carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) which contains the overarching EMP SA Water and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Table 15-3 has been amended

60 Will there be any interactions with other referrals Will the presence of the weir impact on the Goolwa Channel referral

Response The temporary weir is part of a planned progressive response by the South Australian Government to worsening conditions in the Lower Murray in South Australia This Cabinet approved response plan is based on water levels in the barrages weir pool The critical trigger for the temporary weir is -15m AHD The trigger for the project to pump water to Lake Albert was -05m AHD and the trigger for the proposed Goolwa Channel Water Level Management Project is -12m AHD These actions are all linked as part of the overall response strategy The presence of the proposed temporary weir will not impact on the Goolwa Channel project as the latter project will be constructed well prior to the proposed temporary weir near Pomanda Island

61 It is likely that the presence of the weir may adversely impact on the recovery and management of the ecological character of the and therefore in the implementation of the long term plan for the site Does SA have any suggestions about how this will be managedmitigated

Response The temporary weir will not adversely impact on the recovery and management of the ecological character and will assist in preserving the range of options that can be considered under the long-term management strategy If the temporary weir is not constructed and the area acidifies or a greater volume of seawater is required to prevent this the detrimental impacts on the long-term plan will be greater

62 Page 10-25 will SA be purchasing water to ensure that the hydrological disconnection associated with the filling of the weir pool is reduced from 3 to 1month Please provide details under what circumstances would this occur

Response The South Australian Government is committed to pursuing a fresh water solution for the Lower Lakes including the purchase of water from the market However

Supplementary EIS for the temporary weir near Pomanda Island -74-

no commitment of additional water to the Lower Lakes can be made until the winter 2009 inflows are known

Re-wetting of upstream wetlands

63 Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

THIS SECTION DOES NOT EXIST and they do not appear to be described elsewhere (pg 10-10 also mentions likely changes to groundwater interactions and the re-wetting of dried sulfidic sediments and the associated ecological effects that would result and refers to Ch 15 for management tha t s in p lac e) mitiga tion measures mentioned aga in on pg 11-9 but no details

Response The reference to section 1554 should read 15412 and has been corrected in the Errata to the Supplementary EIS Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant Further details are provided in the response to question 64 in regards to ASS mitigation and management of wetlands above Pomanda Island All appropriate approvals for structures will be sought through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project

64 As the weir pool fills and upstream wetlands are re-wetted there exists a real potential for the introduction of low pH water with high metal concentrations into the River Murray (pg 11-8)

Response Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on potential impact refilling wetlands will have on water quality of the Main River Channel and ecological impact of further acidification of wetlands

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the MDBC Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from DEH project identifying acidification remediation options for the Lower Lakes Construction of structures and other on-ground works for remediation at priority wetlands and Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRM Board is managing the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project with a steering committee comprising of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRM Board DEH DWLBC MDBA SA Water EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of 01m AHD CSIRO have undertaken a preliminary assessment of the ASS hazard for each of the 75 wetlands An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of each wetland will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and

Supplementary EIS for the temporary weir near Pomanda Island -75-

ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island eg wetlands providing important aquatic refuges

65 Which wetlands will be re-wetted What are their sizes water levels condition etc

Response Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at +01m AHD The Table below provides information of the c ommenc e to fill level surfac e a reas and ASS management assessment for eac h of the 25 wetlands

NAME

SA (ha) at pool (~075m AHD)

SA (ha) at 02m AHD

commence to fill m AHD

Require ASS management

Riverglades 446 196 -051 Yes

Wellington Marina lt 191 lt 191 lt -080 Needs reassessment

Saltbush Flat 855 88 -025 No

Teal Flat Hut 202 15 -019 Yes

Walker Flat South Lagoon 888 601 -010 Yes

Wellington North (Murrundi) 9 32 -010 Yes Lake Carlet 3457 2998 -065 Yes

Devon Downs North 2627 822 -040 Yes Lake Bywaters 388 321 -017 No Marks Landing 1929 1453 -060 No

Coolcha Lagoon 1284 436 -045 Yes

Tailem Bend 957 811 -057 Yes

Younghusband 223 23 -010 Yes Younghusband West 1089 887 -062 Yes Caurnamont 903 464 -021 No Craignook 369 208 -002 Yes

Forster Lagoon 80 641 -022 No Henley Park 224 177 -027 No Bow Hill 475 140 -033 No Mannum Swamps 1977 1450 -035 Yes Mason Rock 258 91 -046 Yes Reedy Creek 986 436 -004 Yes Priess Landing 5 29 -069 No

Teal Flat 82 476 -011 No

Wongulla Lagoon 124 365 -046 No

Total 24449 13161

66 In the final paragraph on pg 12-16 the EIS says that re-wetting could potentially cause water in these wetlands to become acidic (if acid sulphate soils are re-wetted) which c ould c ause the following ac id ity would then remob ilise meta ls c onta ined within the sediments causing disease or death in fish due to metal toxicity Should this be experienced management measures identified in Chapter 15 will need to be undertaken What a re the management measures How will SA know if this has occurred (ie monitoring)

Response Refer to response in Ref 64 in regards to management of potential risk of ASS in wetlands inundated at 01m AHD The Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project incorporates the development of a monitoring program to assess the success of the ASS mitigation strategies and ecological impacts This will include the monitoring of water quality metals biota such as fish groundwater and vegetation

67 What will be the objectives of the management plan for re-wetting exposed acid sulphate soils How will it achieve these objectives (Table 15-6 pg 15-21)

Response The objectives of the management plan for re-wetting exposed acid sulphate soils are

To mitigate the risks of acid and metal mobilisation to the main River channel water quality and biota of the River Murray and associated wetlands

Supplementary EIS for the temporary weir near Pomanda Island -76-

Mitigate the risk of acid and metal mobilisation within the wetlands above Lock 1 when they are refilled and Ensure the development of ASS mitigation methods incorporate the environmental values of each of the wetlands

The objectives will be achieved through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project which will develop site-by-site management options for ASS hazards The risk assessment has been undertaken which has identified 14 wetlands that require management of ASS hazard Management options are currently being developed and may include regulating structures and other methods such as neutralising agents mulching and revegetation with the aim of ameliorating the risk to the main River channel due to the rewetting ASS hazard wetlands

68 Will the rewetting strategy for ASS areas in the weir pool affect the time it takes to fill the weir pool and therefore prolong the period of no flow to Lake Alex

Response The refill volumes for each of the 25 wetlands that will be inundated at 01m AHD with the construction of a temporary weir near Pomanda Island are currently being calculated using modelling and survey work It expected that the total volume of water required to refill these wetlands will be insignificant in relation to the volume of water required to fill the River channel and would not prolong the period of no flow to Lake Alexandrina

With only 3 of the 75 wetlands in this reach currently wet due to the low River levels it is important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island The re-wetted wetlands will provide important aquatic refuges and breeding opportunities for biota

Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

Threatened and migratory species

69 On pg 13-13 the EIS says The lac k of c onnec tivity [ie as a result of the weir b loc king migration] is expected to also hinder gene flow between populations potentially leading to a decrease in diversity in both Murray Cod and Murray Hardyhead populations if it c ontinues for a suffic ient period What would be a suffic ient period in this c ase Would three years (the design life of the weir) be a sufficient period Obviously for Murray Hardyhead even one year of interrupted reproduction could be significant as the species only lives for 2 years (pg 13-14)

Response A fishway to suit large and small species will be included in the weir design and design is currently underway

70 At what water level will the Swamps of the Fleurieu Peninsula disconnect from the main body of Lake Alexandrina (as per pg 13-4)

See page 32 of the supplementary EIS under the heading Impacts upon tributary wetlands

71 Lack of detail in section on Orange-bellied Parrot (pg 13-8) to exactly where will vehicle movement be spatially restricted How will the creation of new tracks be limited What vegetation will be cleared and how much

Response Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coor ong_Survey_lowpdf

In order to gauge the potential impact of the construction of the temporary weir on local biodiversity a thorough ecological survey of the immediate area in Spring 2009 is

Supplementary EIS for the temporary weir near Pomanda Island -77-

desirable Survey results can then inform relevant mitigation strategies to be included in the EMP

Construction activities on (Pomanda Island) will be restricted to along the northern edge of the island and locally around the abutment It is expected that the temporary weir will cause a minor loss of some of the reed beds along the western access road to the construction site due to the need to construct a wider road for truck traffic The construction footprint will be minimised as far as practically possible by minimising the road width and avoiding the reed beds where practically possible Construction activities on the eastern side will be localised to the immediate area around the abutment The landscape on the Eastern side is characterised by farmed paddocks Hence no reeds (and no habitat of the Orange bellied Parrot) are expected to be impacted on the Eastern side

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

72 In Section 1352 on pg 13-9 rela ting to the Southern Bell Frog it doesn t mention tha t the frogs have been found at Pelican Lagoon (pg 7-24) the section goes on to mention that the site at which the southern bell frog was recently recorded is expected to be disconnected from the water when Will the regulated pumping system continue to operate

Response The main body of Pelican Lagoon where Southern Bell Frogs (SBF) have previously been recorded (River Murray Wetlands Baseline Survey 2005) has been dry since 2007 It is unknown as to whether SBFs are still located in the dredged area closest to the river It is expected that this dredged area will remain inundated at +01m AHD but the rest of the wetland will remain dry

73 Where is the previously occupied southern bell frog habitat near Wellington How will the raised water level help frogs to recolonise this habitat (pg 13-10)

Response The previously occupied site for the Southern Bell Frog near Wellington is called Ferry Crossing (Coordinates139386 -35337) The recording was in the 2000 frog census on 15 September 2000 numbers were identified as few The only other areas where they have previously been recorded within the Lower Lakes are at Tolderol Game Reserve and Clayton (Dunn Lagoon) These sites are to the West of Wellington on the shores of Lake Alexandrina

The raised water level of the weir pool will re-hydrate the wetland and provide re connection with the main river channel This in turn enables the re-establishment of emergent and submergent vegetation within the wetland providing suitable habitat for the species to colonise and reproduce Reproduction requires still or slow moving water (Australian Government 2009)

Australian Government 2009 Significant Impact Guidelines for the vulnerable growling grass frog (Litoria raniformis) EPBC Act Policy Statement 314

74 An Environmental Management Plan is proposed as mitigation to the likely impact of disruption to Southern Bell Frog tadpole migration (Table 16-1 pg 16-3) how will the EMP mitigate this impact Need more information on the potential for the weir to disrupt the dispersal and migration of southern bell frog tadpoles (pg 13-10)

Response This response takes into consideration the history of inter-governmental documentation on this point in relation to the proposed Pomanda Island Temporary Weir and a lso the Dra ft EPBC Ac t Polic y Sta tement 314 Signific ant impac t Guidelines for the vulnerable growling grass frog (Litoria raniformis) [= southern bell frog] (Feb 2009)

Environmental conditions habitat and breeding

The preferred habitat for breeding of the southern bell frog is high emergent vegetation cover (eg Phragmites and Typha) and still or slowly-moving water (Stratman 2007 DEH 2009) Current conditions in the Lower Lakes region are poor and breeding is unlikely to be occurring in the region at the moment It is unlikely that breeding will occur immediately downstream of the temporary weir in the short-term Immediately upstream of the temporary weir it is likely that habitat conditions will be maintainedenhanced (see also page 30 of this document)

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Migration of southern bell frog

It is now considered that the original comment in the draft EIS of The likely impacts on this species are confined to possible Interruption to dispersal and migration of tadpoles Additional pressures resulting from the construction and operation of the temporary weir include short term changed water regimes water chemistry and localized noise As no individuals have been recently recorded at the proposed site these local disturbances are not expected to impact the population was incorrect in its reference to tadpoles The adults of the species are highly mobile (movement of up to 212 m in a single night has been recorded referred to in Schultz 2008) Less is known about the mobility of tadpoles Tadpoles may be involuntarily swept over the temporary weir during significant flow events The top height of the proposed temporary weir is lower than the normal operational sill level at the Goolwa barrages so the structure will only present a barrier to dispersal of the Southern Bell Frog during unfavourable conditions such as those that have prevailed for the last 18 months

Since adult frogs are highly mobile the causeway and abutments associated with the temporary weir may impact on the movement of adults along the banks of the river corridor Experimental developments in Victoria have used culverts or pipes placed beneath roads as corridors to try to link populations however Bell Frogs have not been observed using them to date (G Heard personal communication)

Survey

The SAMDB NRMB advised that a targeted frog survey was needed to determine whether Southern Bell Frogs still remain in the vicinity of Pelican Lagoon prior to the development of the Environmental Management Plan

DEH undertook a habitat preference survey during March 2009 and a follow-up survey is planned for Spring and Summer 2009 to assess population numbers The rapid assessment of suitable habitat for the Southern Bell Frog (March 2009) was conducted around the perimeter of Lake Alexandrina and Lake Albert with survey sites stretching along the edge of Lake Alexandrina from Milang to Wellington then Wellington to Meningie along Lake Albert around to Narrung The result of this habitat assessment is a proposed targeted species survey in line with the original project objectives

As indicated in Figure 7-4 of the Draft EIS L raniformis has been detected at wetland habitats around Lake Alexandrina and in the lower reaches of the Murray River upstream of the lake including locations near Narrung Point Malcolm Wellington and around Milang Most of the sites based on habitat mapping undertaken by DEH are characterised by permanent water and to some extent reedbeds

Mitigation

The comment on mitigation that was included in the draft EIS is relevant

All construction operation and decommissioning activities are expected to be done in accordance with an Environmental Management Plan A survey for this species is expec ted to be c onduc ted in 2009 to better understand the p resent d istribution The initial assessment to indicate likely target sites (preferred habitat survey) has now been completed and the follow-up survey is planned for spring summer later in 2009

75 On pg 13-11 the EIS says that the Yarra Pygmy Perch are more commonly found in the well-vegetated lake margins and the channels of Hindmarsh Island and the lower ranges of the eastern Mt Lofty Ranges tributaries but that these areas are currently disconnected from the main body of Lake Alexandrina (also on pg 14-1) When did the channels of Hindmarsh Island disconnect Yet it is stated in the EIS the eastern Mt Lofty Ranges tributaries (Currency and Finniss) a ren t expec ted to be d isc onnec ted until lake levels drop to -12m AHD (pg 10-1) do you mean Angas and Bremer

Response refer to the discussion on page 23 of the supplementary EIS regarding Connectivity of Surface and Ground Waters

76 Why do PIRSA Fisheries have a policy of not re-stocking fish species (pg 13-14) and what is different about these circumstances that would mean it is now a suitable option

Response PIRSA Fisheries advises that in the absence of a fishway stocking of fish to increase populations in a degraded habitat is unlikely to result in a net increase in the population However as the water is pooled upstream of the new temporary weir there could be some limited restocking as the environment improves to allay any concerns

Supplementary EIS for the temporary weir near Pomanda Island -79-

that cod populations have suffered from the weir works The PIRSA website has a policy paper4 which explains why large scale restocking is not supported (there are implications of spreading diseases in wild populations from those that have been housed in aquariumsgrown in aquaculture there is also the risk of limiting genetic diversity if stock have been bred from only a few source fish and a series of other issues)

In regards to the broader issue of re-stocking native fish species within the site that have been lost to the freshwater environment due to their complete disconnected from the lake re-stocking before recovery of the ecosystem is not appropriate Upon recovery of the ecosystem and re-establishment of an appropriate freshwater ecosystem these species will either re-colonise from elsewhere or if only located regionally re-introduced via a stocking program An existing program is in place whereby populations are being bred in captivity to allow later re-introduction in the future of EPBC listed (Yarra pygmy perch and Murray hardyhead) and regionally significant species (Southern pygmy perch River Blackfish and Southern Purple-spotted gudgeon) We are presently in the situation where for some species (those listed above) there are no remaining genetically-distinct populations remaining in-situ so the only option is to reintroduce those held in captivity if we want the population to persist Murray cod are believed to be a single genetic unit across South Australia and hence re-population from upstream populations should enable recovery This could be supplemented by a breeding program but would be subject to a complete collapse of the SA South Australian population and approval from PIRSA as would the re-introduction of other species presently held in captivity and would be subject to specific testing and satisfaction of relevant conditions

In addition to these potential activities a fishway is now being included in the design for the temporary weir to enable the egress of species from the lake environment into the river channel above Wellington

77 What is the evidence that Murray Cod and Murray Hardyhead are able to withstand high turbidity conditions (pg 13-15)

Response No data on the tolerances of Murray Cod and Murray Hardyhead to high turbidity conditions are available Evidence on tolerance to relatively high turbidity is correlative Both of these species are distributed across lower regions of the Murray-Darling Basin in areas subject to relatively high turbidity Turbidity in the River Murray in South Australia is highly variable and largely influenced by discharges from the clay-laden Darling River (Woodyer 1978) Turbidity at Morgan averaged 516 NTU between 1994 and 2004 with peaks as high as 304 NTU (Westwood and Ganf 2004) Turbidity in Lake Alexandrina is also highly variable with mean values between 1975 and 1978 varying from a high of 93 NTU to a low of 9 NTU with localised values as high as 150 NTU recorded (Geddes 1988)

78 What would the parameters be for reintroduction of Yarra Pygmy Perch andor Murray Hardyhead (pg 13-16)

Response The reintroduction of the Yarra Pygmy Perch and the Murray Hardyhead would be undertaken once the habitat has been rehydrated and the keys components to their survival are in place such as

There is a level of confidence inflows into South Australia will be able to sustain the habitat at least in the medium term Habitat structure has recovered (eg aquatic plants) sufficiently to provide for o Spawning o Shelter o Food source and o Predation avoidance Water quality parameters are within tolerances (specified in the draft EIS) of each species such as o Salinity o pH o Dissolved oxygen o Water temperature o Turbidity and o Concentrations of contaminants particularly Aluminium

4 httpwwwpirsagovau__dataassetspdf_file000950895Stock_enhancement_policy_Aug_07pdf

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For Murray Hardyhead the following ranges of parameters have been utilised for reintroduction at a Lower Lakes site

EC 2000 30000 EC

DO gt50 mgL (ANZECC WQ Guidelines)

Turbidity 2-200 ntu (ANZECC WQ Guidelines)

84PH 70

Yarra Pygmy Perch would have similar parameters but with a much lower salinity range

79 On Pg 14-7 it says that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB what noise levels will construction create

Response At this stage it is difficult to predict what the average noise level might be Presumably levels will fluctuate and for short periods of time the 56db level may be exceeded Important also in the equation is the distance of the waterbirds from the noise source If the equipment levels a re say 85dB(A) then they ll d rop to 45db (A) within 100m

There are no wetlands on the eastern side near the abutment We expect any areas around Low Point populated by birds to receive noise levels similar to that from a busy highway This same comment will apply for the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels so it is assumed they would occur further north into the wetland area

Monitoring of EPBC-listed species throughout the project is expected to occur to ensure construction operation and decommissioning activities do not impact on EPBC-listed spec ies how will monitoring ensure this This can only work if particular contingency measures are undertaken if a particular measure is observed during monitoring

80 On pg 15-24 it says tha t

Response Monitoring during operation of the weir Monitoring efforts will be coordinated as part of the SA MDB NRMB s na tura l resourc e c ond ition monitoring program It will include additional monitoring efforts as per expert advice

Monitoring during the construction and decommissioning of the weir It is recognised that the monitoring of the EPBC listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life breeding cycles The monitoring focus will be of an observational nature mainly in regards to compliance monitoring to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by Commonwealth and NVC) and the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora amp fauna expert advic e if warranted In add ition the Contrac tor s EMP will identify based on a risk assessment which specific mitigation and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations is recorded

Fishway

81 One of SA s river hea lth ob jec tives under the River Murray Ac t is Barriers to the migra tion of native species within the River Murray system are to be avoided or overc ome (pg 3shy36) The weir would obviously impede the migration of native species without appropriate measures eg fishways

Response As explained in the Supplementary EIS a fishway is now included in the design for the temporary weir SARDI have indicated that they have sufficient knowledge to be able to design a fishway without the need for further site survey work

82 On pg 5-5 the EIS says that no provision is necessary for fish passage

Response See response to 81

83 The weir may impede upstream movement of juvenile and adult (spawning) Murray Cod and would possibly affect the downstream drift of larvae into if lake if spawning in the

Supplementary EIS for the temporary weir near Pomanda Island -81-

river was to occur (pg 7-29) possibility of fishway to allow larvae movement or other mitigation measures

Response See response to 81

84 On pg 13-12 the EIS says that the weir is expected to limit migration abilities

Response See response to 81

85 Why wouldn t Murray Cod use the fishway (Tab le 15-9 pp 15-2526)

Response Due to concerns about the lack of a fishway a design process has been initiated with the assistance of consultants to determine a suitable design concept that would allow passage of both NES and other fish species A concept design is expected to be available in July 2009 The inclusion of a fishway has a number of challenges not the least of which is the initial desire of the fish specialists to pass all the normal flow of approx 1 GLday through the fishway rather than over the spillway

86 Construction of the weir embankment begins when water levels in Lake Alexandrina are between -05m and -10m AHD (pg 5-11) however on pg 12-17 it says construction is preposed to commence when lake levels are at -11m AHD which will occur in October 2009 according to Figure 1-3 and then in Table 16-1 on pg 16-2 it says that construction is proposed to commence at 9 months before Lake Alexandrina is predicted to reach shy15m AHD

Response We will commence work at the latest date regardless of the water level that will allow closure of the river by the required deadline date It is expected to take approx 9 months from the award of contract to closure of the river but the weir construction will not be completed until a number of months after the closure date

87 2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Response South Australia is guaranteed 896 GL of dilution and loss flow plus 201 GL of Critical Human Needs reserved from 2008-09 The figure of 940 GL was a possibility in December 2008 but should not be used

The graphs provided clearly state 896 GL flow for 2009-2010

88 A dilution flow of 696 GL per year is available to SA which is used to maintain salinity levels at Murray Bridge below 1400 EC (pg 2-13) however on pg 4-5 it says than 200 GL in addition to the 696 GL is needed to maintain the salinity at this level at Murray Bridge on pg 10-7 it says that 695 GL is the dilution flow

Response The dilution and loss component of Entitlement Flow guaranteed to South Australia under the Murray-Darling Basin Agreement is 696 GL per year This does not meet the normal system losses within South Australia (average about 1130 GL per year) and this flow does not dilute salinity sufficiently to maintain lt1400EC at Murray Bridge Modelling has shown that an additional 200 GL is required to maintain salinity at Murray Bridge at lt 1400 EC (ie a total flow of 896 GL)

As stated in the response to question 9 South Australia is now guaranteed a flow of at least 896GL during 2009-10 The 896 GL includes 201 GL extracted for Critical Human Needs

Note that the 201 GL for Critical Human Needs serves a dual purpose in that it also contributes to the dilution of the salt loads as well as being extracted mainly in the lower reaches of the river for use in the potable water supply system

89 The text on pg 2-15 says that it is predicted that by May 2009 salinity in Lake Alexandrina will be about 7260 EC however Fig 2-11 on the same page and Fig 1-4 on pg 1-4 show that salinity is predicted to reach only just over 6000 EC by May 2009

Response Both graphs are the same and by May 2009 it was projected that the salinity would be around 6000 EC Current salinities indicate that this projection will be accurate The figure of 7260 EC on page 2-15 is incorrect and is corrected in the Errata

90 It would require 220 GL in 200910 and 365 GL in 201011 to maintain the lakes at 10cm above the critical acidification level [ie maintain the lakes at 1-4m AHD (sic)] however it is unclear if this means water flowing over the weir or additional water purchased from upstream (pp 4-78)

Supplementary EIS for the temporary weir near Pomanda Island -82-

Response South Australia is committed to providing a minimum River Murray flow of 350 GL per annum to Lake Alexandrina via Wellington This minimum flow is required to maintain potable water quality (salinity not exceeding 1400 EC) at the SA Water Corporation major pumping station at Murray Bridge

The cessation of pumping from Lake Alexandrina to Lake Albert preserves approximately 170 GL per annum in Lake Alexandrina and reduces the additional water requirement for 200910 from 220 to 50 GL and the requirement for 201011 and subsequent years to 195 GL per annum The 170 GL annual savings is a subset of the 350 GL annual commitment

The additional 50 GL (200910) and 195 GL (201011) requirements are over and above the 350 GL commitment and could be sourced from improvements in River Murray flows improvements in eastern Mount Lofty ranges tributary flows better than worst-case rainfall directly over Lake Alexandrina (Lake Albert is now under alternative management) better than worse case evaporative losses and purchases from intra and interstate

91 In 2007-08 SA was supplied 1564 GL of water and the River Murray supplied 95 of this (Table 1-1 pg 1-2 2) however on pg 2-4 it says that in 2007-08 SA Water provided SA with over 176 GL of water 95 of this was sourced from the Murray

Response Table 11 may be poorly labelled The figure of 1564 GL in 2007-08 is the demand from the Metropolitan Adelaide Water Supply System It includes water pumped through the Mannum Adelaide pipeline system and the Murray Bridge Onkaparinga pipeline system so therefore covers Adelaide plus the surrounding areas supplied from these pipelines The 176 GL figure in 2007-08 represents the above demand plus the usage from the other two major pipeline areas supplied from below Lock 1 (ie Swan Reach amp Tailem Bend)

92 On pg 2-12 the EIS says that in 2006-07 SA Water provided SA with just over 245 GL of water approximately 90 of which came from the Murray however in Table 1-1 on pg 1-2 2 it says SA used 1805 GL 79 of which came from the Murray

Response See Response to 91 above

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Supplementary EIS for the temporary weir near Pomanda Island -84-

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report

85

1 Introduction

Community Consultation Report purpose The Community Consultation Report is a companion document for the Supplementary Environmental Impact Statement (EIS) for temporary weir near Pomanda Island This Report is the record of activities completed during the public consultation period and a record of the submissions received on the draft EIS

This document demonstrates that the Department for Environment and Heritage (DEH) created a public interest context for the Environmental Impact Statement process

The Department gathered processed and responded to public submissions so that the Supplementary EIS was appropriately produced

Objectives for this Report are

to meet the requirements of the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act)

to record the actions of the Community Consultation process

to record all submission summaries and a response to them This is a significant aspect of the Community Consultation Report (Appendix IX)

to demonstrate that a diligent transparent and effective process was in place which optimised receipt of public submissions relevant to the draft EIS

Summary This document overviews

four Community Information Sessions about the Draft EIS for the general public targeted consultations with Ngarrindjeri and ten other specialist groups media generated during the consultation period processes for receiving submissions and for developing the Supplementary EIS

2 Community Information Sessions Advertising and materials distribution prepared the way for the Community Information Sessions

Community Information Sessions were advertised using newspaper advertisements the DEH website and the Coorong Lower Lakes and Murray Mouth Project (DEH) email Bulletin lists (See Appendix VI)

Draft EIS materials (CD hard copy Executive Summary) were distributed widely free of charge The full text Draft EIS was also made available in appropriately targeted local government offices and schools and a number of full text Draft EIS Appendices were also available Hard copy Draft EIS were available for $100 from one Adelaide retail outlet (See Appendix VI Distribution List)

Four Community Information Sessions were held as follows

Murray Bridge Tuesday 24 March 2009 1000am - 1230pm Uniting church Worship Hall Registered attendees 50 people

Meningie Tuesday 24 March 2009 300pm - 530pm Meningie Bowling Club Registered attendees 47 people

Goolwa Friday 27 March 2009 1000am - 1230pm Centenary Hall Registered attendees 93 people

Clayton Bay Friday 27 March 2009 400pm - 630pm Clayton Community Hall Registered attendees 53 people

Supplementary EIS for the temporary weir near Pomanda Island -86-

A total of 243 people attended the four Community Information Sessions

The agenda for these meetings were as follows

Community Information Sessions Agenda

Facilitator Lindsay Holmes (Meeting Success)

Session Length 25 hours

Timing Task Responsible person

(mins) 5 Welcome and Ground Rules Lindsay Holmes Welcome to Country 5 Explain purpose of Session Peter Croft 5 Introduce specialist panel Lindsay Holmes 20 Explain session agenda and process Hon Dean Brown

Water Presentation 25 EIS introduction presentation Russell Seaman 5 How to respond to the EIS Peter Lumb 5 Explain small group purpose Lindsay Holmes 15 Tea Break 20 Work in small groups Lindsay Holmes

Groups identify and prioritise questions for resourc e peop le

60 Resource people answer questions Chaired L Holmes 5 Meeting thanks and closure Peter Croft

Explanation of the agenda

The purpose of the Community Information Sessions was to provide information about the EIS process and to assist people in preparing their written submission (comment) on the draft EIS It was made clear that the sessions were about gaining information rather than making verbal public comment on the draft EIS

A range of options for lodging submissions was presented

At each Community Information Session there was a panel of five or six specialist resource people

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The panel was drawn from the following

Peter Croft DEH Director Coorong Lower Lakes and Murray Mouth Projects

Russell Seaman DEH Manager Environmental

Dr Kerri Muller Contract Ecologist

Ross Carter SA Water Manager Major Projects

Glynn Ricketts DWLBC Environmental Water amp Infrastructure

Judy Goode DWLBC River Murray Environmental Manager

Hon Dean Brown Drought Reference Group

Premier s Spec ia l Advisor on Drought

Paul Harvey Murray Darling Initiative

Program Leader

Jan Whittle SA Murray Darling Basin NRM Board

River Murray Environmental Manager Unit

The panel of specialists was introduced early in each meeting prior to two major presentations

Russell Seaman gave a PowerPoint presentation which overviewed key aspects of the draft EIS for the proposed temporary weir near Pomanda Island

The Hon Dean Brown gave a PowerPoint presentation which provided a Murray-Darling Basin water issues context for the proposed temporary weir

Participants formed groups of eight with a trained DEH facilitator The purpose of the group fac ilita tion was to write questions on la rge post-it notes These questions were to be sorted and answered by the specialist panel

As group facilitators wrote questions the questions were continuously collected and placed on a wall Specialist panel members gathered and discussed who would be the most appropriate panel member to answer each question Like-questions were assembled with like Duplicate or overlapping answers were avoided

The meeting regathered and the specialists answered questions in an open manner

DEH provided a light meal at the end of each Community Information Session Community members were invited to stay on after the meeting to informally discuss issues and ask questions of the specialists Many members of the public accepted the invitation

This meeting format allowed all community members the opportunity to ask questions hear answers from people with specialist knowledge and then to engage with them further This was a successful format for the purpose of sharing information A large number of questions were answered and the community had maximum exposure to specialist panel members Panel members and community members generally responded favourably to this format

The records of these meetings include the wording of each question submitted to the specialist panel (Appendix IV) A summary of broad indicative categories of questions are included in Appendix IV including a graph consolidating answers from the four Community Information Sessions

People who attended the Community Information Sessions were invited to pre-register via email at eisdehsagovau or to register through an EIS 1800 number hotline (Appendix VIII) Registrations were sought to ensure that venues had sufficient capacity there was a sufficient number of group facilitators and so that catering was adequate Registrations were also accepted on entry and all registrants were supplied with a

Draft EIS Executive summary

CD containing a submissions cover sheet the Executive Summary the full text Draft EIS and all Appendices of the Draft EIS and

paper summary of the main PowerPoint Draft EIS presentation

Registration also provided the option for people to provide an email address so that they could receive Coorong Lower Lakes and Murray Mouth project updates

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In addition copies of Sim T and Muller K (2004) A Fresh History of the Lakes Wellington to the Murray Mouth 1800 to 1935 SA Murray Darling Basin Natural Resources Management Board Government of South Australia were available to registrants courtesy of the MDB NRM Board

3 Targeted Meetings The Ngarrindjeri People individually and collectively are involved in ongoing consultation about the about the Draft EIS for the proposed temporary weir near Pomanda Island Consultation about the Long Term Plan for the Coorong Lower Lakes and Murray Mouth will be ongoing

Ten targeted meetings were held between 2 February and 2 April 2009 Two meeting were held in Adelaide and eight were in the region (Appendix III)

The targeted meetings were attended by Peter Croft Director Coorong Lower Lakes and Murray Mouth Projects and Russell Seaman Manager Environmental (Department for Environment and Heritage) Peter Croft briefly discussed the developments leading towards the Long Term Plan for the Coorong Lower Lakes and Murray Mouth while Russell Seaman provided the PowerPoint presentation used for the Community Information Sessions but tailored the presentation towards the interests of particular audiences Brief records of these meetings appear in Appendix V

In each case these targeted meetings were scheduled meetings which allocated time on their agenda for the additional presentations about the Draft EIS and the Long Term Plan

4 Overview of media articles (see Appendix VII) This section provides the media context during the time leading up to the opening for public comment on the Draft EIS for the proposed temporary weir near Pomanda Island (12 March) to the close of the comment period (9 April)

In January and February 2009 med ia foc ussed on d isc ussions about flood ing the Lower Lakes Two of the 15 stories provided mention of the proposed temporary weir Through March when the Draft EIS for the proposed temporary weir near Pomanda Island was released 18 of the 20 articles focussed on the proposed weir Some media reporting (as summarised by Media Monitors) did not clearly differentia te between the EIS for the flood ing of the Lower Lakes and the EIS for the Proposed Temporary Weir indicating and exacerbating some public confusion

Main discourse The South Austra lian Government s ma in message was tha t the weir is a last resort tha t will only proceed if absolutely necessary in a worst case scenario situation The South Australian Government is committed to seeking a fresh water solution - they do not want to build the weir

A consistent criticism of pursuing approval for the weir is that it indicates that the South Australian Government has given up on a freshwater solution The media surveyed indicates that a fresh water solution is the preferred and only suitable option If the South Australian Government was serious about providing a solution media discourse suggests they would use the money to purchase water rather than for construction of the proposed temporary weir

Many who are opposed to the weir are of the opinion that the government has already made its decision and the weir will go ahead

Other issues raised There were several other issues raised in the articles including

the proposed temporary weir will cut off the River Murray from the Lower Lakes (one article)

there are alternatives to the weir such as storm water harvesting and more water efficiency (one article)

if the weir is built it is a temporary weir and temporary solution and the final decision on the weir will come six months prior to decision to flood the lakes (one article)

the number of regulators and weirs being planned in addition to the proposed temporary weir Clayton Finniss Latham Point Goose or Goat Island (two articles)

Throughout the majority of articles the weir was referred to as the weir or the Wellington weir and approximately 10 per cent of the time it was called the Pomanda weir

Supplementary EIS for the temporary weir near Pomanda Island -89-

A media release by the Federal Minister for Environment Heritage and the Arts mentioned the need for a long term vision and noted that the Australian Government has committed $200 million from its Water for the Future Plan to assist in the planning process and an additional $10 million towards the development of a long term plan for the Coorong and Lower Lakes

Two media reports expressed concern about the triggers to remove the proposed temporary weir saying that unless increased salinity and acidification levels are addressed and there is freshwater released into the lakes one of the triggers that salinity levels drop below 3000EC - will not be able to happen

Summary

Media analysed

Medium (Total) Channel Number ABC 16 5AA 5Radio (22) Triple M 1 9 Network 2 10 Networks 1Television (4) ABC 1 1 Independent Weekly 1 Adelaide Advertiser 1 Stock Journal (Regional) 3 Times Victor Harbor 1 Murray Valley Standard 1

Print (8)

Lakelander 1

Media release The Hon Peter Garrett Minister for the Environment Heritage and the Arts (one)

Four were regional stations five were Adelaide metropolitan stations and seven were both Adelaide metropolitan and regional stations

Total - 35

5 Receiving submissions and developing the Supplementary EIS The Draft EIS was open for public comment from the 12 March to 9 April 2009

The public were invited to provide written submissions as emails as emails with word attachments or to send hard copy using a free post address

Seventy submissions were received from the public There were 49 individual submissions 18 from community and other organisations and three from local government All submissions are available on DEH website wwwenvironmentsagovaucllmmsubmissions-receivedhtml

Submissions were uploaded twice per week during the public comment period Submissions were listed by author or organisational author as per Appendix I and Appendix II

Supplementary EIS for the temporary weir near Pomanda Island -90-

Timeline of the post-Community Consultation period

9 April Acceptance of submissions closed at 5pm

10 13 April

During the four days over Easter submissions were read summarised and a statement provided in a response column Key words in submissions were identified Summaries and responses were entered into a specially prepared Microsoft access data base Summaries from the data base are provided as appendix ix

14 April

A list of key words was compiled from the access data base The data base was then searc hed by a ll relevant key word s All sub missions jud ged to be in sc ope and a ssoc ia ted with a key word or key word string were then assembled Submissions were then sent to thirteen specialist writers Most writers had attended a meeting at which the requirements for preparing responses were outlined and the constraints of the tight timeline emphasised Other writers had individual briefings Writers could choose to receive hardshycopy of all relevant submissions or access copy on the internet The broad objective provided to writers was to create an over view summary of issues in response to issues associated with the key words for which they were responsible

15 17 April Specialist writers had three days in which to write their over view summaries

17 April Summaries were returned for compilation into the supplementary EIS and an executive writer and assistants then had six days to create an integrated supplementary EIS

24 April A draft of the supplementary EIS was prepared and sent to specialist writers for comment to be returned by 12pm Monday 27 April

27 April

Comments were incorporated into the draft of the supplementary EIS and a new version prepared for a briefing meeting on Tuesday 28 April The objective of this meeting was to facilitate final changes before chief executive and ministerial sign off

30 April The supplementary EIS was prepared and sent to the chief executive and the minister s offic es

Supplementary EIS for the temporary weir near Pomanda Island -91-

Supplementary EIS for the temporary weir near Pomanda Island -92shy

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report ndash Appendices

93

Appendix I Submissions received Individuals

Surname First name Suburb Date Submission

number

Cooke Roger Goolwa 29032009 PTW00001

Galea Michael Clayton Bay 30032009 PTW00002

Fargher Philip Norwood 01042009 PTW00003

Zoerner Andrew Prospect 03042009 PTW00004

Smith Douglas Goolwa 03042009 PTW00005

Rees Melanie Henley Beach 03042009 PTW00006

Brisco Mike Campbelltown 04042009 PTW00008

Moyle Ian Woodcroft 05042009 PTW00009

Harvey Richard North Adelaide 06042009 PTW00011

Richards Sally Finniss 06042009 PTW00012

Giles Trevor Langhorne Creek 06042009 PTW00013

Lower Brenda Goolwa 06042009 PTW00014

Michelmore Frederick Gordon Middleton 07042009 PTW00015

Lucas Ann Goolwa 07042009 PTW00016

Jones Glen Adelaide 07042009 PTW00017

Fenton Derek Finniss 07042009 PTW00019

Tjukonai Vesper Meningie 07042009 PTW00020

McFarlane Keith Tailem Bend 07042009 PTW00021

Read Tony Beaumont 07042009 PTW00023

X Mick Mannum 08042009 PTW00024

Hartnett Anne Milang 08042009 PTW00025

Whitehead Alexander Hindmarsh Island 08042009 PTW00027

Fairweather Peter Adelaide 08042009 PTW00028

Thomas Robert Goolwa 08042009 PTW00029

Carroll Barbara Happy Valley 08042009 PTW00030

Jones Henry Clayton 08042009 PTW00031

Bagley Chris Milang 08042009 PTW00033

Yelland Liz Milang 09042009 PTW00034

Vonow Lynton Lobethal 09042009 PTW00035

Trigg Ruth Normanville 09042009 PTW00036

Yelland John Milang 09042009 PTW00037

Brooks Bruce Finniss 09042009 PTW00038

Walker Keith Yankalilla 09042009 PTW00039

Harden Trevor Finniss 09042009 PTW00041

Allnut Bruce Finniss 09042009 PTW00042

Shillabeer Neil Oakbank 09042009 PTW00043

Heyne Ron Goolwa 09042009 PTW00044

Showell Jacqui Goolwa Beach 09042009 PTW00048

South Cecily Milang 09042009 PTW00049

Moon Silver Finniss 09042009 PTW00051

Supplementary EIS for the temporary weir near Pomanda Island -94-

Surname First name Suburb Date Submission

number

Hunter Rex 09042009 PTW00052

Bradford Karen Milang 09042009 PTW00059

South Mike Milang 09042009 PTW00060

Belford Beryl Mt Barker 09042009 PTW00063

Hobbs Elizabeth Goolwa 09042009 PTW00064

Vizard Talina Victor Harbor 09042009 PTW00065

Carter Carlsa Bridgewater 09042009 PTW00066

Scobie Keith Meningie 09042009 PTW00069

Russell Ruth Magill 16042009 PTW00070

Young amp Jury Mike amp Ken Goolwa 16042009 PTW00071

Submission received under special circumstances Submission sent prior to end of community consultation period

Supplementary EIS for the temporary weir near Pomanda Island -95-

Appendix II Submissions received Organisations

Organisation Date Submission

number

Southern Alexandrina Business Association Inc 04042009 PTW00007

Signal Point Riverine Environment Group Inc 05042009 PTW00010

Alexandrina Council 07042009 PTW00018

The Marina Hindmarsh Island 07042009 PTW00022

SA MDB NRM Board 08042009 PTW00026

Rural City of Murray Bridge 08042009 PTW00032

Australian Institute of Landscape Architects 09042009 PTW00040

Ngarrindjeri People 09042009 PTW00046

DTEI 09042009 PTW00047

Environmental Defenders Office (SA) Inc 09042009 PTW00050

The Coorong District Council 09042009 PTW00053

River Lakes Coorong Action Group Inc 09042009 PTW00054

Nature Conservation Society 09042009 PTW00055

Murray-Darling Basin Authority 09042009 PTW00056

Australian Democrats 09042009 PTW00057

Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

09042009 PTW00058

PIRSA Fisheries 09042009 PTW00061

Natural Heritage Trust 09042009 PTW00062

Conservation Council of South Australia 09042009 PTW00067

Goolwa District Ratepayers and Residents Association Inc 09042009 PTW00068

Supplementary EIS for the temporary weir near Pomanda Island -96-

Appendix III Participants and notes from Targeted Meeting Sessions

Local Knowledge Reference Group

Date Wednesday 4th February 2009 1100am 200pm Location The Monastery

In attendance Dean Brown Bill Paterson Prof Diane Bell Mike Geddes Mike Hammer Neil Shillabeer Paul Davis Rebecca Lester Rob Fitzpatrick Sebastian Lamontagne Mary-Anne Healy

Summary of comments or issues

Draft EIS was presented to the Local Knowledge Reference Group (LKRG) - draft is confidential

Consequences of weir removal and ability for system to recover

Scope of EIS should extend beyond matters of NES

Management strategies for potential flooding should be addressed in the EIS

Approvals process

Concerns regarding high water mark in relation to the causeway and Ramsar boundaries

Apologies were given to the group in regards to the lack of communication around the draft EIS in the past

Discussion

Raised issue re water levels relating to the barrages should say 7000 years

Changed the word ing to levels never rec orded ra ther than not seen sinc e the c onstruc tion of the barrages

No work has been done on how to recover the environment after the removal of the weir

Not going to remove the roads and tracks

Impacts locally not Ramsar site

Weir sinks over time

Remove down to bed level should not be any impediment to what was originally there

Will take time but should result in no impact

Weir will be there for 3 years

SA Water suggests there will be minimum impact

Mud waves will cause impact but will be transported away from sedimentary processes

Increased sedimentation as a result of the structure and disagreement that there will be a significant impact after the removal

The need to conserve the Ramsar wetland and what might be the implications Is it just going to go ahead Worried about the significant damage and if the system will ever recover

Cannot assess what has been done Needs clarity about the purpose of the group

Issues around rates of change and thresholds associated with the weir Also life stages and ecological character

Limited scope about this in the EIS only addresses matters of NES

Will edit the factual errors

Will help edit as well

Worried about experts need for higher level expertise for public comment period

Supplementary EIS for the temporary weir near Pomanda Island -97-

What if there are natural water flows floods Recovery Should be reference in the document to flood event happening and the ability to manage that

Agrees with Bill and need to understand and have something in place if there is a flood and removal of the weir

States that the draft EIS seems to have solid blame on the drought but over-allocation and excessive use are contributing factors as well Look at the language and justification of the EIS Issues about the decision making Commonwealth SA Gov

Understands that it goes to Commonwealth and SA Govt makes the decision Need approval under the EPBC Act

Need approval for MDBA and Minister

Interested to see if the Ramsar site is actually the boundary of where the weir will be built and the implications of that and whether the weir can take place

Drew a diagram of where the cadastral boundary is and where the causeway and proposed temporary weir are Assuming this is where the high water mark is

The whole group are concerned that the high water mark is actually exceeding where the causeway is and if that is the case the causeway and where the weir will be built will actually be in the Ramsar site

Supplementary EIS for the temporary weir near Pomanda Island -98-

Meningie Community

Date Thursday 5th February 2009 700pm 1100pm Location Football Club Rooms Meningie

In attendance Approximately 200 locals Andrew Beal Prof Diane Bell Robyn McLeod Dean Brown Peter Croft AProf David Paton

Summary of comments or issues

Dean Brown Prof Diane Bell Andrew Beal Peter Croft Robyn McLeod and AProf David Paton each gave a short presentation on current issues based around the Coorong and Lower Lakes providing management options

Summary of conditions and long term plans to help secure a future for the Lower Lakes Coorong and Murray Mouth

Following the presentations the community members were given the opportunity to ask questions of the presenters

Neil Shillabeer facilitated the meeting

The meeting was a little heated and closed around 11pm with people staying to speak with the presenters and other expertsofficials

Questions and discussion

What can we do to make other states realise that we are in a dire situation and that we need more water

What is temporary

Groundwater

Over-allocation

Where is the support for the community

Ngarrindjeri hurting no one is speaking with them or the community

What are the government officials going to do to help the community

Yes they are helping the environment but not the economic values and people

Why c an t they have a p ipeline like the other side (referring to the Langhorne Creek irrigation line)

Why haven t they been told about the c osts involved with this p ipeline

Lake Albert s a lloc a tion

What level will the Lakes be once the weir is in place

What are the trigger points for removal

If the weir is built are they going to put in fish ladders or will they be blocked

If Lake Alexandrina gets lower how are they going to continue pumping into Lake Albert

If seawater is let in how are they going to deal with the millions of dead fish and the clean up

How are they going to fix South Austra lia s own wa ter issues and a lloc a tions Need to address what is happening here before we blame upstream

Supplementary EIS for the temporary weir near Pomanda Island -99-

Milang Community

Date Thursday 12th February 2009 130pm 500pm Location Milang Institute Building

In attendance Anne Hartnett Dianne Bell Ken Follett Tim Trevorrow (APOL) Rowena Brown Dr Rob Fitzpatrick Bruce Brooks Graham Gates Lesley Fischer Tony Randall Peter Alexander Wayne Brown Carol Richardson Greg Lundstrom Richard Owen Peter Croft Clare Manning Russell Seaman Karyn Bradford Kathryn Rothe Shirley Smith Liz Barnett Simon Oster

Summary of comments or issues

The Lower Lakes Partnerships for Recovery

Lower Lakes communities are keen to use their knowledge labour and community infrastructure to bring about Lakes and River recovery

The community seeks partnership with government to

- Rescue and remediate degraded environments

- Impede further degradation

- Instigate environmental management and development practices

- Address current and future effects of climate change

Projects have been identified for both immediate and long term implementation

Revegetation Revegetate areas subject to Acid Sulfate Soils with plants having low impact on soil

saturation in

- Priority areas in Finniss River and Currency Creek

- Receding lake shores

- Known ASS hot spots

- Spots at-risk of drying out wind erosion and sun exposure and affected by stock access

Revegetation capacity building Collect seeds for replanting (native plants)

Undertake at-risk plant rescue and propagation

Purchase propagation and planting of annuals

Plant large trees away (upwind) from Lake edge as leaf litter will provide sources of organic matter and iron to Lakes (builds resilience)

Flora and fauna protection Control of increased feral populations arising from revegetation

Establish refuges for endangered flora (and fauna)

Weed control

Protecting fringing vegetation Protect lake revegetation areas from cattle

Protect cattle from poor quality drinking water

Environmental remediation Community Acid Sulfate Soil treatment projects

Source local limestone for application to ASS

Supplementary EIS for the temporary weir near Pomanda Island -100-

Nurture and capture knowledge

Train communities to identify and map plants useful for land protection and remediation

Create systems for long term monitoring of soils vegetation growth and regrowth

Establish community survey systems to map current and changing status of soils

Collect and contribute data that will enhance GIS data banks and veracity

Create local administrative and data collation processes to manage the above incorporating two-way communication and mutual benefit from data

Monitor water use to aid in the beneficial allocation of water resources

Supplementary EIS for the temporary weir near Pomanda Island -101-

Peter Croft s Murray Futures update for the Lower River Murray Drought Reference Group representatives

Date Thursday 26th February 2009 200pm 500pm Location Murray Bridge

Summary of comments or issues

Status of Environmental Impact Statement for the proposed temporary weir near Pomanda Island

Timelines for the project

Community involvement

Timelines for the Long-Term Plan to secure a future for the Coorong and Lower Lakes Ramsar site

Community Action Planning

Information provided

EIS has not yet been finalised or lodged but is in the critical final stages and is expected to be lodged shortly

We will be holding some Community Information Sessions in the 4th week of March (pending approval from the Commonwealth)

There will be a media release of notices via national state and local press announcing the sessions locations and times to inform the communities (subject to Commonwealth approvals)

These sessions are to summarise the draft EIS allow community members to ask technical questions of some specialists and provide advice to the community on preparing submissions on the draft EIS

A Reference group has been developed (The Long-Term Plan Reference Group) and brings together community leaders scientists and government staff with a view to develop a long-term plan to secure a healthy future for the Coorong and Lower Lakes Ramsar site

This is an important first step to help identify a realistic sustainable future for the region one that will address the environmental community and economic values that are important to the region

Our aim is for a coordinated management response for the future of the Coorong and Lower Lakes And involving the community along the way is critical to the success of our work

We are aiming for a 1st version of the Long-Term Plan ready for public consultation in April We will ensure that a range of different communities get on the list of possible locations (eg Milang and Langhorne Creek)

Notices of such events will be distributed through the national state and local press as well as our website

On 12th February we met with representatives of Landcare Groups and Local Action Planning Groups to discuss proposals for community action around the Lakes

A number of areas of action were identified and a small team with representatives from DEH Regional Conservation Team and LAP Coordinators will flesh out the actions in more detail

A Plan of Action is being developed for trial projects with potential funding of $100000 that may be available to support some preliminary work We plan to finalise the details and get activities rolling ASAP

Supplementary EIS for the temporary weir near Pomanda Island -102-

Ramsar Taskforce Committee

Date Friday 13th March 2009 1100am 1230pm Location Wyndgate

In attendance Ramsar Taskforc e c ommittee members Peter Croft Russell Seaman and Peter Lumb

Summary of comments or issues

Peter Croft briefly introduces EIS processes and distributes draft EIS community development and hard copy Executive Summary

Russell Seaman gave a presentation in the EIS and asks for feedback

Broad range of questions ranging from fish ladders in the weir to alternative options

Questions and discussion

Will the Supplementary EIS be made public

Will the Australian Government then require community consultation on the Supplementary EIS

Why is there such a short time for public comment on the draft EIS

What do you mean by environmental hotspots

Has any thought been given to a natural causeway near Pomanda Island

Is the weir site within the Ramsar site

Where will the water come from to flow over the weir if a weir is built

Comment about the importance of fish ladders

Emphasise that the weir is not a trigger for sea water incursions

Emphasise that the presentation is mostly based on worst case scenarios

The EIS must mention over-allocation

Emphasise actions taken or about to be taken when possible

Emphasise terrestrial vegetation more as well as Lake bioremediation

How much employment will be created in the region

Is it possible to have Councils administer vegetation and bioremediation projects rather than the Attorney-General

Supplementary EIS for the temporary weir near Pomanda Island -103-

Scientific Advisory Group (SAG)

Date Monday 16 March 2009 930am 1130am Location L5 81 Flinders Street Adelaide

In attendance Rebecca Lester Ingrid Franssen Mardi van Wielan AProf David Paton Adrienne Frears Glynn Ricketts

Summary of comments or issues

Decision trees and timelines

Alternative options

Trigger points

Questionscomments

Needrequest to set aside 5 for science to underpin management

Lake Albert needs early consideration

Need a decision tree as some actions are alternatives or consequent actions

Link decision tree to timeline and water flows

Need to account for measures for Long Term Plan to prevent the need to do reactive work again in ten years

Assumption restore wetland functioning to build resilience

Focus on upper Finniss and Currency dam bypasses upstream modelling water allocation and managing low-flows

Scientific Advisory Group can assist with advice if needed

Pomanda weir s estimated c ost $150m

Need to find out if there is a major ecological downfall if the acidification occurs

Reduce or stop pumping for winter lower evaporation and stop wind erosion

Apply limestone only when triggers are reached

Any ideas for the Long-Term Plan will influence the second version of the Plan

Ephemera l systems a re na tura l Lake Albert is a termina l wetland no outflows

A more complete document will allow a more thorough examination of the situation (possibly in April)

Which trigger will come first

Is a virtual weir still on the table

Does the dam allow for a fishway

Supplementary EIS for the temporary weir near Pomanda Island -104-

South Australian Murray-Darling Basin Natural Resource Management Committee

Date Thursday 19 March 2009 930am 1200pm Location Murray Bridge

In attendance SA MDB NRM Board members Peter Croft Kerri Muller and Lindsay Holmes

Summary of comments or issues

Questions focussed on conditions climate and the environment

Questionscomments

How will the weir be deconstructed

Can we separate the effect of the weir from the effect of the drought

Is the 350GL of wa ter over the weir in c urrent c ond itions

Will water go into the Lake when there are disconnection issues

Will there be a short-term increase in salinity while the pool fills

What is the current river level

Does the EIS consider scouring

Is flooding risk considered (in EIS)

Mud waves are a major issue

Why will construction of the weir be worse during summer

What are other alternatives

When does the EPBC Act review end

Can we make a definitive statement about what happens to the wetlands

Supplementary EIS for the temporary weir near Pomanda Island -105-

Icon Site Community Reference Committee

Date Monday 23rd March 2009 930am 1200pm Location Langhorne Creek Bowling Club

Summary of comments or issues

Questioned the science and experts available

Alternative options were discussed

Questioned engineering aspects of the weir

Russell Seaman presented an overview of the draft EIS

Group showed concern for repercussions of actioninaction

Questions asked

Coorong evaporation 200GL of fresh or seawater

Who will DEH engage as experts to advise on seawater incursion

What will DEH be basing their knowledgeevidence on in regards to the seawater incursion

Has anything like it been done before

Mulching

Limestone locally sourced

Coorong North lagoon monitoring and ASS who is monitoring and what is being done to remediate the hyper-saline conditions

To what extent can we replicate what was in the past southeast freshwater

Salinity in the south lagoon would the level allow Rupia sp to establish itself

Mechanical mouth operation as opposed to dredging has this been considered

What are some other options

Has the department looked at Vortex sand pumping

Will there be culverts between the Lakes through the causeway for water to flow via wind seiching

More research needs to be done has the Department considered engaging the local knowledge Don t dup lic a te researc h

If temporary why are you considering installing fish passages in 5 years time Should that not be done at the time of the weir installation

What levels are you looking at for the lakes

Supplementary EIS for the temporary weir near Pomanda Island -106-

Russell Seaman presentation Overview of the draft EIS for the temporary weir near Pomanda Island

Questions asked Why 01 AHD for the spillway

At what Lake level will it start acidifying

Should we have a lower weir

What is the risk of salt levels increasing when you stop the flows for 3 months

Will ground waters be coming in

What about the banks collapsing

What is the water quality of ground water and will it contaminate the Lakes

What happens if water flow exceeds 15GL per day ie if flood occurs will the structure cope

How quickly will the structure sink is it 1m per year

Will the weir be in place by 1st January 2010 as the graph indicates

When is -15 AHD expected

Has the Premier decided to buy water to see the Lakes through to winter 2010

Have you factored in the local rainfall flows within Currency Creek and Finniss

Is there an indication of seepage of ground water into any region of the Lakes

Have you looked at Biochar for remediation purposes

Lime straight pH neutraliser or feed the bacteria

Why not put a carbon source in there as well

Supplementary EIS for the temporary weir near Pomanda Island -107-

Lower River Murray Drought Reference Group

Date Thursday 2nd April 2009 Location Murray Bridge Council Chambers

Chair Dean Brown In attendance 14 Reference Group members 15 people in the Public Gallery

Summary of comments or issues

EIS Presentation by Peter Croft 30 Minutes including questions

Peter Croft presented overview of the draft EIS

Issues relating to seepage

Costs and issues relating to weir construction

Weir removal

Timelines for weir construction

Questions and comments

All questions asked were from Reference Group members with occasional comments from the public gallery

If the weir is built will more wetlands be closed between the weir and Lock 1

Are estimates being made of loss of water to seepage through the cracked levee banks above the weir And will this seepage appear in the Lake

Will it be the case that water will stop flowing over Lock 1 at some stage to facilitate the construction of the weir

Adrian Pederick MP asked who wrote the draft EIS

Member referred to a rumour that irrigation will cease with weir construction

Can you be clear about the cost of the temporary weir if built

Is the cost of the causeway included

Where will the SA Government get the money to construct the weir (Some anxiety that it would be CLLMM money (Comment wasn t c learly aud ib le)

What is the likelihood of a virtual weir

There was a question (inaudible) about the height of the weir above sea level (Was it about the adequacy of the height to secure water supply if the Lake levels rose)

How much of the weir would be removed when decommissioned

Comment about the complexities of start times and the apparent late start to protect water supply

Update on other matters Peter Croft Closing date for submissions on the draft EIS on proposed temporary weir

Promotion of availability of all documents and information sources

The Goolwa Channel referral lodgement is imminent

Actions Application for projects under $120000 April 10

Approvals process for lime-stoning the first flush coming down the Finniss and Currency Creek

Seeding and bioremediation workshop held Tuesday 31 March

Rural Solutions developing a bioremediation plan around both Lakes

Supplementary EIS for the temporary weir near Pomanda Island -108-

Appendix IV Organisations that participated in Community Information Sessions

The Advertiser

Department for Environment and Heritage

University of South Australia

La Trobe University Centre for Sustainable Regional Communities

Native Food

Investigator College

River Lakes and Coorong Action Group Inc

South Australia Murray Darling Basin Natural Resources Management Board

River Murray Boat Owners Association

River Murray Museum of River History

Department for Sustainability and Environment

Wellington Lodge Pty Ltd

Ranges to River NRM Group

Food and Beverage Australia Ltd

Narrung Wetland Monitoring Group

BMT-WBM (Engineering and environmental consultants)

River Lakes and Coorong Action Group

All Land and Livestock

Clayton Bay Community Association

Finniss Catchment Group

Southern Alexandrina Business Association Inc

Coorong District Council

Narrung Dairy Farmers

Southern Fishermen s Assoc ia tion

Clayton Bay Foreshore Committee

SA Water Corporation

Fleurieu Regional Development

Alexandrina Council

University of Adelaide

Supplementary EIS for the temporary weir near Pomanda Island -109-

Appendix V Participants and notes from Community

Information Sessions

Community Information Sessions Agenda

Proposed Locations Meningie Murray Bridge Goolwa Clayton Bay Facilitator Lindsay Holmes (Meeting Success) Session Length 25 hours

Timing Task Responsible person

5 min Welcome and Ground Rules Lindsay Holmes

Welcome to Country

5 min Explain purpose of Session Peter Croft

5 min Introduce specialist panel Lindsay Holmes Explain session agenda and process

10 min Water Presentation Hon Dean Brown

25 min EIS Introduction presentation Russell Seaman

5 Min How to respond to the EIS Peter Lumb

5 min Explain small group purpose Lindsay Holmes

15 min Tea Break

30 min Work in small groups Lindsay Holmes Groups identify and prioritise questions for resourc e peop le

40 min Resource people answer questions Chaired Lindsay Holmes

5 min Meeting thanks and closure Peter Croft

Supplementary EIS for the temporary weir near Pomanda Island -110-

Meningie Community Information Session

Date Tuesday 24th March 2009 300pm 530pm Location Meningie Bowling Club

Questions asked of the specialist panel listed by category

Lake Albert Is pumping going to stop or continue at Lake Albert

In worst case scenario what will be done about Lake Albert if it runs dry

Assuming a weir will be built what actions will be taken to maintain Lake Albert

What is the future for Lake Albert

Why isn t Lake Albert written up more in the d ra ft EIS

River flows Why are upstream tributaries not included in the flow data considering it is the Murray-Darling Basin system (The information is then misleading for Min Garrett)

Inflow figures Are these figures based on whole basin or just the Murray River catchment

Is there information on how much water is coming in to the basin catchment (not just inflows)

Is 350GL guaranteed to come over the weir per annum Is that happening now

How will the weir pool level be maintained ie Where will the water come from Does this relate to water buy back

Why c an t some of the wa ter held on fa rm dams etc be released and peop le use a little less water to maintain levels (federally)

What measures are being considered to improve sharing and saving water throughout the Basin

How much area is considered Murray-Darling catchment

put in place to use alternative storagemake Adelaide less dependent on the Murray

Ramsar How will the Ramsar convention be respected

Australia signed the Japan-Australia migratory birds agreement (also with China) re wetlands of international significance How will the weir effect this agreement

Is government looking at taking control re Ramsar site

Wildlife What happens if there is a fish kill in Lake Albert

Will the weir affect cod numbers and is there a plan to recover this species

Has the magnitude of a fish kill been considered ifwhen the weir is built Consider Lake Albert amp Lake Alexandrina separately

What will happen to the fish turtles etc if salinity increases

Acid Sulfate Soils (ASS) Why hasn t the government looked a t other op tions for remed ia tion for ASS

What is the long term planmedium term plan for Lake Albert and the ASS issue

What is the gas that comes out of the mud in Lake Alexandrina (Three cases of dizziness when exposed to this)

What can be taken out of Menindee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Alternative catchments Adelaide is now taking 90 water from Murray What is being

Wha t c an be ta ken out of Menind ee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Supplementary EIS for the temporary weir near Pomanda Island -111-

Salinity issues What mitigation strategies are in place to mitigate hyper-salination in the Lakes

Salt water sits beneath fresh water How will the salt water flow over the weir

If the weir is pumped is the pumped-out water saltier

Does the salt water layer

How are they going to flush the salts that accumulate in the weir pool

What is the evaporation rate per annum at the present time considering the Lake levels today Is it still 800GL

Rainfall Was there rainfall measured over Lake Alexandrina in winter last year (No rainfall measured by farmers)

Why doesn t the d ra ft EIS mention Lake ra in

Will decreasing the surface area of water in the Lakes reduce rainfall over the Adelaide catchment increasing the strain of Adelaide Hills reservoirs

Proposed temporary weir impacts How is the weir going to be removed

What is the trigger point for the weir decommissioning

Given the modelling and g iven the government dec ides to build the weir why isn t a lock considered Would allow navigationfish passageflow management

Why is there no facility for navigation through the weir

Why a re there no fishways Why isn t it nec essa ry to have fishways

Is the base of the weir stable enough to stop slippage of the structure

How will they monitor the silt on the downside of the weir and particularly with ASS

Will time to fill the weir pool be more than three months (based on worst-case scenario) Will some leak out under the levee banks

When would construction start

What would it cost to move the intake points above Lock 1

Will the weir help mitigate acid soils in the Lower Lakes

Why does the EIS not address much between Lock 1 and the weir in relation to damage of embankmentshabitat above the weir

How can they guarantee that removal of the weir will allow things to go back to the way they were

Social and economic impacts What consideration has been given to sustaining cultural flows for Indigenous people

Are the social impacts of building the weir and low flows being considered in the decision to build the weir

What provision has been made in the EIS for socio-economic impact factors

Seawater If seawater is let in how far into the groundwater will the seawater penetrate What will be the impact on the level of groundwater

How will the weir affect the decision to allow seawater into the Lakes

How does the weir link with the seawater incursion and will it need another EIS

Politics and Government When is the Murray-Darling Basin Authority going to get up and running (currently only a CEO and Chairman) If it were in place then politics will be in order ()

There have been a lot off government bodies set up over the last few years What has their role been and what is their role now

What is the government doing to educate the public

Supplementary EIS for the temporary weir near Pomanda Island -112-

Miscellaneous Have the trigger points been addressed

Will the weir guarantee water for stock from existing pipelines

Will the weir cause impact on the positive impact that wind seiching plays in the system

Do submissions all go together to the Commonwealth

What will happen when a flood occurs at the Narrung pumping station Will it be removed and the channel opened

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 2 fishways) 14 River flowsallocations 11 Salinity issues 6 Lake Albert 5 Wildlife (Fishturtles) 4 Social and economic impacts (one Indigenous) 3 Ramsar 3 Sea water incursion 3 PoliticsGovernment 3 Acid Sulphate Soils 3 Rainfall (Lake rain) 3 Miscellaneous 4

Supplementary EIS for the temporary weir near Pomanda Island -113-

Murray Bridge Community Information Session

Date Tuesday 24th March 2009 1000am 1230pm Location Uniting Church Worship Hall

Questions asked of the specialist panel listed by category

Acid Sulfate Soils (ASS)

What effect will the weir have on the current situation of Acid Sulfate upstream given that the weir will not be constructed within the next three years

How extensive are the potential Acid Sulfate areas

How deep does the lake need to be to prevent ASS

What is the plan to deal with acidification post weir

What is worse Seawater or lake acidification

Salinity issues How will salt get back into the Lakes

What measures will be taken to address salt building up behind the weir (upstream)

How can you handle the salt (that will come down the river) How will it be managed

Have you considered installing pipesregulators to manage salinity at the base of the weir

Wildlife What evidence do we have that the birds will return after construction

Have we calculated impact of extinctions

River flows allocations Is there a lot of water available for sale

Why hasn t temporary wa ter been purc hased

What about buying water as an alternative to a weir

If a weir is built will there be more water allocations in SA

If the weir goes forward who will receive the water that will be saved from less evaporation Will the allocation be more

18 wa ter a lloc a tion Universa l na tiona l standard set a lloc a tion Why isn t there an agreed allocation standard to all usersirrigated Why not a special rule to override current allocation agreements

Has there been an audit on un-metered bores in the Basin and what action is being taken

How much have extractions increased and what were base extractions

Developed methods to estimate inflows model for calculating extractions How much water is prevented from entering the system Where do extractions go Why is there no graph for extractions for entire systems How is the flow calculated Where is this information available

What is the definition of inflows

Where is the water coming from to maintain the level of the weir pool and the river level

What are the differences in water quality in the channel with or without a weir How serious is the situation What about the use of water upstream Over-allocation

Proposed temporary weir Has consideration been given to the weir at Wellington having a fishway

Will the weir pool inundate the wetlands upstream

How will the water and salt discharge over the weir into Lake Alexandrina Spillway Gate

How will the process prevent the build up of algal blooms and nutrients behind the weir

Supplementary EIS for the temporary weir near Pomanda Island -114-

What will build up behind the weir (eg iron etc)

Water hitting the weir what is going to happen

Why a temporary weir Why remove it and rebuild it

When the weir is deconstructed what happens to debris rocks etc

What will the volume of seepage be What are the implications

Will construction of the weir begin in June

What are the trigger points for removal of the weir

Why is a permanent weir not being considered CSIRO says conditions will get worse

How are they going to remove the weir

How is the level going to be maintained as weir is expected to sink in sediment

Why is the weir being build to 01m above sea level

If and when the weir is removed can it be reassembled quickly

How long will the weir take to build

Were other options considered for construction of the weir and what were they

Have you found a solution to the weir foundation (ie mud and construction of the weir at Pomanda Point)

What is the trigger to open the weir

Are the triggers to demolish the weir strict

Why haven t they got sta rted on build ing the weir

Lock Have investigations been made to have a permanent weir with lock with fishway and means of allowing the bottom salt water to be discharged

Has there been consideration of a lock with the weir (or a bypass channel)

Why have we not considered a lock

Why consider a temporary weir when a permanent weir could be constructed with a lock to maintain a navigable river system

Politics government and planning What about the constitutional right that the river be navigable from top to mouth

When will the Murray-Darling be run federally Not by the states

Why not hand over water management to the Commonwealth

When will the government declare this a disaster

What grantsassistance will be provided (eg tourism) Irrigators get support Why not others Industry assistance

Why is the weir being considered as part of a piecemeal approach What about a long-term plan

Is the weir part of the broader management of the Lakes and Murray Wha t s the b igger picture and where does it fit

Why is there not an integrated plan including Goolwa Channel regulators rather than doing it piece by piece

What is the present status of the Goolwa Channel projects

Is there a trigger for putting in a desalination plant at Tailem Bend

How will the remediation be managed and the long-term effect of the silt build-up be dealt with

Will building of the weir delay the equitable distribution of water in relation to other states

If the weir is built what are the triggers for letting in seawater to the Lakes

Riverbanks What measures have been taken to ensure the levy banks do not collapse with the higher river levels

What proactive approach will be taken to care for river banks

Ifwhen we build the weir what about the raising of the head River bank decline

Supplementary EIS for the temporary weir near Pomanda Island -115-

Has there been any consideration given to realigning the Lake Alexandrina shoreline Reduce evaporation in future

Pumping stations

Cost of moving pump stations above Lock 1

Chapter 4 Relocation of pumping stations above Lock 1 (needs clarification)

If they put in the weir will they continue to pump water to Lake Albert

Society and economy What is the impact on peoplecommunities

Why is economic impact not dealt with in the EIS

Miscellaneous What s the likelihood of worst-case modelling becoming irrelevant Is it likely that worst-case modelling is over predicted

Numbers of questionscomments on each topic indicative

Proposed Temporary Weir (Locks 4) 27

River flowsallocations 13

Politics Government (2 Goolwa channel) 13

Acid Sulphate Soils 5

Riverbanks 4

Lock 4

Pumping stations 3

Society and Economy 2

Wildlife 2

Miscellaneous 1

Supplementary EIS for the temporary weir near Pomanda Island -116-

Goolwa Community Information Session

Date Friday 27th March 2009 10000am 1230pm

Location Centenary Hall

Questions asked by the specialist panel listed by category

Wetlands Milang wetlands identified as number one natural resource by Adelaide University It has now been disconnected for two years Why is it not mentioned in the EIS

Will the wetlands between Lock 1 and the weir be filled How much water is needed to fill these wetlands Will the filling of wetlands result in an increase in acid

Bioremediation Are they considering bioremediation rather than building a weir

Impac t of g rasses tha t a re na tura lly g rowing on beac hes of the Lake

River flowsallocations What s being done about the wa ter supp ly

How much inflow into the River Murray in SA comes from SA compared with inflow across the VicNSW border (see figure 0-2 of the Exec Summary)

What flows would be necessary past Wellington to support a virtual weir at AHDs of -15 shy2 -25m

Will the weir be able to withstand a significant flood

How will water flow over the weir and into the Lower Lakes or will it flow through a gate underneath

How much water bypasses the weir if it is built

What will happen to the temporary weir if there is a flood Will it get washed away

Has the sc enario of three months without flow into the Lakes to fill the weir pool been allowed for in determining the trigger date of Jan 2010

Is it possible to have a shorter period where there is no flow over the weir but take a longer time to fill the weir pool

Has the government considered buying water to maintain the annual 350GL to the Lower Lakes

If the Lower Lakes are without water for three months during construction will the government purchase additional water to factor this in

Why doesn t the environment get a wa ter a lloc a tion like every other user

Why does Adelaide not have underground storage or other measures to alleviate the need for taking water from the River and hence for need of a weir

What difference would it make if we moved down to critical human needs rather than gardens and swimming pools

What is the impact of the various private and public water storages when comparing the Federation Drought and the current drought

What proportion of the Living Murray water agreement will reach the Lower Lakes (of the 500GL from 30 June 2009)

Ramsar What is the potential threat to the Ramsar status of the wetlands

Has the Wellington weir been put to Ramsar

Could building the weir lead to international action and delisting

Wildlife (Four questions on fish passage a re listed under Proposed temporary weir )

How do we consider the impact on species which are not listed under the EPBC Act These species are part of the ecosystem and food chain

Has the EIS looked at all species that will be affected eg snakes kangaroos and others

Supplementary EIS for the temporary weir near Pomanda Island -117-

Will the weir reduce flows significantly downstream and continue to adversely affect wildlife already in distress

There will be a spike in salinity in the Lake after disconnection which may lead to fish kill in certain species eg carp Fish kill will give high ammonia and low dissolved oxygen what is the impact on the other species as a result of this

Acid Sulfate Soils (ASS) What is proposed to address Acid Sulfate Soils

Acidification problem on land There are options to cover sand other than freshwater

Is the lake bed soil at Pomanda sulfuric

What does the Department anticipate will be the result of disturbing and replacing thousands of cubic metres of sulfuric soil above and below the weir

What is the problem with ASS What does it do that is so bad

When acid soils dry out does they still retain their acidity What happens when they turn to dust

What problems have Acid Sulfate Soils caused so far Why do we need to be concerned about this problem

Wha t is the government s stra tegy to c ombat the ac id and heavy metals entering the river as a result of varying levels caused by wind seiching

Salinity issues Why after Lake Alexandrina has been sucked dry should the Lake have to put up with the salt from behind the weir therefore making the Lake worse with a high salt content

What happens to the salt which normally comes down the River and flushes to the sea via the Murray Mouth

Will the weir result in a highly saline weir pool

How will the accumulated salts be flushed at the weir

How quickly can the rocks be removed if it becomes apparent that the weir pool salinity levels have unexpectedly risen to unacceptable levels If not quick enough what is the contingency plan

What is happening to water above the weir Will salinity affect Adelaide water supply

Where are the salt and other contaminants going to go once the weir is constructed

What consideration has been given to the massive mobilisation of salt that would follow heavy inflows

Has the government considered increased salinity building up behind the weir

If the weir has a long life will salinity keep rising

Won t sa lt and toxin c onc entra tion inc rease upstream of the weir

What science is there that demonstrates the mixing of saline waters in the weir pool immediately above Wellington to be kept to acceptable levels while the weir is in operation Is there any precedent of a similar scale for this mixing scale

Proposed temporary weir impacts If the weir is there for a long time what are the groundwater impacts

Why are there far more truckloads of material being put into building the weir as opposed to taking it out

What are the implications of taking the weir down

Impact of increased vehicle access on Lakes beaches on Sulfate soils dust and wildlife

How do you intend to remove the weir given it is a massive structure

How do you intend to remove the weir given it is a temporary structure

What part of the structure and sub-structure will remain after decommissioning

What are the consequences if the weir fails to withstand a flood

If the temporary weir is engaged for three years but is required for longer what would it take to remain operable for as long as it is needed

Wha t will happen a fter the end of the three years of the weir s life

Is twin lakes concept a possibility Has it been sufficiently considered

Supplementary EIS for the temporary weir near Pomanda Island -118-

What is the effect of the weir on the water ecology in the channel (downstream) Eg water rats crustaceans birds beetles etc

Is a fishway being incorporated into the design of the weir

During the period of disconnection can a tunnel be built through the weir to allow fish passage

Will the temporary weir include provision for a fish ladder

What provisions are there in the weir construction for fish ladders and other access for boating

What is the level of the weir spillway and the level of the weir pool behind it

What is the level of the weir itself

Is it possible that the temporary weir will need to be replaced by a barrage if the drought continues

Why not build a permanent weirlock rather than building a temporary weir that may need to be re-built in a number of years

How long do you expect the weir to be in place

Social and economic impacts Where do we take our concerns about economic and social impacts of the situation

Politics and government What are the budget figures of water (both temporary and permanent) How much do they expect to pay per GL

The weir won t a llow boa t tra ffic Is this aga inst the c onstitution

Is it legal to build a weir which will hold the River flow to the detriment of the Riparian rights users downstream

Is it true that Commonwealth or State Laws require the River to remain navigable

How can I use this process to promote a change to the system of governance (States sharingallocations)

How can this consultation process address over-allocation

What is being done about over-allocation

Over-allocation in other states is at the root of the problem When will governments apply sufficient pressure to deal with the shortage of water coming over the border

What is going to happen with the issue of over-allocation and theft of water upstream

Would it be better to spend money on infrastructure instead of buying back water

We need a 50 year plan to remove all man-made infrastructure in the Murray

Why doesn t the federa l government focus on new sources of water being made available For example new engineering securing water from Queensland and delivering it to northern point of Murray-Darling

Is the Murray-Darling Basin Agreement still a legal document Is it still in force

What is the federa l Minister s responsib ility to the c ommunity c onsulta tion p roc ess (Specifically relating to issues submitted to state and if they disagree with the citizen who adjudicates)

What coordination is there between different government departments

Miscellaneous Why was A Fresh Water History g iven out today To influenc e thinking

How long under the worst case scenarios will the water contained by the temporary weir remain suitable for Adelaide use

What would be the cost of shifting the uptakes above Blanchetown

How are they measuring water quality in Lake Alexandrina What about DO and temperature

What role is the rising water temperature having on the aquatic species and water quality as a whole

Will the water beyond the weir cease to be aerated as a result of the weir

How much has wind seiching been considered in the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -119-

Why has there been no consultation with community in Milang Why have they been neglected

Wha t does spend mean in rea l wa ter terms We need a bold idea

If the weir is built will the blocking banks at Clayton Finniss and Currency Creek still be needed

If the blocking banks go ahead with the weir still go ahead

If the drought continues and the weir goes in and barrages are left closed what will happen to the Lakes and Coorong

Trigger Points What will be the indication to dismantle the weir

What is defined as temporary and what are the decommissioning triggers for the weir

Lake Albert What is the future of Lake Albert

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 4 on fish-ways) 21

River flowsallocations 16

PoliticsGovernment 15

Miscellaneous (including 5 on water quality) 12

Salinity issues 12

Acid Sulfate Soils 8

Wild-life (Fishturtles) 4

Ramsar 3

Wetlands 2

Bioremediation 2

Social and economic impacts 1

Lake Albert 1

Supplementary EIS for the temporary weir near Pomanda Island -120-

Clayton Community Information Session

Date Friday 27th March 2009 400pm 630pm Location Clayton Community Hall

Questions asked of the specialist panel listed by category

Regulators Why is a regulator at Clayton for pumping to the Goolwa Channel considered above letting seawater in to it

If the Clayton Regulator is built will it protect the water quality at the pumping stations (without building the weir)

How does the function of the Pomanda Island weir relate to the functions of regulators proposed for Currency and Finniss Creeks and Clayton

Is the weir going ahead as well as regulators If so why are both necessary

With the proposed regulators will the inflows of water to the next section be regulated from the bottom of the weir or from the top ie What will happen to accumulated salt behind the weir

Why is information on the regulators only in the papers and not mentioned in this forum

Lake Albert Should the weir at Pomanda Island proceed what are the ramifications for the future of Lake Albert

River flowsallocations Has blocking off the wetlands between the weir and Lock 1 to allow water when available to run into Lake Alexandrina been considered

If the weir is installed is the initial idea to pump water into the weir pool immediately or to leave it to whatever comes in

If the water extraction cap in other states is applied in 2012 will we get any water flow to SA

What are restrictions in other States on water use

What if anything happens in other states in allocating water as NSW has no meters

How is water removed from the River tracked

How is surface diversion tracked and measured

Has there been an assessment of all water storages available to the MDB

Do we believe SA will actually be able to get more freshwater from the larger eastern states as they are also growing

Would stormwater redirection help the Murray

What is stopping us from buying more water

How can the process of buying water be sped up

Ramsar

of the Murray-Darling Basin and River mouth is of paramount importance

Wildlife Ecology of LakeRiver studies on cod too late They have been in scarce supply for a long time

Given that the Yarra Pygmy perch is in other river systems why is it included

No cod in the Lower Lakes for decades Why are they included in the draft EIS

Is a base line study into Bell Frogs too late

Has anyone looked at the effect of the weir and its repercussion on micro-invertebrates etc on whic h a ll the Lakes residents (human anima l and p lant) depend

The Coorong and La kes site is reg istered a s an interna tiona l Ramsar wetla nd Isn t the Prime Minister responsib le for p rotec ting this a rea Isn t this the b ottom line The ec ology

Supplementary EIS for the temporary weir near Pomanda Island -121-

What effect will the proposed seawater introduction have on the Lower Lakes freshwater species

Why are marine species that were prevalent before the barrages not mentioned in the EIS

What study has been done on non-river marine species threatened by not allowing seawater in as nature would have done under these circumstances

How will species not listed in the EPBC Act be addressed

Acid Sulfate Soils What is the risk of potential ASS becoming actual ASS

The Executive Summary of the draft EIS alerts to the danger of acidification of the weir pool above the weir when wetlands are flooded again Is it intended to close off the entrances to them Has there been any decision yet about exactly what the effect of covering ASS with water (salt or fresh) will be

What will happen to the wetlands above the weir when they are refilled with water Is there a danger of the water being contaminated due to acidic soils

Due to ASS and extraction for urban use it appears that the weir must be in place by mid-January 2010 Is that the case

If the weir is installed is the intention to block off back waters and lagoons below Blanchetown If so are these subject to ASS

Bioremediation Is there something groupsindividuals can do to help with bioremediation projects etc How can we be involved

Will revegetating problem areas with dust fix the problem

Salinity issues What are the impacts of salt water within CurrencyFinniss Rivers

In the introduction it was stated that salt levels in the Goolwa Channel are 20000 ppm (parts per million) I believe they are 30000 ppm Is your information up to date

What will happen to salt accumulation when the proposed temporary weir is removed

Will the water coming over the weir spillway bring the salt with it or will salt build up at deeper levels

How will the salt coming past Pomanda Island be managed with a complete blockage that has a low level spillway in shallow water east of the main River channel

Does the weir prevent salts from being flushed out to sea (ie they will be built up behind the weir)

Rainfall Has consideration been given to constructing a barrage behind the temporary weir given continuing long-term low average rain fall

Proposed temporary weir Given the EIS indicates a 3 year lifespan of the weir what is the situation if the objectives of its installation are not met

Given the criteria for removal why is the design life for 3 years only

How permanent is this weir

If a weir is built upon removal will it all be removed or will it be a narrower channel

Figure 0-4 (lake level and the -15m red line) Is this the trigger for both the start of weir building and the introduction of seawater into the Lower Lakes

In the draft EIS statement there was no mention of effect on commercial social recreational or irrigation impacts Have these been considered

What is the impact of not constructing the weir

If the weir fails to guarantee water supply to Adelaide will it be removed

How long is the temporary weir to be in place

Why is the weir going to be temporary

Supplementary EIS for the temporary weir near Pomanda Island -122-

Has any consideration been given to building a barrage not a weir at Pomanda Point and removal of existing barrages below

Why not build a permanent structure which will service us for the next 100 years

Social and economic impacts Does the EPBC Act consider social and economic issues that the weir will impact on

How is this affecting tourism throughout the Lakes

How are the social and economic impacts being understood

Seawater If we let seawater in would it be flushed out again Would it return to fresh water

Is seawater into the Lakes seriously being considered What are the strong arguments against seawater as a sustainable option for the Lakes

Have we looked at letting seawater in at similar locations in Australia eg Mantra And the effects

Are Professor Gells results for c ore sampling about historic a l seawa ter being c onsidered (in letting seawater in)

Have any studies been conducted to consider the impact of salt water entering this Lake What were the outcomes of it

What prevents the weir height to be increased to say 07AHD to permit ingress of seawater to allow sufficient depth (~05AHD) and the operation of boat ramps jetties sailing clubs and safe navigation within the Lakes

Has a desalination plant option been considered for Beach 19 Lake Albert and Cantara (Replacement of fresh water from evaporation etc)

Politics and government Why has it been left so long for the urgency of this to be recognised and acted on

If the Federal government takes control of the MDB will that make this EIS invalid

Will the d ra ft EIS need to be reviewed due to the Government s rec ent dec isions regarding the blocking banks at Finniss amp Current Creeks

How does the EPBC Act deal with long-term management of the Lower Lakes

As it impacts on matters of NES does a state territory or industry need to get approval under the EPBC Act to get current or future water extractions

Why isn t the Commonwea lth ac ting to restric t a lloc a tions more urgently

Does the construction of the weir contravene Section 100 of the Australian Constitution that gives States or people rights to use water for conservation or irrigation

Due to state environmental assessments being overridden by emergency powers how a re issues suc h as wa ter a ffec ting ac tivities and wetland management p lans add ressed in this process

Miscellaneous Why is the Murray called a river when it is a series of pools

Has the idea of an island in the middle with dredging around it been considered for Lake Alexandrina

Why were 1982 figures used when 2006 was the worst case (until now)

Can we have hope that we will get to a sustainable system and that irrigation can provide Australian food

Has sea level rise been a consideration in the draft EIS and how may this impact on the weir if built

Were there EIS studies on any of the other 4000 barriers across the Murray

Has study of other precedence areas such as Mandura been done

Would it help if we had dry toilets

What level will the Lake be allowed to come up to once the weir is in place How far below the weir will the lake level be

Why have they decided on a pool of 01AHD given that previous pool level of the whole area was at +05 to 06 (Given that top of tide is +06m)

Supplementary EIS for the temporary weir near Pomanda Island -123-

How will water restrictions apply to small farmers on the river

Why wasn t Finniss Angas Bremer etc in MDB c a tc hment a rea

Why hasn t more been done about effic ienc y improvements in wa ter use by loc a ls as well as industry and people in Adelaide and beyond

If we all collected domestic water from properties etc would it negatively impact the Murray

Why isn t Myponga used to supp ly wa ter to the Fleurieu

Why has no impact study on underground water in the Currency Finniss and lower south east region been done

Has there been a comprehensive study of ground water and surface water into the area surrounding Lake Alexandrina

Why is there no navigation pass in the weir or no provision for one in the future

What will happen to Lake Alexandrina if water is pumped out into the Goolwa channel

Once the Lake is dry how will the Clayton channel then be refilled

Trigger Points Where are the trigger points for monitoring salinity and calcium carbonates sites located

Once we reach a certain trigger level at a monitoring site is the weir removed immediately or does it have to sit at a point for a certain amount of time

Will the weir be deconstructed if one trigger point is reached or all trigger points

Wha t is the trigger point for the guaranteed dec ommissioning of the weir

What are the triggers for removing the temporary weir

If the main a im of the weir is p reserva tion of Adela ide s water supp ly why is the level of water in the Lakes the trigger point for construction of the weir rather than the ability to extract water for Adelaide Is the real reason to do with Acid Sulfate in the Lakes

What is being done now to speed up the process of water allocation

Respiratory problems Low water levels are increasing the dust levels How quickly will this be covered to tackle health issues such as respiratory problems

Are health effects of the dust being surveyed What evidence is there of this

Has research been done regarding increases in respiratory problems

Supplementary EIS for the temporary weir near Pomanda Island -124-

Numbers of questionscomments on each topic indicative

Miscellaneous 20

Weir construction impacts 12

River flowsallocations 12

Wildlife 9

PoliticsGovernment 8

Sea water 7

Trigger Points 7

Regulators 6

Salinity 6

Acid Sulfate Soils 5

Social and economic impacts 3

Respiratory problemshealth 3

Lake Albert 1

Ramsar 1

Consolidated list of question topics from all Community Information Sessions

River flowsallocations 50

Weir construction impacts 47

Politics amp Government 39

Miscellaneous 37

Proposed Temporary Weir 27

Salinity issues 24

Acid Sulfate Soils 21

Wildlife 19

Seawater 10

Social and economic impacts 9

Lake Albert 7

Ramsar 7

Regulators 6

Trigger Points 7

Lock 4

Riverbanks 4

Pumping stations 3

Rainfall (Lake rain) 3

Respiratory problemshealth 3

Wetlands 2

Bioremediation 2

Supplementary EIS for the temporary weir near Pomanda Island -125-

Graph of consolidated question topics from all Community Information Sessions

All CIS Questions Summary

0

10

20

30

40

50

60

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AcidSu

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Soils

Wild

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Sea

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Socia

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Lake

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Ramsa

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Regul

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Supplementary EIS for the temporary weir near Pomanda Island -126-

Appendix VI Advertising copy used in the consultation process

Date Thurs 12th March 2009

The Australian

The Victor Harbor Times

The Advertiser

The Southern Argus

The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -127-

Supplementary EIS for the temporary weir near Pomanda Island -128-

Date Thurs 12th March 2009

The Australian The Victor Harbor Times

The Advertiser The Southern Argus The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -129-

Supplementary EIS for the temporary weir near Pomanda Island -130-

Public Release Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island Email Update Sent 12th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -131-

Public Release Amended Draft Environmental Impact Statement for the

proposed temporary weir near Pomanda Island Email Update Sent 17th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -132-

Public Release Reminder re lodging submissions - Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 1st April 2009

Supplementary EIS for the temporary weir near Pomanda Island -133-

Public Release Submissions due 9 April 2009 Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 6th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -134-

Public Release Consultation period for draft EIS closes Draft Environment

Impact Statement for the proposed temporary weir near Pomanda Island

Email Update Sent 15th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -135-

CD Pack Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island

Supplementary EIS for the temporary weir near Pomanda Island -136-

Executive Summary

Supplementary EIS for the temporary weir near Pomanda Island -137-

Distribution of draft EIS Executive Summaries and CDs

Organisation Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Alexandrina Council 2 2 5 45 50 Coomandook Community Library

1 0 20 20 1

Coorong District Council 2 2 5 45 50 DEWHA library 2 2 5 5 Goolwa Public Library 1 50 50 1 Meningie Community Library 1 30 30 1 Milang Old Schoolhouse Community Centre

1 50 50

Mount Barker Community Library

1 20 20 1

Mt Barker Natural Resource Centre Mt Compass Library

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1 Murray Bridge Library 1 Murray Bridge Natural Resource Centre

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Rural City of Murray Bridge 2 1 National Library of Australia 2 Port Elliot Library 1 State Library Adelaide 2 1 Strathalbyn Community Library 1 Strathalbyn Council Office 2 Strathalbyn Natural Resource Centre Tailem Bend Community Library Tailem Bend Office of Coorong District Council Tintinara amp Coonalpyn Community Library Tintinara Office of Coorong District Council Victor Harbor Natural Resource Centre

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Victor Harbor Public Library 1 30 30 1 Willunga Environment Centre 1 30 30 CLLMM Project Team 2 2 40 20 Mapland (DEH) 2 2 5 45 50 Meningie Community Information Session

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Murray Bridge Community Information Session

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Clayton Community Information Session

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Goolwa Community Information Session

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Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 SA Government Ministers Hon Mike Rann MP Premier Minister for Economic Development Minister for

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Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

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Sustainability and Climate Change Hon Paul Holloway MLC Minister for Urban Development and Planning

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Hon Jay Weatherill MP Minister for Environment and Conservation

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Hon Paul Caica MP Minister for Agriculture Food and Fisheries Minister for Regional Development

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Hon Gail Gago MLC Minister for StateLocal Government Relations Hon M OBrien MP Minister for Employment Training and Further Education Hon T Koutsantonis MP Minister for Correctional Services Hon J Rankine MP Minister for Families and Communities Hon M Atkinson Attorney-General Hon M Wright MP Minister for Police Hon John Hill MP Minister for Health

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Hon Kevin Foley MP Treasurer Minister for FederalState Relations

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Hon Jane Lomax-Smith MP Minister for Tourism

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Hon Patrick Conlon MP Minister for Transport Energy and Infrastructure

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Hon Karlene Maywald MP Minister for the River Murray Minister for Water Security

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Shadow Ministers Martin Hamilton-Smith MP 1 2 2 Adrian Pederick MP 1 2 2 Mitch Williams MP 1 2 2 Aust Govt Ministers Minister Penny Wong 1 2 2 Minister Peter Garret 1 2 2 SA Parliamentarians Parliamentary Leader SA Greens - Mark Parnell

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Parliamentary Leader SA Democrats - Hon Sandra Kanck MLC

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SA Parliamentary Library 1 1 Chief Exec DEH - Allan Holmes 1 Chief Exec EPA - Helen Fulcher 1

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2Chief Exec DWLBC - Scott Ashby Chief Exec DTED - Brian

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Supplementary EIS for the temporary weir near Pomanda Island -139-

Organisation

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Appendices CD Exec Sum

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Cunningham Chief Exec DTEI - Jim Hallion Chief Exec SA Water - Anne Howe Chief Exec DPC - Chris Eccles 1 2 2 Chief Exec DPLG - Ian Nightingale

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Chief Exec PIRSA - Geoff Knight

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Chief Exec DTF Rob Freeman 1 2 2 Dr Tony Sherbon 1 2 2 Mr Dean Brown 1 1 Mr Simon Stretton 1 2 2 Mr Sean Berg 1 2 2 CLLMM Steering Cttee 8 8 8 CLLMM Project board 4 4 4 Conservation Council of SA -Julie Pettett

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Spares 2 2 500 500 92 15 25 2410 2012 11

Hard Copy Append CD Exec Sum CD Ordered 140 20 0 2500 2000

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Web content

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Fact Sheet

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Appendix VII Media generated by the consultation process

Radio 12012009 410 PM ABC North amp West SA (Port Pirie) Late Afternoons - Kieran Weir Interviewees Michael Pengilly Liberal Member for Finniss Duration 10

18 01 2009 850 AM 5AA (Adela ide) Mic hael Keelan s Weekend - Michael Keelan Neil Humphrys amp June Taylor Interviewees Simon Birmingham South Australian Liberal Senator Duration 710

8012009 954 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 025

Newsreader News Director Ms Monique Crichton Duration 014

8012009 603 AM Triple M (Adelaide) 0600 News

8012009 1212 PM 5AA (Adelaide) Mornings - Mike Smithson Interviewees caller Jeff Mike Rann SA Premier Duration 1133

8012009 731 PM 5AA (Adelaide) Matthew Pantelis - Jeff Burzacott Interviewees Caller Robyn Duration 1605

8012009 1127 AM ABC 891 Adelaide (Adelaide) The Soapbox - Sonya Feldhoff Interviewees Michael Pengilly Member for Finniss Duration 328

8012009 1212 PM ABC North amp West SA ABC North amp West SA (Port Pirie) SA Country Hour -Annabelle Homer Interviewees Senator Sarah Hanson-Young Australian Greens SA Duration 415

8012009 100 PM ABC 891 Adelaide (Adelaide) 1300 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Martin Hamilton-Smith SA Opposition leader Mike Rann SA Premier Duration 119

8012009 600 PM ABC 891 Adelaide (Adelaide) 1800 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Duration 033

9012009 632 AM ABC 891 Adelaide (Adelaide) 0630 News - Newsreader Interviewees Arlene Buchan Australian Conservation Foundation (ACF) Duration 036

9012009 704 AM ABC 891 Adelaide (Adelaide) 0700 News - Newsreader Interviewees Arlene Buchan ACF Duration 050

3022009 1003 AM ABC 891 Adelaide (Adelaide) 1000 News - Newsreader Interviewees Karlene Maywald SA Minister for the River Murray Duration 046

12032009 830 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 017

12032009 521 PM ABC North amp West SA (Port Pirie) Late Afternoons - Annette Marner Interviewees Caller Tom Karlene Maywald Minister for Water Security

Supplementary EIS for the temporary weir near Pomanda Island -146-

Duration 847

13032009 809 AM 5AA (Adelaide) Pilkington amp Conlon - Tony Pilkington amp Keith Conlon Interviewees Karlene Maywald SA Minister for the River Murray and Water Security Duration 628

13032009 840 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan - live from Goolwa Interviewees Prof Diane Bell Resident and former Federal independent candidate for the Seat of Mayo Duration 239

13032009 910 AM 5AA (Adelaide) Mornings - Mike Smithson Interviewees Senator Sarah Hanson-Young Australian Greens Party Duration 612

13032009 1024 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan Interviewees Clem Mason Lower Lakes and Coorong Infrastructure Committee Lesley Fisher Lower Lakes and Coorong Infrastructure Committee Duration 923

13032009 1105 AM ABC 891 Adelaide (Adelaide) The Soapbox - Matthew Abraham and David Bevan live at the Goolwa Sailing Club Interviewees Dean Brown Premiers Special Drought Advisor Robyn McLeod SA Independent Water Commissioner Duration 603

31032009 835 AM ABC North amp West SA (Port Pirie) Morning Show - Kieran Weir Interviewees Dr Jochen Kaempf Oceanographer Senior Lecturer Flinders Uni Duration 1136

Television 8012009 600 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Martin Hamilton-Smith SA Opposition leader Peter Garrett Federal Minister for the Environment Rory McEwen Acting Water Minister Senator Sarah Hanson-Young Australian Greens Party Simon Birmingham Liberal Senator for SA Duration 135

8012009 601 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Henry Jones fisher Jock Veenstra tourism operator Kym McHugh Mayor Alexandrina Michael Smyth Channel 9 reporter Duration 200

12032009 516 PM Channel 10 (Adelaide) TEN News - George Donikian and Rebecca Morse Interviewees Karlene Maywald Water Security Minister Mark Parnell Australian Greens Martin Hamilton-Smith SA Opposition leader Duration 147

Print media PG227 13 March 2009 The Hon Peter Garrett MP Minister for the Environment Heritage and the Arts Final terms of reference for Barrage EIS httpwwwenvironmentgovauepbcnoticesassessmentslower-lakeshtml Stock Journal 19032009 p 8 General News Adelaide Advertiser 14032009 p 27 General News Lakelander 27032009 p 9 General News Stock Journal 19032009 p 12 General News Stock Journal 19032009 p 16 Letters Times Victor Harbour 19032009 p 1 General News Murray Valley Standard 19032009 p 4 General News

Supplementary EIS for the temporary weir near Pomanda Island -147-

Appendix VIII Summary information of enquiries and

submissions for provision of the proposed temporary weir

Summary information

Number of phone calls to EIS hotline 52 Number of emails to eisdehsagovau from unique individuals 82 Number of feedback comments on the CLLMM website 14 Number of subscriptions to e-newsletter via the CLLMM website 48 Number of Community Information Session registrations on the CLLMM website 47

Number of submissions received by email 61 Number of submissions received by letter 9 Total number of submissions received 70

Number of unique visitors to the CLLMM website 1588 Number of visits to the CLLMM website 2834 Number of page views on the CLLMM website 9343

Supplementary EIS for the temporary weir near Pomanda Island -148-

Submission Summary

Mr Roger Cooke The writer proposes a major scheme which aims to simultaneously drought-proof the Murray-Darling Basin and to meet 2020 emissions targets Features of the scheme include - Laying concurrently gas and water pipelines from the NW Shelf to major centres including SA mining towns and Adelaide - Laying irrigation pipes to replace open channels a financial stimulus package - Piping LNG to replace coal-fired energy production assisting Australia to meet 2020 emissions targets The submission outlines a national water distribution scheme as well as a proposal for creating a river channel in order to prevent evaporation across the Lakes while maintaining a freshwater channel The writer proposes a scheme for a long-term solution to the Lower Lakes The writer suggests a permanent weir is necessary as drought will increase in severity and frequency The proposed scheme would aim to reduce evaporation occurring over the Lakes by creating a channel from a proposed permanent weir to the barrages The writer suggests benefits to the Coorong mitigation of Acid Sulfate Soils a freshwater environment for boating while p rotec ting Ad ela id e s wa ter supp ly

Mr Michael Galea Argues there are too many unquantifiable risks associated with the proposed weir and freshwater is needed now The writer bases the submission on local knowledge and common sense He reports the awesome impact of low water on many plants and animals in recent years in the vicinity of Clayton Bay He expresses concern that a weir will pool polluted water upstream and the saline spike will kill tens of thousands of carp and pollute Lake Alexandrina

Mr Philip Fargher The writer is keen to see base environmental River flows established through the use of Commonwealth Government powers The writer outlines established processes of River flooding which periodically flushed out saline water from the Lower Lakes and Coorong Changes to the system due to locks allocations irrigation and the barrage are noted Seawater flooding of the Lakes is thought to lead to negative and unpredictable results as tidal exchanges are insufficient Acid Sulfate Soils require freshwater flows or peripheral lime sand

Mr Andrew Zoerner The writer is concerned that a freshwater environment in the Lower Lakes will not survive unless a Lock is built east of Clayton as well as a water pipeline from Wellington The aim is to maintain freshwater around Goolwa Hindmarsh Island and Clayton for environmental cultural historical industrial recreational and tourism reasons while preserving local flora and fauna

Mr Douglas Smith The submission has nine points The author seeks clarification identifies gaps and expresses points of view The author asks that the definition of sea level and salinity measures are clarified He notes that ferry operations are

Appendix IX Table of submissions

The table below provides a summary of submissions received during the public consultation period An electronic copy of the submission can be located on the DEH website httpwwwenvironmentsagovaucllmmtemporary-weirhtml

Submission no

PTW00001

PTW00002

PTW00003

PTW00004

Submission from

PTW00005

Supplementary EIS for the temporary weir near Pomanda Island -149--

Submission no

Submission from Submission Summary

not discussed under the do nothing option and notes that the difficulties of decommissioning a weir are understated He notices that there is no discussion of management of blue green algal blooms above the temporary weir

PTW00006 Ms Melanie Rees The author argues that efforts to mitigate negative impacts of a proposed temporary weir are grossly inadequate and any amendments envisaged to the draft EIS will not make the weir development acceptable Threats to species and communities are not adequately addressed or are downplayed or discountedThe author indicates concern about the lack of genuine community consultation and argues that the weir development should be considered with other developments because there are cumulative impacts She expresses points of view on public understanding of pertinent issues drought the importance of cost benefit analysis and suggests changed wordings The author suggests investigating filling reservoirs and drawing from them while relocating pumping stations She suggests that stormwater statistics are inaccurate and recommends increasing stormwater harvesting to alleviate reliance on the River Murray The author provides detailed information about the Southern Emu-wren noting Draft EIS information is out of date Gaps are identified in that phytophthora impacts are not considered at the weir building site and the impact of a weir on Callop fish is not discussed

PTW00007 Mr John Clark President Southern Alexandrina Business Association Inc

This submission puts a case for an alternative to the proposed temporary weir near Pomanda Island SABA argues for a permanent lock (Lock 0) in the vicinity of Tailem Bend SABA refers to Gell et al and notes the estuarine but predominantly freshwater environment of the Lower Lakes A navigable lock with a fishway would support the ecology and recreational fishing and boating (boating valued at $200m pa) and meet water security objectives SABA argues that climate change increases the logic of a permanent Lock 0 Supports remediation and revegetation where appropriate and seawaterif needed to check Acid Sulfate Soils

PTW00008 Mr Mike Brisco This submission draws on authoritative literature on climate change The author argues that the weir is proposed in an inadequate context that is the context of severe drought in south eastern Australia The proposed weir should be located in other scenarios - especially for example that of rapid climate change In the event that the weir needs to remain in place projected sea level rises need to be considered in its design The main point is that the impacts of the proposed weir cannot be understood in an inadequate context An additional chapter is suggested Other detailed suggestions are made for changes to the draft These changes show more dramatic water security issues than currently documented in the draft EIS (for example diminished run off over time into Adelaide water storages)

PTW00009 Mr Ian Moyle The writer has lived and worked at Narrung and has lasting educational and environmental interests in the Lakes and Coorong He is c onc erned b y governments lac k of acknowledgement of climate change and previous poor water management He urges the state government to get serious about collecting and using rainwater and grey

Supplementary EIS for the temporary weir near Pomanda Island -150shy

Submission no

Submission from Submission Summary

water re-use PTW00010 Ms Jan Meek

Secretary Signal Point Riverine Environment Group Inc

The group believes a weir willl become permanent and that a revised draft EIS should be prepared based on this premise There are seven issues of concern listed Gaps and lack of clarity in the draft EIS are identified The group indicates - that species rescue outside the Ramsar boundary is unacceptable and that the EIS needs to include species impact statements on a range of species - that an impact of a weir will be increased salt discharge salt interception schemes or mitigation measures need consideration - weir removal triggers are unrealistic and imprecise and out of the control of the SA Government

PTW00011 Mr Richard Harvey

PTW00012 Ms Sally Richards

The writer has a long association with the Coorong and Lower Lakes He indicates his opposition to any seawater incursion In relation to the weir he understands that in the order of 500 tonnes of salt a day would build up This would impair water piped to Narrung The writer urges strong action by Federal Government to reverse over-allocation The writers submission is informed by her residence in the Finniss Catchment and membership of the Finniss Catchment Group Points made by the writer include - more freshwater in the river system - over-allocation and poor management of water continues today - for example in the Finniss catchment where there is no Water Allocation Plan - system wide over-allocation must be addressed - more species than those listed in the draft EIS should be considered - the weir will have impacts beyond the weir site The writer advocates working with community and nature and and disallowing XXXXXXX water supply control (company not named for legal reasons)

PTW00013 Mr Trevor Giles

PTW00014 Ms Brenda Lower

The writer has very extensive experience living and working as a primary producer in the Langhorne Creek District and has a strong attachment to the Lower Murray Region He notes the lack of freshwater will lead to habitat loss and that all water supply proposals are interconnected All projects together are an overall threat to the environment Other concerns include - the bund at Narrung Narrows and proposed regulators prevent wind seiche - lack of consideration of groundwater - no fishway inclusion - the unsuitability of the weir site Freshwater is the only viable solution to retaining habitat The writer is concerned about the river and the people of the district and she asserts that water is needed now The author notes negative impacts of increasingly saline water on turtles birds and fish and is concerned about sulfidic soils and human health The author favours a permanent weir and seawater incursions to cover soils

PTW00015 Mr Frederick Gordon Michelmore Farmer

The author is concerned by the increasing salinity in the Lakes He suggests spending 10 of the cost of the weir on increasing rainwater capture from roofs Other sources of water must be found because the river can not keep up with demand

Supplementary EIS for the temporary weir near Pomanda Island -151shy

Submission Summary

Ms Ann Lucas The writer is concerned about previously estuarine areas between the Murray Mouth and Beacon 19Goolwa Barrage which are an important habitat for migratory birds It is suggested freshwater is accessed for the area in order to return it to estuarine conditions - possibly through the use of an inexpensive Desal plant

Mr Glen Jones General Manager Boating Industry Association of SA Inc (BIASA)

Points on matters of national environmental significance relating to the EIS no comment Concerns - BIASA would have liked to see provision for boating

ac c ess (a vessel loc k ) through the weir - the greatest concerns of BIASA are for both the natural environment and the declining economic viability of many businesses and communities along the River Murray downstream from Lock 1 and in the CLLMM region - concerns are for both the immediate situation and the longer term The submission documents the broad membership of BIASA the operation of BIASA and the organizations with which it liaises and for which it provides advice The submission documents financial losses being incurred (economic losses $ figures) as a result of low water levels and low water flows The cost of repairing river bank slumping and impact on ferry services and nearby communities are mentioned The impact of low water levels and low water flows in the CLLMM on social and health wellbeing of communities and jobs in boating and tourism businesses is documented in some detail and discussed The submission supports the immediate construction of a weir

Mr John Coombe Chief Executive Alexandrina Council

Points on matters of national environmental significance relating to the EIS - concern about the future health of the Ramsar protected areas - concern about the lack of fish passage between Lake Alexandrina and the River Murray and vice versa Concerns - most concerns are based on the premise that the weir will reduce water flows into the CLLMM region however this will be temporary only (90 days) - potential for unknown andor unforeseen impacts of building a weir on biodiversity and water quality both upstream and below the proposed weir - the biodiversity of the CLLMM region is dependent on freshwater for survival and is getting insufficient freshwater - infestations of tubeworms and other pests have the capacity to impact on biodiversity including turtles (not currently listed under EPBC Act) - health problems caused by excess dust from dry lake bed areas - increased impact of environmental condition on social and economic wellbeing of the region Suggestions building of a lock upstream is preferred because it will allow fish passage and boating access up and downstream

Mr Derek Fenton Points on matters of national environmental significance relating to the EIS No specific points were raised but a concern was expressed about impact on other species which are not listed under the EPBC Act

Submission no

PTW00016

PTW00017

PTW00018

Submission from

PTW00019

Supplementary EIS for the temporary weir near Pomanda Island -152shy

Submission Summary

Concerns the main concern is for lack of water for environmental flows in the River Murray in the CLLMM area

PTW00020 Ms Vesper Tjukonai Points on matters of national significance relating to the EIS not addressed except to say that in Ngarrindjeri traditional thinking animal bird and fish species (part of Ruwe) are not separated as in Chapter 13 but considered in an integrated way Concerns - questions the thoroughness of consultation with Ngarrindjeri Traditional Owners - impact of declining quality of river systems on humans (especially Ngarrindjeri in this case) - construction of weir would reduce water flows available for the Ngarrindjeri - continuing noise nuisance from pumps at Narrung Narrows pumping especially low frequency noise (health problem) - lack of clarity of the relationship between the Narrung Narrows bund the proposed weir and the future need for pumping at Narrung Narrows - potential health impacts of dust from the exposed edges of drying lakes - there could be increased pumping in summer and autumn at Narrung Narrows if the weir is built - current restriction of activities including collection of traditional foods basket making and others - soc ia l imp a c ts of the d rought a nd inappropriate water

hoard ing and fa rming method s Suggestions - Include the Ngarrindjeri Nation as Traditional Owners of the CLLMM region in the Draft EIS Executive Summary and Draft EIS Fact Sheet - Refer to Ngarrind jeri as Nation and Trad itiona l Owners - Go beyond consultation to partnership with traditional owners in planning and management - Consideration of impact of the drought and water quality situation on humans (Ngarrindjeri Nation and the wider community)

PTW00021 Mr Keith McFarlane

Background local landowner along Lake Alexandrina (family since 1845) cattle production irrigation Points relating to matters of national environmental significance EIS - Mr McFarlane says that the CLLMM is the most important part of the MBD and that river flows must be allowed for environmental maintenance as the highest priority - He is concerned that increased salinity below lock 1 caused by building the weir will be disastrous for the Ramsar-listed wetlands - He is also concerned that mud disturbance around the weir site during construction would turn the water saline and impact on all fish species Mr McFarlane does not support the building of the temporary weir at Pomanda Island The closure of wetlands along the River Murray is supported as long as there is periodic re-wetting Additional concerns Mr McFarlane is concerned that the seasonality of wind direction and speed across Lake Alexandrina may not have been taken into account when the modelling was done and that SW winds in winter and spring will counteract river flow such that river salinity will

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -153shy

Submission no

Submission from Submission Summary

build up more quickly than has been suggested in the draft EIS Suggestions - that Acid Sulfate Soils have not been a problem to date and could be counteracted in future by seeding into exposed areas - it is not necessary to keep the Lakes up to pool level in drought because the Lakes will present a smaller surface area for evaporation reducing amount of water lost - establishment of more rainfall recording stations around the Lower Lakes region to improve the accuracy of data used in modelling

PTW00022 Mr Tom Chapman Director The Marina Hindmarsh Island

Points relating to matters of national environmental significance EIS - the weir would reduce (economic and) environmental activities of the LLMM region - suggests that a fishway should be included in the weir Support the submission supports the proposed weir as a last resort but argues that a permanent lock between Tailem Bend is a better solution He views the weir as a high cost item to build and maintain as well as not allowing boating access between the Lakes and the River Concerns Mr Chapman is very concerned about the impact of lack of boating access through the proposed weir and the consequent negative impact on economic activity in the LLMM region especially on the recovery of boating but not necessarily limited to boating Perspective a worst case scenario and the weir might not be removed for a considerable time (many years) Alongside this he also supports the introduction of seawater into the LLMM and makes points about historic and current salinity levels in the LLMM

PTW00023 Mr Tony Read The author argues that there is no compelling evidence to build a weir He indicates that long-term investments are required for long-term solutions A short and a long-term solution exist The author refers to research into aquifers beneath the Adelaide Plains and provides a reference He indicates that groundwater bores can be increased quickly if necessary and argues that brackish bore water can be desalinated more cheaply than seawater He makes a case for a long-term solution that is the Twin Lakes concept He notes that the partial weir options do not support any argument to build a weir

PTW00024 Mr Mick The writer supports building a weir He notes that people upstream are suffering He is concerned about evaporation losses

PTW00025 Ms Anne Hartnett Points on matters of national environmental significance relating to the EIS - this EIS is only a partia l doc ument bec ause there a re many interrelated interventions occurring in the CLLMM region a single holistic EIS should be put together covering all of the interventions - the site of the proposed temporary weir is at or near a biodiversity hotspot as pointed out in Appendix 15 and was this considered when the site was chosen - potential for release of metals (including heavy metals) from sediments by acidification and associated ecological impacts are unknown

Supplementary EIS for the temporary weir near Pomanda Island -154shy

Submission no

Submission from Submission Summary

- the potential threat of blue-green algal outbreaks and the associated impact are not addressed sufficiently - concern that the honouring of international biodiversity agreements is not a high priority (migratory birds Ramsar wetlands) - an apparent inconsistency in that -15 m AHD is proposed as the trigger level for building a weir and is also the point at which Acid Sulfate Soil risk increases substantially yet the water level after building a weir

will drop below this to -167 m AHD concern that the scenario from here might need to include seawater introduction into the lakes and there is no EIS relating to this possible intervention Concerns - the size and therefore the impact of mud waves generated during the construction of the proposed weir are unknown - the lack of information on rates of acidification and lack of chemical analysis of the sediments and the potential for release of heavy metals upon acidification - cutting off the river from the Lake by building the weir leading to loss of the aerating wind seiche effect - if there are low water flows over the weir in future what will be the impact on water salinity levels upstream - has sought clarification on the cost of engineering solutions but not received information Expresses supports for 10 other submissions Suggestion - proposes that the money that would be spent on all interventions and engineering solutions be used instead to buy water for environmental benefit as well as human consumption

PTW00026 Ms Judy Goode River Murray Environment Manager SAMDB NRM Board

The SA MDB NRM Board agrees the weir should only be built when all other solutions have been exhausted The submission argues in detail and with reference to EPBC-listed species and numerous other species that a fish passage is required to support migration of species upstream and downstream and to support upstream movement as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river Upstream wetlands The submission asks for consideration of the environmental impacts of re-filling wetlands and potential impacts of Acid Sulfate Soil mobilising into the river The submission indicates inadequate measurement of water savings from wetland closures in Section 434 There is an unquantified assumption about the prevalence of the Southern bell frog in Section 1310 which requires consideration Water qualitywater quantity impacts A significant omission is identified in that salinity impacts are not modelled over three years The weir pool above the weir will be relatively small and the impact of wind seiche in the pool is not understood Additional modelling is sought for acid release from acid

Supplementary EIS for the temporary weir near Pomanda Island -155shy

Submission no

Submission from Submission Summary

soils metals release increased nutrient loads blue-green algal outbreaks increased sedimentation and turbidity increased temperatures fish and other biota kills odour dissolved dust fuel and oil spills Further modelling on a range of scenarios Impacts of construction The weir site is at a junction of the Lake and River and is a biodiversity hot spot A more comprehensive explanation of the choice of this weir site is required Technical issuesmore details which require more consideration What are the environmental impacts of sourcing the weir building materials SA Planning justification in writing for exemption under the Development Act Environment and Construction Management Plans How do all the costs which would be included in a properly constituted business plan compare to the potential purchase of water (for a freshwater solution)

PTW00027

PTW00028

Mr Alexander Whitehead Hindmarsh Island resident

Supports the building of a weir at Pomanda Island Also suggests that regulators not be built in the lower reaches of the river and that seawater be allowed into the Lakes

Prof Peter Fairweather Professor of Marine Biology School of Biological Sciences

Background Research Associate and Prof of Marine Biology Flinders University Points on matters of national significance relating to the EIS - the submission raises a number of concerns about the adequacy of the geographic scope of the EIS the treatment of different types of aquatic habitat the use of averages in modelling and several other points listed below Concerns - there is a concern about gaps in the EIS relating to factors that drive ecosystem change the submission questions whether maxima minima and seasonality rates of change have been considered in addition

to average values as these are important - argues that the Coorong and Lake Albert will be affected and should therefore be included in the EIS - questions whether the impact of a weir really is insignificant relative to the effects of drought - questions the reliability of modelling for years 2 and 3 and suggests that more caution should be used in interpretation towards the end of the period - that there is a gap in the EIS in the treatment of aquatic habitat types such as the benthos and the water column - that the different models appear to use different weather sequences to predict outcomes for the same sets of years and that more attention should be given to variation as a result of different weather sequences The authors are not opposed to the need for or construction of a weir but argue that the accuracy of the EIS needs to be improved in relation to several matters of national environmental significance Other points raised The legibility of many Figures in the EIS was not adequate A comment about bird species discussed in 142 and 143 and whether these are the correct or appropriate species

Mr Robert Thomas Points on matters of national environmental significance relating to the EIS none

PTW00029

Supplementary EIS for the temporary weir near Pomanda Island -156shy

Submission no

Submission from Submission Summary

Concerns - concerned about health problems relating to lowered Lake water levels (dust) Supports the construction of a weir at Pomanda Island Suggestions - not to build the regulators around the lower reaches of the River and allow seawater into the Lakes - as a longer term solution suggests the building of a barrage with a lock at Wellington

PTW00030

PTW00031

PTW00032

PTW00033

Ms Barbara Carroll Native Foods amp Plants

Confidential submission

Mr Henry Jones Commercial Fisherman Boating Industry Association

The writer is a commercial fisherman He and his family have been in the Coorong Lower Lakes and Murray Mouth commercial fishing industry for six generations The industry in the area has achieved a number of significant firsts in sustainable fishery management The author now feels ashamed for the following reasons - the extinction of species - the dredging of the Murray Mouth - the death of two thirds of the Coorong - the changing from estuarine to marine of the remaining third of the Coorong - the change from once busy bustling wetlands to a sandy wind-blown desert - the exposure of Acid Sulfate Soils - the pain inflicted on our native animals especially the pain and death of turtles - the slow death of native water rats deprived of habitat - the death of small Lake birds who no longer have their sustaining habitat - the tonnes of dead mussels invertebrates and macro invertebrates - the Government blaming drought rather than providing environmental flows The writer submits that a weir will cause major fish kills and further environmental decay

Ms Gloria Booker Manager Development amp Environmental Services Rural City of Murray Bridge

The submission points out that there was insufficient time for Elected Members and the Council to provide formal comment The Murray Bridge community may receive aesthetic and environmental benefits from raising the River level but this should not be to the detriment of native wild life and migratory birds Points made include - the weir is a last resort in ensuring water for critical human needs - ecological damage is not irreversible - the proposed weir is of sufficient height to prevent salinity moving upstream from Wellington - professional fishermen are provided with access to Lake Alexandrina - the location of pumps does not allow salt water to be washed back into the river - consideration be given to allowing river craft and fish to move from the River to the Lake

Mr Chris Bagley Dryland Farmer

Points on matters of national environmental significance relating to the EIS - the Draft EIS carries no mention of the highly regarded and important Milang Snipe Sanctuary Concerns

Supplementary EIS for the temporary weir near Pomanda Island -157shy

Submission no

Submission from Submission Summary

- that SA water planning focuses too much on consumption - that the Draft EIS indicates that only 50 of the weir material is to be removed a the end of its life and that this is not acceptable - that there may be a weir collapse with associated impacts due to the nature of the base material Suggestions - the a uthor strong ly suggests tha t Dilution Flow be

rep lac ed by the c onc ep t of Maintena nc e Flow with a rationale and that MDB management should focus on this - that the Draft EIS focuses on a base flow of 350GLyear past Pomanda Island he suggests that other scenarios and their impacts also need to be considered including zero flow 700GLyr and 2000GLyr - the author supplies a water resource report for the MDB (Mar 09) and proceeds to argue that SA can buy environmental water to save the Lower Lakes without building the weir and for 25 less cost than weir

construction and removal a set of Tables outlining water purchases over the next 3 years is presented

PTW00034 Ms Liz Yelland General concerns are expressed about the draft EIS It fails to concentrate on all species and acknowledge interdependency It fails to persuade that sufficient water will overspill the weir into the Lake No or insufficient water could result in Carp dying and then all Lake life dying Suggests that the proposed temporary weir EIS should be considered with a seawater incursion EIS In relation to chapter 10 the author is concerned that Weir construction will signal to upstream river management that there is no need to provide water to replenish the Lakes as it evaporates Ch 10 is not predicated on the view that there is already an environmental emergency further endangering international treaty sites - Political will addressing over-allocation can save these wetlands - The author expresses concerns about Goolwa Channel and Finniss and Currency Creek regulators - Questions why so little attention is given to the Coorong Comments on Ch 5 - The writer provides an image of childrens Lego sinking in porridge - Local knowledge and draft EIS Appendix 6 are referred to as the author makes the case for the difficulty of establishing the weir at the designated site Comments on Ch 11 - Asks the question what is the possible effect of cutting off the seiche surges of water from Lake Alexandrina into the lower reaches of the River Murray - Local knowledge of seiching is provided which indicates that the River beyond Murray Bridge during times of very low flows has been oxygenated and saved - Also during low flow periods the seiche and wind variations allows salinity and pollution burden to be transported to the Murray Mouth Should seiching be interrupted increasing salt build up causes flocculation of clay particles suspended in the River Conditions then support the possibility of blue-green algae blooms

Supplementary EIS for the temporary weir near Pomanda Island -158shy

Submission no

Submission from Submission Summary

- The author is sceptical that temperature inversion will mix salt to an extent which allows low flow to transport it away - Negative effects of seiching - Salinity build up since 2002 is described (reference provided) - Acid A graph is provided with detailed interpretation of wind salinity water levels and pH The author concludes that generally wind seiching has positive outcomes and that acid is not showing signs of being a problem and salinity could be managed by intermittently ceasing pumping - Concerns about mobilising acid upstream from the weir in wetlands which have been cut from the River Comments on Chap 16 - It is the author s view tha t the EIS implies a n ac c ep tanc e of an unacceptable environmental collapse which shames country and governmentThe weir is an enormous gamble due to the possibility of the weir sinking that construction methods will be ineffective and there are probable unexpected consequences

PTW00035 Mr Lynton Vonow Points on matters of national environmental significance relating to the EIS - the EIS is deficient in that it is not presented as part of an integrated plan for the region and its water and environmental problems - potential impact of building a weircompared to only

having the sill a t the entra nc e to Lake Alexa nd rina a t Pomanda on fish eg Murray Cod Concerns - that the environmental impacts of permanent weirs along the River Murray are severe and the temporary weir poses a similar risk - that the weir would increase the likelihood of blue-green algal blooms in the river upstream of the weir (and associated risk to drinking water supply) - that the salinity spike that would occur in the water near Pomanda Island after construction of the weir would be very detrimental to long-necked tortoises through the negative direct impact of tubeworms which are salt-tolerant Suggestions - that better alternatives to building a weir are (a) purchasing water (b) increasing water harvesting in the metropolitan area of Adelaide (c) relocation of pumping stations to upstream of Lock 1 and that increasing the storage at Mt Bold reservoir has significant problems including negative environmental impacts - that as the Lake levels drop the problem of wind seiching of saline water into the river will decrease - that acid Sulfate Soils are not as serious a problem as was predicted - that allowing seawater into the Lower Lakes would be very destructive The author supports the submissions of 17 other people and groups

PTW00036 Ms Ruth Trigg Concerns - the author is concerned about the basic premise(s) for construction of a weir at Pomanda Island and offers a critique of the process which has led to this point She analyses Chapter 3 of the Draft EIS using an

Supplementary EIS for the temporary weir near Pomanda Island -159shy

Submission

no Submission from Submission Summary

ana lytic a l framework and a toolkit of d ifferent method s (such as Critical Discourse Analysis and a number of others) - from the list of 73 reports agreements and Acts of Parliament relevant to the River Murray system in the CLLMM region (cited in the submission and in Chapter 3) it is argued that the existence of these documents has not helped to retain the long-term health

of the river system - the lack of accountability with regard to the health of the MDB river system in the present system of government and interactions between governments - the unavailability of water audit figures for the whole MDB system for more than one month of data at a time (data seen as withheld) - tha t the voic e of multina tiona l c omp anies and sha rehold ers overrid es the environment s need s illustra ted

with recent quotes from the media about continued expansion of irrigation in upstream states - that the decision to build the proposed weir is connected

with the a im of g rowing South Austra lia s popula tion (to 2 million by 2050) and that keeping this expansion target in the face of present difficulties with the

sta te s wa ter sup p ly is unreasona b le - that the collective voices of knowledgeable people who live near and care about the River system in the CLLMM region will not be listened to Suggestions - the author suggests that new models of economic growth and development need to be urgently considered (eg further development and use of the Genuine Progress Indicator Dr P Lawn Flinders University) The author supports the submissions of 16 other individuals and groups

Supplementary EIS for the temporary weir near Pomanda Island -160shy

PTW00037 Mr John Yelland Points on matters of national environmental significance relating to the EIS - concern that the EIS guidelines have not been followed Concerns - the author seriously questions whether the weir structure can be built considering the nature of the foundation material especially the apparent unsuitability of the foundation at the western end and quotes material presented in Appendix 5 - the mud waves formed by the dumping of rock have not been studied adequately - the wetlands upstream of the proposed weir which are currently dry will be re-wet at some stage with potential for acid formation and release of heavy metals these acids and metals might not be adequately

flushed with the weir in place and the risks need to be studied - the Draft EIS is deficient in that it does not refer to other proposals such as the regulators at Clayton and at Finniss and Currency Creeks modelling of salinity and Lake water levels should take these other

developments into account The author supports the submissions of 13 other individuals and groups

PTW00038 Mr Bruce Brooks Points on matters of national environmental significance relating to the EIS no direct comment but questions are asked about some assumptions and the accuracy of

Submission

no Submission from Submission Summary

modelling presented in the EIS which lead to decision points (water levels wind speed and salinity) Concerns - argues that the problems of the CLLMM are not primarily a result of drought by comparing Figures 0-2 and a graph showing Murray-Darling Catchment annual rainfall trends 1950 2008 (both graphs with trendlines the latter graph possibly not in the draft EIS but presented at community consultation meetings) - argues that the data and modelling that have been used that point to -15 mAHD (trigger point) being reached in Lake Alexandrina in early 2010 may be incorrect and predicts that the levels reached will not be as low as this in the worst case scenario Further he presents data from Kotwicki 1993 (a factor relating evaporation from the lake to pan evaporation measured in situ at the lake) which differs from the factor used b y MDBC a nd uses Kotwic ki s factor to arrive at a higher Lake water level than predicted in the EIS - concern that the salinity levels in the Lakes in the modelling output presented in the EIS are underestimates and that the data need to be looked at again

PTW00039 Dr Keith Walker This is a detailed submission which provides important knowledge and information on a range of relevant issues including ecology and threatened species of the lower Murray and CLLMM The submission raises many pertinent questions Points on matters of national environmental significance relating to the EIS - a weir pool is not the same habitat for plants and animals as a river or a lake conditions in the pool will favour species such as common carp and discourage riverine species in particular - there should be a fish passage in plans for the weir - the author is concerned that diadromous fish (ie requiring access to the sea) are prevalent in the lower Murray but these would be unable to move beyond the weir - more consideration should have been given to the wetlands between Blanchetown and Wellington - contends that statements on page 13-17 (Interaction of salinity with EPBC-listed fish species) about salinity tolerance of early stages of freshwater fish are misleading - the author says that the discussion of EPBC-listed species is incomplete and superficial - states that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the MDB including the CLLMM region are currently being evaluated for EPBC listing

- the author disagrees with statements in the Draft EIS that suggest tha t the weir would not a ffec t c ond itions a fter d isc onnec tion a rguing instead tha t rec overy will b e delayed - suggests that Chowilla should be listed among the Ramsar wetlands because birds may need to move that far if food becomes scarce in the CLLMM region Concerns - the proposal should be considered alongside other current and planned interventions in the CLLMM regions for

Supplementary EIS for the temporary weir near Pomanda Island -161shy

Submission no

Submission from Submission Summary

the purpose of the EPBC Act - that over-allocation of water is likely to be a major contributor to the crisis in the CLLMM - that the alternatives to a weir have not been adequately considered in terms of feasibility costs and benefits in economic and environmental terms ideas such as shandying water are put forward - that there is a significant risk of development of algal blooms including toxic blooms in the weir pool and that there is scientific literature on this local situation - that the weir will be in place for at least 10 years (with reasoning for this conclusion) - the construction of access roads to Pomanda Island should have been subject to an EIS as it iswas a (dynamic) sand spit - that there is little reference in the EIS to work on Acid Sulfate Soils in other places - that the salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences that the tolerable salinity limits for freshwater species need to take into account peak levels not

average levels - that flooding of the Lakes region with seawater will cause a total ecosystem collapse of a Ramsar-listed wetland - that the weir will have an impact on pest species (common Carp and tubeworm) but this is not addressed in the Draft EIS - tha t the term keystone spec ies is misused in Chapter 6 Suggestions - more attention should be paid to mixing processes in the weir pool and Lake Alexandrina with respect to the perceived increased risk of algal bloom formation - tha t we should ma ke more use of others c onsid erab le experience on dealing with Acid Sulfate Soils

PTW00040 Ms Alison Radford SA President Australian Institute of Landscape Architects

The AILA notes that the following points appear to be missing from the Executive Summary under the terms of reference of the EIS and should be included there as they have been addressed in the body of the Draft EIS - what is the potential for deterioration of the quality of water in the weir pool - is there a soil acidification risk upstream as a result of the construction works - how will the weir pool be filled without increased water flows to the River - there d oes not a p p ear to b e any worst c ase sc ena rio discussion of the effects of further disrupting flows within the main River channel Also AILA notes that while there has been a lot of discussion of impacts downstream from the proposed weir in the Draft EIS there is not a corresponding examination of effects upstream AILA requests that future consultation processes include information sessions in the Adelaide metropolitan area

PTW00041 Mr Trevor Harden This submission argues that dust from exposed dry lake beds in the CLLMM region is a major problem and concern and that the best way to control this problem is to fill the Lower Lakes region with seawater a step which requires that the weir at Pomanda Island be built as soon as possible The author is opposed to community groups who advocate a freshwater solution only and argues that historically the

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CLLMM area is very likely to have been saline especially at times of low river flow He takes issue with the d oc ument A Fresh History of the La kes by Sim and Muller a nd a rg ues with the support of quotes from journals and personal observations that the CLLMM has a history of being a saline estuary at certain times

PTW00042 Mr Bruce Angus Allnutt Committee Member River Lakes amp Coorong Action Group

The submission mainly addresses Chapters 8 and 10 of the Draft EIS Points on matters of national environmental significance relating to the EIS - queries why there is no fishway in the proposed weir - contends that many statements in the Draft EIS use

language tha t suggest there may be impac ts but the authors believe that many of these impacts will definitely eventuate - the authors suggest that impacts on non-listed EPBC-listed species can affect EPBC-listed species because they are part of the same food chain Errors - Page 10-2 of the Draft EIS the authors state that

Tookayerta Creek is a tributary of the Finniss River not of Lake Alexandrina also the Finniss River and Currency Creek flow into the Lower Murray not Lake Alexandrina Concerns - the lack of consideration of ground water resources in the

Draft EIS - that the site for the weir is unsuitable - the loss of habitat due to lack of freshwater flows - that the social issues and impacts are not addressed - that the effects of drought on low water levels are overstated and that the impacts of water over-allocation are likely to be substantial - Table 10-4 states that water levels in Lake Alexandrina will be maintained at +08 mAHD the authors argue that levels of no greater than +07 mAHD should be maintained otherwise there can be serious

erosion damage - the authors are concerned that the systems modelling uses incorrect assumptions or is not reliable (Table 10-8 and Section 1042) - that Section 107 may not be taking into account the extraction of water from pipelines being constructed that take off water upstream of the proposed weir Questions and suggestions - that the EIS should be part of a combined EIS for the larger set of interventions occurring in the CLLMM region - Section 823 that hazardous substances be stored well away from the weir site during construction - query whether the site of the spillway is optimal and suggest that in the present eastern location this will lead to worse silting problems than if it were placed further west - on page 10-3 there are additional reasons for increase in salinity in the Lower Lakes - in Table 10-3 the word sp illway should be inserted a fter weir in the sec ond aspec t point - query why the dilution flow would be disrupted apart from during the weir pool filling period (Table 10-3) - in Table 10-4 there should be a LAC for the Angas River - the modelling has used worst case scenarios was any modelling done with other scenarios

Supplementary EIS for the temporary weir near Pomanda Island -163shy

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Submission from Submission Summary

- the authors would like clarification of the last paragraph on page 10-30 - top of page 10-31 The authors endorse the majority of the key points of 15 other submissions

PTW00043 Mr Neil Shillabeer Chairperson Lower Lakes and Coorong Infrastructure Committee

Points on matters of national environmental significance relating to the EIS - potential effects of significant mud displacement during building of the weir on aquatic life - states that the Draft EIS Chapter 12 (page 12-2) is incorrect and that the Ramsar boundary does extend above the proposed weir site and quotes section 1248 (page 12-12) Some wetland s up stream of the

weir [that are] still within the Ramsar boundary are expec ted to experienc e eleva ted wa ter levels Concerns - that the time required to fill the weir pool will be greater that stated in the EIS because swamps between Wellington and Mypolonga have subsided and the soils under the swamps have dried out these will take time to be re-wet

- that the weir will be difficult to complete (close) satisfactorily given the design and construction method and that it may be unstable as a result - that the scale of the proposed weir is much larger than the example quoted in the EIS of the blocking bank at Narrung Narrows which has already had problems that required attention including recent problems not included in the Draft EIS

PTW00044 Mr Ron Heyne The author supports a weir or a permanent lock at Pomanda Island and seawater incursion into the Lakes The author is concerned about other weirs at Finniss River Currency Creek and Clayton and pumping water from Lake Alexandrina into the Goolwa channel He understands this will deplete the Lake and expose more Acid Sulfate SoilsHe proposes a channel into Lake Albert from the Coorong

PTW00046 Mr Shaun Berg Lawyer Ngarrindjeri People

This is a lengthy detailed submission which addresses a variety of issues and makes 57 points about the Draft EIS The submission suggests that the Draft EIS for Pomanda Island be rejected and that the building of the proposed weir should be rejected on a number of grounds It is argued that the EIS has failed to take into account Ngarrindjeri views and that Ngarrindjeri Native Title Rights are affected Finally the submission appends the disclaimers in the Draft EIS and the Appendices to the Draft EIS and thereby points to a number of uncertainties in systems modelling (eg salinity wind) and efforts made by Government and consultants to reduce these uncertainties This submission supports those made by two other individuals Early in the submission the following points are made about the wishes of the Ngarrindjeri

1 natural solutions should be used rather than engineering solutions

2 solutions should consider the CLLMM region as an integrated whole

3 the CLLMM region needs to be maintained as a freshwater area

4 environmental flows to the system are needed to

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Submission no

Submission from Submission Summary

maintain freshwater ecology 5 exposed lake beds should be remediated by

plantings or sand 6 cattle and other animals should be excluded from

these areas to minimize acid soil problems 7 hot spots of acid soils should be treated with lime or

sand Omission Table 4-3 is referred to in the text of the Draft EIS but is not supplied Points on matters of national environmental significance relating to the EIS At least 5 points relate to the EPBC Act - the Australian Painted Snipe should be considered in the EIS (with reasoning) - the EPBC protec ted matters searc h tool wa s used to generate the list of EPBC-listed species likely to be found in the region This result is indicative only has consultation with experts also occurred - the draft EIS does not include the Coorong or Lake Albert in relation to impact on Ramsar listed wetlands yet the Coorong and Lakes Alexandrina and Albert were listed together as a wetland of international

importance under the Ramsar Convention the three are related especially given that water is being pumped from Lake Alexandrina to Lake Albert - the potential impacts of weir operation and removal on

EPBC-related matters has not been not addressed Concerns - EIS process at least 6 points deal with EIS process for

example there is concern that the Draft EIS is not a stand-alone document as required (eg accompanying documents referred to in the Draft are not all available)

- Integration is needed at least 5 points deal with the need to consider this Draft EIS together with the environmental impacts of other current or planned interventions in the region (such as the introduction of seawater into the Lower Lakes)

- Over-allocation it is suggested that over-allocation of water is a major reason for the current crisis

- Technical concern is expressed that too little detail is provided about the construction of the weir

- Removal of the weir no consideration has been given to the removal of the weir if the Lower Lakes have been flooded with seawater This needs to be considered

- Alternative solutions 14 points deal with alternative solutions to the building of a weir it is argued that alternative solutions have not been described or considered in sufficient detail particularly the possibility that

combinations of alternatives may be an effective way to gain sufficient freshwater supplies

- Systems modelling concern is expressed that (a) the impacts are assessed only with an inflow of 896 GLyear to SA other scenarios with lower inflows need to be considered (b) salinity is only modelled for one year (c) impacts of the weir on water temperature

and turbidity are not addressed sufficiently - Soil chemistry risks associated with Acid Sulfate Soils

upstream of the weir and potential impact on the potability of water around pumping stations should be given greater attention there are several questions

Supplementary EIS for the temporary weir near Pomanda Island -165shy

Submission no

Submission from Submission Summary

about Acid Sulfate Soils for example what is the likelihood that the building of the weir itself will lead to a pH crash

- Management and mitigation a number of concerns are raised about what monitoring enforcement mitigation and review procedures will be applied

Suggestions - that the Draft EIS for Pomanda Island be rejected on the grounds that it does not comply with the Guidelines - that the SA Government take into account the changed use of the weir (from a means of securing water supply only to also acting as a barrier to ingress of saline or polluted water into the river) and then resubmit an EIS which covers this broader scope - that the Draft EIS fails to support the construction of a weir at Pomanda Island on the following grounds

1 The proposal does not consider alternatives sufficiently particularly combinations of alternatives

2 That the draft fails to distinguish adequately between impacts of the scenarios with and without the weir

3 There is a risk that the water quality in the weir pool may be poor because of algal blooms

4 There is insufficient attention given to the problem of Acid Sulfate Soils and measures taken elsewhere to solve this problem

5 The proposal should be integrated with other proposals eg the proposal to allow seawater into the Lower Lakes

6 The treatment of EPBC-listed species is superficial and lack plans for mitigation of negative impacts

- that the Draft EIS fails because it does not take into account views of the Ngarrindjeri - that Ngarrindjeri Native Title Rights are affected by the proposal and a number of points are made in relation to this claim

PTW00047

PTW00048

PTW00049

Mr Andrew Milazzo Executive Director TSD DTEI

This submission details the requirements for technical aspects of commissioning the weir according to DTEI regulations Examples are the inclusion and positioning of warning lights on the structure and signage The submission notes that there was no mention in the Draft EIS of the operation of the Narrung Ferry

Ms Jacqui Showell Suggests Adela id e s wa ter supp ly is the main d river for the weir Questions if enough alternatives are being investigated Concerned that decommissioning criteria will never be met Suggests ecological effects downstream will also occur upstream affecting the whole country Believes the system should be treated as a whole Suggests acid and heavy metals will affect regions and Ad ela id e s d rinking wa ter Concern for flora fauna (particularly southern bell frog Murray cod and migratory birds) and Ramsar obligations

Ms Cecily South Over-allocation and human activities need to be addressed The Eastern Mount Lofty Ranges flows into Lake Alexandrina mitigate ASS and heavy metals Further water savings are possible if households have allocations rather than timing restrictions There is water upstream get it Crops that cannot be sustained with irrigation should be

Supplementary EIS for the temporary weir near Pomanda Island -166shy

Submission

no Submission from Submission Summary

abandoned - change to sheep and cereals Reference to technical paper written by Brooks and South The barrages all lead but must be kept closed The SA Government and SA Water should stop pumping from Lake Alexandrina into Adelaide storages Landowners are losing 2-3 metres of lakefront pa The author is opposed to seawater incursions

PTW00050

PTW00051

PTW00052

PTW00053

Ms Ruth Beach Solicitor Environmental Defenders Office (SA) Inc

Points on matters of national environmental significance relating to the EIS

- this submission argues that the proposed weir will be permanent rather than temporary because the conditions for its removal are not likely to be met and that it will be physically very difficult to remove the weir as such the proposed weir should be assessed under the Development Act and the Draft EIS should take into account permanent effects on the environment in the CLLMM region including the Ramsar-listed wetlands and associated fauna and flora

- proposes that the construction of the weir is in contravention of legislation (State and Federal) and international conventions (Federal EPBC Act Water Act Murray-Darling Basin Act State Development Act River Murray Act Natural Resource Management Act Environment Protection Act)

- it is argued that the Draft EIS and proposed weir should be considered alongside other current and planned interventions in the CLLMM region

Concerns - that the EIS has not given sufficient consideration to

alternative sources of water - that other relevant Government reports are still in

preparation Ms Silver Moon Suggests EIS should and fails to be about the impact of an

action Suggests there is deficient understanding of the environmental processes and interactions in the Coorong and Lower Lakes Suggests climate change needs to be addressed Contributes considerable researchedreferenced information on various fauna and suggests they should be included as matters of NES Indicates the significant impact weir construction will have on wildlife and the system Suggests Australia has agreements it must abide by Suggests Chapter 15 is vague and lacking substance Suggests the weir does not meet principles of environmentally sustainable development and calls for action in addressing water allocation in the Eastern Mount Lofty Ranges including Finniss catchment

Mr Rex Hunter Confidential submission

Mr Tim Drew CEO The Coorong District Council

The Council points out - Tha t muc h of the CLLMM area is within the Counc il s boundary and details the population and main land uses - That the area is of particular significance to the Ngarrindjeri - That the Coorong and Lower Lakes were listed in 1985

as a wetland under the Ramsar Convention and that

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a req uirement is to manage the a rea in a way tha t mainta ins [its] ec olog ic a l c harac ter

- That the Coorong and Lower Lakes are icon sites under the Living Murray Initiative - That as a response to the situation it has established the Lower Lakes and Coorong Infrastructure Committee (2007) - That it is opposed to the construction of the weir at Pomanda Island and any other new man-made structures in the River Murray

Points on matters of national environmental significance relating to the EIS

- the submission points out that there is a Ramsar wetland just upstream of the expected weir site at Pomanda Island and that this needs to be corrected in the Draft EIS - there is concern that there will be significant algal blooms after weir construction and that this will have a negative impact on native fish stocks

Concerns - that the present situation has been brought about by over-allocation of water resources across the MDB rather than by drought - the economic and social impacts of the situation (low water levels and flows) are very serious - that the weir will intervene in the natural river system and have a negative impact as a result - that the Draft EIS Chapter 26 includes the topic of maintenance of water levels for pumping purposes and that this was not included in the original referral to the Federal Government - that the modelling in Chapter 2 is in error because the forecast figures used for levels of L Alexandrina considerably understate the winter rainfalls of 2008 - that the modelling in Chapter 2 may be unreliable because it relies on estimates - that the triggers for removal of the proposed weir need to be more clearly defined and more realistic (the current conditions for removal are not likely to occur for another decade) - that there is a significant risk of blue-green algal blooms in the weir pool - that there is a risk of heavy metal release and acidic soils if the weir is built and potential impact on wildlife - that the weir will lead to the build-up of water with low oxygen concentration with risk to fish populations - that the significance of wind movement (wind seiche) is underestimated in the Draft EIS

PTW00054 Prof Diane Bell Committee Member River Lakes amp Coorong Action Group Inc

The Draft EIS should be rejected because it is inconsistent with the Guid elines for the Content of a Draft Environmental Impact Statement on the Proposed Temp ora ry Weir a t Pomand a Isla nd The p roposa l

- is not a stand-alone document - should properly be considered as part of a larger plan - lacks detail to support plans for construction operation and removal - has no staged and costed short mid and long-term plans for mitigation of NES - fails to investigate alternatives

The proposal will not achieve its stated goals because the

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- triggers for removal are unrealistic - construction is problematic - water quality above the weir will be poor

The proposed action is likely to have significant impacts on internationally protected wetlands and species that the Federal and South Australian governments are obliged to protect The proposed weir is not the solution to the crisis in the Lower River Murray and Lakes The SA Government should be required to submit a Referral which takes all proposed actions into account and explores all options Part 1 the status of the EIS procedural points Summary It is their contention that the Draft EIS is significantly flawed and should be rejected by the Minister under Section 133 EPBC or alternatively the Minister should require that new Draft Guidelines ones that accurately reflect the situation and the needs of Adelaide for a secure water supply be prepared by the SA Government A number of points require further consideration

1 There is no longer a crisis of water security Minister Maywald has announced she has bought water for next year Acidification and increased salinity are now significant issues but were not when the Guidelines were published Given that both quantity and quality issues have changed the Guidelines should be varied or a new Referral written

2 Since the proposed temporary weir referral there have been a number of other proposals which impact on the quality of water (a weir rationale) The EIS is (therefore) flawed because it is not a stand-alone action and is in violation of the Guidelines

3 The author asserts that the triggers for removal cannot be achieved and there is no long-term plan that explains how they might be achieved

In other points the writer expresses a desire for access to related documents greater clarity and certainty less repetition in the draft EIS and for supplementary reports to be ava ilab le In a d d ition the EIS outlines c onsulta tion whic h has been inadequate ineffective and non-responsive to pub lic questions Part Two Chapter commentaries substantive questions The a uthor s summary sta tesThe EIS is tentative incomplete lacks detail and refers important matters to further supplementary reports and EIS The author states that the SA Government should be req uired to make d eta ils of the freshwa ter solution available as part of the EIS process She asks for a stronger d efenc e of the weir as the only feasib le op tion Referring to Richards she indicates that over-allocation and poor management continue on the Finniss and other tributaries today and asks who makes decisions about critical human needs and under what conditions On wetlands she states that the EIS cannot be considered competent and on seepage and run off the EIS does not give due consideration and states that the criteria for removal are unrealistic and unlikely to be met The Draft EIS displays little or no understanding of the imp ortanc e of c ultura l flows to the Nga rrind jeri

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Submission no

Submission from Submission Summary

Chapter 2 comments as for submission by K McFarlane Chapter 3 comments this consists of pages 7 and 8 of the EDO submission which sets out reasons for non-approval of the Draft EIS under various legislative and regulatory processes Chapter 4 comments this is a combination of K Mc Farla ne s sub mission with a few c ha nges with the addition of the suggested Government freshwater purchase options (staged over three years) from C Ba g ley s submission Chapter 5 Proposed works to be undertaken The author contributes local knowledge about aspects of the Causeway which indicate that it is a dynamic area and that the development of the Causeway will create new flow patterns during floods Comments included

- there is no staged plan for the period of the weir pool filling to manage water issues and consequences below and above the weir - there is insufficient detail describing weir construction methods - insufficient is known about embankment materials and potential to pollute

Concern is expressed about - the amount of weir material which will sink or be washed downstream - the lack of an Environmental Management Plan - the lack of a fish passage - unrealistic weir decommissioning triggers and lack of detail in decommissioning planning

Relevant aspects of the submission by Liz Yelland are then included Chapter 6 comments replicate those submitted by Silver Moon in her submission Chapter 7 comments replicate those submitted by Silver Moon in her submission Also included is a portion of Anne Hartnetts submission (80409 page 5) The first section asserts Australias seemingly low honouring of Jamba Camba Kowamba and the Ramsar agreement and refers to the effect of the weir on migratory birds and the significance of weir placement at a meeting of waters Further Hartnett references (page 5) are made in relation to water levels and the need for spelling out of the effects of MAJOR interventions to remedy the result of these that

would be felt by all other biota Chapter 8 comments this is essentially taken from the submission by B Allnutt and T Giles with an additional comment expressing concern about the risk of habitat loss which in turn leads to species extinction Chapter 10 comments this section contains almost all of B Allnutt a nd T Giles submission (exc ep t for the summa ry of c omment for EIS p lus a paragrap h referring to C Bag ley s submission (questions about salt mobilization when sufficient ra in fa lls) two c omments from K Walker s sub mission (concerns about algal blooms upstream of the weir and acidification of wetlands upstream of the weir) and pages 3 to 5 of L Yella nd s sub mission a b out wind seic hing Chapter 11 comments this includ es N Shillabeer s submission one page (pa ge 4) of A Ha rtnett s submission (the effect of the weir on upstream water quality) and two

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Submission no

Submission from Submission Summary

paragra p hs from S Ric ha rd s sub mission (wa ter qua lity) Chapter 13 The criteria for removal are unrealistic and unlikely to be met This underlines the lack of a long-term rec overy p lan and c asts d oub t on the tempora ry na ture of the weir Chapter 14 comments raise the absence of the Milang Snipe Sanctuary from the draft EIS Page 67 contains the list of birds also contributed by Silver Moons submission (Moon S un-numbered page re section 77 Summary) Commentary on Chapter 15 Environmental safeguards and mitigation measures raises

- Lack of fish passage - Diminution of freshwa ter hab ita t for two mentioned fish spec ies - c omment tha t a rg uements tha t the impac t of the weir c onstruc tion a nd opera tion a re minima l a re misguid ed and fa ils to rec ognise the p rob lem

Further Chapter 15 inclusion replicates in full questions raised by Liz Yelland (submission PTW 34 pages 1-2)

PTW00055 Mr Tim Milne Scientific Officer Nature Conservation Society of SA

Issue 1 Suggests the weir will exacerbate water level reduction and potential problems increasing need for remedial action Also suggests EIS does not address remedial action required Solution 1 examine the impacts of actions to increase water levels in the Lake as these are a direct consequence of weir construction and operation Issue 2 Risks to species associated with increased salinity and acidity Solution 2 EIS should examine impacts of accelarated incareases in salinity and acidity of the water Issue 3 Shortcomings in the environmenetal assessment of construction in Ramsar wetlands Solution 3 Full range of florafauna species need to be examined Issue 4 Lacking accurate information on period of operation and predictions of removal triggers Solution 4 EIS should assume the weir to be permanent to mitigate matters of NES in case this occurs

PTW00056 Ms Gillian Whiting Project Coordinator Murray-Darling Basin Authority

This submission is in the form of the letter addressed to the Director CLLMM Projects under the signature of the Chief Executive Rob Freeman Murray-Darling Basin Authority The letter notes that the proposed temporary weir must be assessed and approved under the Water Act 2007 (Cth) The MBDA requires more details than already provided in the EPBC Act referrals The MBDA asks for clarification and expansion of a range of issues - flow use control and quality of water The MBDA requires information and data relating to hydrology design flow assumptions water balance (inflows storage outflows) assumed water volumes design flood assumptions Hydraulics design details relating to flood surcharge and Water Quality flow cessation into Lake Alexandrina and seawater introduction and acidification thresholds The authority seeks additional information in order to make an Environmental Assessment on fish passage and disconnected wetlands below Lock 1 Weir plans must be submitted to the Authority for

Supplementary EIS for the temporary weir near Pomanda Island -171shy

Submission no

Submission from Submission Summary

consideration and approval Information is required about the capacity of the weir crest to resist erosion More detail is required in relation to weir removal in relation to definitions of normal time required to remove method of removal if a flood Other issues in relation to increased salinity in Lakes Alexandrina and Albert the effect of potentional increase in heavy metals and salinity and increased acid production It is anticipated that the Authority will require at least six weeks to undertake its approval processes

PTW00057 Mr David Winderlich Member of the Legislative Council Leader of the Australian Democrats

The author suggests that the cost of the weir be put into buying water bioremediation and assisting communities experiencing hardship due to low flows In his opinion the Lakes ecosystem and relevant matters of NES will not tolerate the impacts of the construction of the proposed weir The author advocates a natural freshwater system

PTW00058 Ms Kathryn Rothe Project Manager Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

Background this submission is on behalf of the Mannum to Wellington Local Action Committee and the Mypolonga Highland Land and Water Management Committee This submission relates in some aspects to the submission by Ruth Trigg Points on matters of national environmental significance relating to the EIS - lack of a fish passage across the weir is pointed out - concern about loss of important habitat Concerns - that the weir is only a bandage solution and that a strong integrated plan is needed that encompasses the environmental as well as social and economic survival of the Lower Murray and the CLLMM region - the submission does not support the construction of a weir and argues that alternative measures must be used especially the purchase of freshwater upstream for the CLLMM and Lower Murray region - that over-allocation of water is an important cause of current problems - that alternative water supplies have not been given sufficient consideration - that there have been and are many plans and reports about the situation but there does not seem to be a holistic or integrated plan - tha t g rowth in the Sta te s pop ula tion will put even more pressure on water and other resources - the allocation of water to different users needs to be reassessed by the MDBA in a holistic way and with food production as a priority - that the weir will be unstable Suggestions - that freshwater be brought downstream to SA where evaporation rates are much less than at the Menindee Lakes - that bioremediation of Acid Sulfate Soils is already occurring - that the new MDBA should start emergency actions in the region as soon as possible - that alternative sources of water and water conservation and re-use measures be put in place The author points out that the task of preparing this

Supplementary EIS for the temporary weir near Pomanda Island -172shy

Submission no

Submission from Submission Summary

submission was daunting and that it took a lot of time effort and community spirit to prepare This submission endorses the submissions of approx 18 other individuals and groups

PTW00059 Ms Karyn Bradford The writer highlights long connection with the CLLMM extensive knowledge and a long list of achievements in the region The submission contains additional references The writer is concerned that there has been a lack of effective public consultation and that government ministers and their employees chose to dismiss the knowledge skills and expertise freely offered by members of the community many of whom have intimate and generational knowledge of the Lakes and Coorong environment EIS coverage The writer believes that the EIS should be rewritten to include all proposed action for the CLLMM region Language used EIS la nguage is c ritic ised a s [c asting] d oub t on the qua lity and veracity of the informa tion p rovid ed and a s having very few d efinitive sta tements

Seiching A very strong possibility that un-potable water could travel down the river and be trapped behind the weir is identified as a flow on effect of interruption of wind seiching Fish passage The lac k of a llowa nc e for a fish passage is sta ted as not meet(ing) one of the three key ecological objectives of the Murray-Daring Basin Commission Environmental Management Plan 2007-2007 for the CLLMM Icon Site River and Lakes system complexity not understood The writer states that the EIS shows that the proponent does not understand the complexity of the interactions between the River Murray Lakes Alexandrina and Albert its tributaries and the Coorong Ramsar principles breached The author submits that the Ramsar wise use tenet and the precautionary principle are breached by the weir at a time when over-allocation and drought have already done c onsid erab le ha rm to the environment The writer endorses submissions of other named persons A table is used to identify and address issues applicable to specific sections of the EIS including - Executive Summary Purpose

Questions whether full information is available No discussion of bad water coming down Murray Seawater option outside this EIS Alternatives to EIS proposal named

- Executive Summary Introduction Possibility that weir will contribute to algal growth if mixing is impeded

- The original referral Lack of fish passage contradicts Murray-Darling 2007shy2007 Management Plan objectives

- Draft EIS section 737 References to Angus and Bremer Rivers are omitted d esp ite signific a nt b iod iversity va lues partic ula rly a t their c onfluenc e with La ke Alexa nd rina

- Draft EIS section 7-5 Why were only 9 of the 68 listed threatened species discussed in detail

Supplementary EIS for the temporary weir near Pomanda Island -173shy

Submission no

Submission from Submission Summary

Short and Long necked turtles and the Japanese Snipe are of particular interest to local people

- Appendix 15 Raises concern with levels of confidence in 64Confidence in impact assessment Suggests that further information is required

- Selections from the EIS The uncertainty expressed by the use of qualifiers in the EIS language is raised as a concern Question Is there enough evidenc e for this p rop osa l to proceed without further study of all aspects of the p roposa l

- Section 121 A sta tement is mad e tha t the weir will not may interact with the ecological values of the Lower River and Lakes

- Section 141 An attachment provides a record of migratory birds sighted in the area The definition of regularly sighted birds in the EPBC Act is questioned and a Web address supplied at which a local record of birds sighted is kept httpwwwmilangorgauMilanghtm

PTW00060 Mr Mike South Attachment Brooks B amp South M Discussion Paper 19 August 2008 Applying a localised water balance approach to estimate losses from Lake Alexandrina and Lake Albert for the years 1970 to 2006 The author suggests that the models used for the virtual weir should be used with caution and a range of further scenarios need to be modelled A clarification is offered in relation to weir pool levels and pumping SA Water pumps can access water at minus 30m therefore there is no need to maintain levels at +1m AHD The a uthor d isc usses in d eta il sec tion 452 Red uc ing Evapora tive losses of the d ra ft EIS and d isputes the statement that 70 of evaporative losses occur in the Lower Lakes He concludes that long-term evaporation for the Lower Lakes is an over estimate and that the apportionment of losses inappropriately biases the Lakes

PTW00061 Mr Jonathan McPhail Inland Fisheries Management Officer PIRSA Fisheries

The proposed weir will increase pressure on fish stocks and fish habitats which will have significant environmental impact on commercial and recreational fishing Habitat above the weir water will be more stable than currently The changed flow regime will better support European carp and negatively impact on spawning recruitment and migration of Murray cod Murray hardyhead and Yarrra pygmy perch This will work contrary to the MDBC Native Fish Strategy Water quality Removing saline water above the weir will d iminish na tive fishes c omp etitive a d vantage Potentia l decreases in salinity and increases in nutrients and sedimentation will also favour European carp and Mosquito fish and potentially increase the threat of blue-green algae blooms A fish passage is required to support migration of species upstream and downstream and to support upstream fish movements as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline

Supplementary EIS for the temporary weir near Pomanda Island -174shy

Submission no

Submission from Submission Summary

In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river The proposed temporary weir will have severe negative impacts on the available fish habitat and water quality and affect the environmental sustainability of commercial fishing

PTW00062 Mr Glenn Williams Natural Heritage Manager Natural Heritage Trust

The writer has 4 areas of key concern with the EIS 1 Failure to take an ecosystem approach

- The imp a c t of adding a further 5200 hectares to the tens of thousands of hectares of fringing reed-bed habitat that have already dried out and degraded along with their micro and macro invertebrate populations has been stated but not properly assessed in the EIS

- The EIS tends to b e qua lita tive ra ther tha n quantitative both of the proposed weir construction and the altered water regimes across ecosystems A clearer quantitative estimate of potential impacts upon na tive vegeta tion is need ed An example is given relating to impact of rock acquisition on native vegetation

- The writer states that the impact on wetland vegetation and (specifically) samphire plant communities should be quantified more accurately

- The writer is concerned that the EIS does not address over-allocation of water and states that no water allocation has been made for the Ramsar site Irrigation and upstream allocations are referred to

- It is asserted that the weir will withhold even more flow including 350MLday to flush out salt emanating from upstream water-using activities

- EIS is considered to give insufficient attention to the potential implications for the Coorong and the hydrological links between the Lower Lakes the Goolwa Channel and the Coorong particulalry during the period of filling the weir

- The writer believes that the Draft EIS lacks context and overview of the range of other feasible actions that might have been taken as well as those needed with the construction of the temporary weir

2 Failure to seriously examine pursue and commit to fund ing other rea sona b le a nd p rud ent a lterna tives

- The writer argues that human needs have been given priority with minimising of environmental impact being a secondary objective

- The writer asserts perceived lack of action by the state government to decrease reliance on Murray giving examples of water allocation from the Murray to the Clare Valley the BILL scheme Port Lincoln and a Port Hughes golf course

- The writer sta tes tha t the p roponent s EIS ob liga tion to exa mine p rud ent a nd fea sib le a lterna tives has

not been fulfilled by the failure to seriously address - Harvesting of stormwater and more substantial flows

from the short west-flowing creeks of the Mt Lofty Ranges

- Promoting water tanks - Increasing Adelaides water restrictions - Pricing water more competitively particularly for

Supplementary EIS for the temporary weir near Pomanda Island -175shy

Submission

no Submission from Submission Summary

industry and irrigation - The writer considers that the movement of the

pumping stations to above Lock One is a better alternative to the weir

3 Failure to adequately address impacts on EPBC Act-listed fish and frog species

- The writer sta tes tha t the EIS ignores c ond itions below the weir and only concentrates on higher water levels above the weir

- The writer notes that there is no commitment to building a fishway to address the impact on Murray hardyhead and Murray cod caused by disconnectivity between the Lake and River and further sta tes tha t the EIS seems to g loss over the very serious impacts that the iconic Murray cod will suffer from reduced water levels and wa ter qua lity

4 Failure to address geotechnical structural problems with the weir

- Refer section 55 and Executive Summary and Appendix 6

Specific issues raised refer to - poor foundation conditions except for the eastern

half of Getochnical model 1 - low sheer strength indicating slope instability - continuing movement and settling of clays - seepage and possible development of piping - impact of earthquakes on foundation sands

Other concerns addressed in short are - The temporary weir being left in place for a longer

period - writer s rec ommend a tion tha t a c tive-adaptive

processses be adopted for bio remediation of Acid Sulfate Soils and a need to clearly identify the indigenous plants to be used

- lack of information on impacts of temperature changes in the Lakes water column

- failure to address the oxygenation of the River water through wind seiching

PTW00063

PTW00064

Ms Beryl Belford Writer supports a one river and whole of basin approach to ecological management of the River and Lower Lakes The writer believes that - water is available in the basin to save the River system - the federal government must take responsibility for equitable distribution of water - state government should regulate water held in stock and domestic dams in Eastern Mt Lofty ranges to ensure environmental flows to the Lower Lakes

Ms Elizabeth Hobbs Points on matters of national environmental significance relating to the EIS - the author is alarmed that the potential impacts of the weir on the Coorong are referred to so little - states that the list of endangered species in the EIS is too narrow and argues that as both species and habitats are interconnected they should not be split up for the purpose of the EIS - emphasizes the need to have healthy waterways in the region due to its ecological importance Concerns - the author is concerned at the cost of the weir and other interventions in the CLLMM region and quotes from other

Supplementary EIS for the temporary weir near Pomanda Island -176shy

Submission no

Submission from Submission Summary

submissions on this point - from first hand experience at seeing sediment build up due to low water flows the author is concerned that this will occur at the weir site and there will be an impact of this silting up - that the weir is a technical solution for problems that should be solved by other means - that the proposed weir needs to be considered as part of the larger set of interventions occurring and being planned in the CLLMM region - that over-allocation of water rather than drought is the reason for major problems occurring Suggestions - the author proposes that there are alternative measures that should be put in place and expanded to reduce Ad ela id e s relia nc e on wa ter form the River Murray - an interconnected systems solution needs to be developed to protect the area listed under the Ramsar agreement

PTW00065 Dr Talina Vizard The writer questions Can local springs be channelled into the river (eg from Victor Harbor) Would redirecting storm water into the system help Have views of Ngarrindjeri been considered Can the use of bore water be policed and how can farmers be educated to the effect of taking water from the c ommon store

Writer Comments Time for comment too short Writer supports the submissions of Liz Yelland (PTW00034)

PTW00066 Ms Carlsa Carter The author states that the South Australian Government ignores the serious environmental condition of the Coorong and Lower Lakes and withholds minimum environmental flows The author states that there is a lack of thorough information about EPBC-listed species and species of the freshwater ecosystem and states that the loss of reed beds and habitat during the period of weir construction is trivialised Attention is drawn to a bird survey by Dr Kingsford of Newcastle University (2009) which shows greatly reduced numbers of water and wading birds over a short period

PTW00067 Ms Julie Pettett CEO Conservation Council of South Australia

The CCSA opposes the construction of a weir near Pomanda Island while accepting that the provision of drinking water is critical CCSA states that the impact of the weir will have unacceptable impacts on several matters of NES and the idea that the weir will be temporary is strongly contested CCSA argues that the EIS is seriously deficient and that the EIS for the proposed temporary weir should be reshyconsidered in conjunction with a referral EIS and public consultation about the introduction of seawater into the Coorong and Lower Lakes The CCSA is concerned about the impacts of a weir on Southern bell frogs Murray cod Murray hardyhead and Yarra pygmy perch and may be able to provide a supplement to the submission about these concerns at a later date CCSA states that the construction of a weir will destroy and degrade more than a hectare of Ramsar wetlands flora

Supplementary EIS for the temporary weir near Pomanda Island -177shy

Submission no

Submission from Submission Summary

and reed beds and have consequent impacts on listed threatened species and migratory fauna Construction of a weir is likely to contaminate the Lake and impact on Ramsar wetlands threatened species ecological communities and migratory species Triggers for removal are discussed CCSA states that the weir will exacerbate acidification of the Lower Lakes and thus the weir will need to be permanent In addition CCSA states the Hume and the Dartmouth storages have not been at normal operating levels for ten years and achieving the prescribed salinity level is unrealistic These factors suggest a permanent weir CCSA believes more consideration needs to be given to the Federal government purchasing water and structural adjustments under the Water for the Future Program Stormwater harvesting aquifer storage and recharge and wastewater re-use would be less environmentally harmful options than a weir

PTW00068 Ms Paula Horbelt Secretary Goolwa District Ratepayers amp Residents Association Inc

This submission urges the State Government to consider water alternatives as Salisbury Council has done It is suggested that Cheltenham could be similarly used as a water capture site The Association encourages rainwater tank policy but questions the energy intensity costs of desalination The Association is concerned that a weir will increase salinity levels in Lake Alexandrina and that Ramsar sites of significance will not be protected The Association understands that water quality between Lock One and a weir at Pomanda island would inevitably deteriorate due to inadequate wind seiching In conclusion the submission states We support the purchase of water rather than weirs temporary or otherwise

PTW00069 Mr Keith Scobe The writer is a member of the Ramsar Taskforce His submission expresses a preference for securing water from upstream He refers to submergable floating booms as a method managing water (instead of a weir) He expresses uncertainty about the no flow period over the weir and expects weir construction costs will escalate He expresses hope that the MDBA will manage the Murray Darling Basin well in future

PTW00070 Ms Ruth Russell The writer is opposed to the construction of a weir and argues for a sustainable freshwater long-term management plan for the Murray-Darling Basin overall The author contributes to Adelaide University Frog Census work and has engaged with CLLMM issues in the region She urges a well researched long-term freshwater solution so that there is a postive outcome for future generations The writer urges - better use of a range of water alternatives - accessing water from the temporary water market through the Water for the Future Program - adoption of the precautionary principle - rejection of this EIS in favour of a more holistic and systematic EIS acknowledging complexity and interdependency The writer understands that the weir will be destructive of nationally listed species and suggests a fish passage should be included She fears algal blooms due to ineffective wind seiching as well as acid soils impacts on water qulaity The

Supplementary EIS for the temporary weir near Pomanda Island -178shy

Submission Summary

writer also fears that the weir will not be temporary PTW00071 Mr Ken Jury and

Mr Mike Young The authors are critical of the unrealistic timeline for consultation They propose a permanent weir which prevents loss of freshwater above and allows an esturine environment in the Lakes below This environment would support wader birds and improve tidal access to the north CoorongThe River Lower Lakes and Coorong must now be regarded as a human-altered environment and managed to suitThe authors argue that it is important not to allow the mobilisation of acid from soils into water as this will corrode the barrages They believe the only option is to inundate the Lakes with seawater and query the freshwater science presented A diversion pipeline is suggested from Morgan and questions are raised about loss of River water into aquifers

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -179shy

Government of South Australia

  • Table of Contents
  • Part Two - Community Consultation Report ndash Appendices
Page 3: Supplementary Environmental Impact Statement

Format of Supplementary EIS

This Supplementary EIS is in two parts

Part One is the Supplement to the Draft EIS It provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report This Report over views and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Proponent s details

South Australian Government represented by

Name Peter Croft

Title Director Coorong Lower Lakes and Murray Mouth Projects

Department Department for Environment and Heritage

Address GPO Box 1047 ADELAIDE SA 5001

Proponent s environmental record

The South Australian Department for Environment and Heritage (DEH) is responsible for South Australias nature conservation heritage conservation and animal welfare

DEH collects and provides information and knowledge about the states environment

DEH manages the states public land including national parks marine parks botanic gardens and the coastline

DEH also advises on environmental policy

DEH is part of the Environment and Conservation Portfolio and reports to the South Australian Minister for Environment and Conservation DEH delivers the Governments environment policies d irectly and through partnerships These are with other government agencies including the Department of Water Land and Biodiversity Conservation (DWLBC) the Environment Protection Authority (EPA) Zero Waste SA Natural Resources Management Boards and Primary Industries and Resources SA as well as a wide range of non-government environment organisations industry bodies and the community

DEH s work is determined by its ob liga tion to ac hieve rela ted ta rgets in South Austra lia s Strategic Plan to administer legislation dedicated to the Minister for Environment and Conservation and to respond to the needs of South Australians

Table of Contents

PART ONE SUPPLEMENT TO THE DRAFT EIS 1

1 Introduction to the Supplementary Environmental Impact Statement (EIS) 2

Overview of Supplementary EIS structure 2 Purpose 2 DEWHA issues 2

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region 3

Submissions received and responses 3

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir 5

Submissions received and responses 5 Murray-Darling Basin Authority submission 5 The time required to remove the temporary weir 5 Floods 5 Phytophthora at the temporary weir construction site 6 Weir Causeway 7 Weir Site 7 Weir Construction and Environmental Management Plans 7 Weir Materials 8 Weir Crest 8 Pumping 8 Permanent Weir 8 Triggers for Removal 9 Salinity measuring locations 10 Decommissioning 11 Modelling 11 Virtual Weir 13

4 Supplementary comment on expected impacts of the temporary weir on soils and water 14

Introduction 14 Submissions received and responses 14 Acid Sulfate Soils (ASS) 14 Water quality 16 Wind seiche 16 Impacts upon Coorong and Lake Albert 17 Dredging of Murray Mouth 18 Water quality impacts near Narrung Narrows 18 Algal blooms 20 Summary of water quality impacts 21 Connectivity of Surface and Ground Waters 22 Surface Waters 22 Groundwater 23

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels 24

Introduction 24 Upstream impacts 24 Impacts of altered water regime in weir pool 24 Impacts to Pelican Lagoon and Nalpa Station 25

Weir Footp rint Impac ts 25 Impacts of Habitat LossDegradation 25 Impacts upon fish migration 26 Impacts of noise upon wetland birds 27 Monitoring during constructiondecommissioning 27 Timing of construction and presence of migratory species 28 Downstream impacts 28 Impacts of water level changes upon aquatic vegetation 28 Impacts of temporary increase in salinity upon aquatic biota 28 Impacts upon tributary wetlands 31 Impacts upon the Milang Snipe sanctuary 31 Impacts upon primary determinants of ecological character 32 Impact upon keystone species 32 Impact upon habitat availability 32 Impact upon salinity 33 Impact upon turbidity and sedimentation patterns 33 Impact upon water levels 33 Impact upon water regime 33 Impacts upon migratory shorebirds 34 Impacts upon Australian Painted Snipe 34 Impacts upon Orange-bellied Parrot 34 Impacts upon Great Egret Cattle Egret and Caspian Tern 35 Impacts upon pelagic birds 35 Impacts upon bush birds 35 Impacts upon Mt Lofty Ranges Southern Emu Wren 36 Impacts upon White-bellied Sea Eagle 36 Issues of scope adequacy and definition 36 Adequacy of species and communities examined 36 Current status of waterbirds 37 Adequacy of EPBC Act threatened species and communities lists 37 Adequacy of discussion of EPBC Act-listed species 37 Omitted flora and fauna records 37 Definition of keystone spec ies 38 Spec ies c onsidered of partic ula r signific anc e 38 Adequacy of description of different wetland types 38 Regional importance of the Coorong Lower Lakes and Murray Mouth 38

6 Notes on significant issues outside the scope of the draft EIS For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities 39

Ngarrindjeri People 39 Social and economic issues 39 Climate change 40 Dust and health 40 Other themes 40

7 Suggested text changes errata additions clarifications and references 41

References 53

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA) 54

General comments 54 Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth 54 More specific comments 61 Water supply 68 Removal triggers (pg 1-6) 70 Wetlands 72 Re-wetting of upstream wetlands 75 Threatened and migratory species 77 Fishway 81

PART TWO COMMUNITY CONSULTATION REPORT 85

1 Introduction 86

2 Community Information Sessions 86

3 Targeted Meetings 89

4 Overview of media articles (see Appendix VII) 89

5 Receiving submissions and developing the Supplementary EIS 90

PART TWO COMMUNITY CONSULTATION REPORT - APPENDICES 93

Appendix I - Submissions received Individuals 94

Appendix II - Submissions received Organisations 96

Appendix III - Participants and notes from Targeted Meeting Sessions 97

Appendix IV - Organisations that participated in Community Information Sessions 109

Appendix V - Participants and notes from Community Information Sessions 110

Appendix VI - Advertising copy used in the consultation process 127

Appendix VII - Media generated by the consultation process 146

Appendix VIII -Summary information of enquiries and submissions for provision of the proposed temporary weir 148

Appendix IX - Table of submissions 149

Executive Summary

The purpose of this Supplementary Environmental Impact Statement (EIS) for the temporary weir near Pomanda Island is to address Issues of National Environmental Significance (NES) (as defined in the Environmental Protection and Biodiversity Conservation Act 1999) arising from written public submissions and government comment during the period of public consultation for the Draft EIS

Part One is the Supplement to the Draft EIS provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report provides an overview and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Part One of the Supplementary EIS is divided into 6 key sections

Section 1 contains an overview of the document

Section 2 considers the role of the temporary weir within the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth Region These comments are made in response to a number of submissions that suggested that the temporary weir was being considered in isolation

The sec tion outlines the Government s multi-faceted strategy to combat the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region

This strategy includes both long and short-term plans including worst-case scenario measures that would only be implemented as an option of last resort should a fresh-water solution not be found

Section 3 considers submissions relating principally to Chapter 5 of the Draft EIS Proposed Works to be Undertaken

The Murray-Darling Basin Authority (MDBA) submission outlined the approvals necessary under the Commonwealth Water Act 2007 and in particular under clause 49 50 and 63 of the Murray-Darling Basin Agreement

The South Australian Government submitted a detailed application to the MDBA on 15 May 2009

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process however the Authority sought details on the method of removal of the temporary weir in the event of a flood coming down the River

As the flood scenario was not discussed in the draft EIS it is addressed in the section 3 of the supplementary EIS

Any flood moving down the River is most likely to have originated in the upper reaches of the river system and can take up to six weeks to reach the temporary weir location During this time an assessment will be possible as to the appropriate method of management of the temporary weir structure

A significant cluster of submissions were made regarding triggers for removal or decommissioning of the temporary weir

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria stated in the Draft EIS remain appropriate

Other submissions considered in Section 3 relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the proposed temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir A number of submissions also raised concerns about modelling

By way of response section 3 outlines the environmental management framework for the temporary weir including an Environmental Management Plan which ensures management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Section 4 provides an overview of submissions relating to expected impacts of the temporary weir on soils and water

A number of submissions raised concerns regarding acid acidity and Acid Sulfate Soils (ASS) These submissions support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible

ASS field investigations and modelling will enable key information gaps to be addressed and be fed back into the ongoing planning and measures undertaken

Wind seiche and its impact on water quality also formed the basis of several submissions as did possible increases in algal blooms within the weir pool itself

While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes

Some submissions sought clarification regarding the interaction between surface and ground waters

Section 5 Submissions discussed in Section 5 relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

A process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Another issue of concern raised in many submissions is the potential impact of increased salinity within the Lower Lakes upon aquatic biota By way of response Section 5 adds considerable detail regarding predicted salinity changes and the likely biotic response

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Section 6 briefly overviews issues raised in submissions which lie outside the scope of the Supplementary EIS In some cases ideas were contributed which are worthy of note

There is a suggestion about the importance of consulting with and recognising the Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

Another submission argues for having more than one scenario when drafting the EIS (not only d rought but a lso c limate c hange) and another c ontextua lised the c urrent p red ic ament of

the Coorong Lower Lakes and Murray Mouth in ideologies about unsustainable growth

A number of submissions outlined the current social and economic conditions of the Coorong Lower Lakes and Murray Mouth region indicating that there is considerable social and economic suffering attributable to drought and over-allocation of River water

Many submissions expressed discontent with over allocation of water resources and a significant majority expressed opposition to the temporary weir A minority supported the temporary weir and some indicated a preference for seawater flooding of the Lower Lakes (rather than a limited incursion)

There was almost no comment about water security issues for Adelaide and the majority of South Australian country towns

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part OnE Supplement to the Draft EIS

1

1 Introduction to the Supplementary Environmental Impact Statement (EIS)

Overview of Supplementary EIS structure

Rather than replacing the Draft Environmental Impact Statement (EIS) this Supplementary EIS d iscusses those issues raised in submissions Thus most of the tables and figures from the Draft EIS are not repeated Section 7 of the Supplementary EIS lists a range of text changes (corrections deletions additions and minor clarifications)

Note This Supplementary EIS needs to be read in conjunction with the Draft EIS for the proposed temporary weir near Pomanda Island There is no re-written version of the Draft EIS

Purpose

The purpose of this Supplementary EIS for the temporary weir near Pomanda Island is to address issues relating to Matters of National Environmental Significance (NES) that are within the scope of the guidelines arising from written submissions lodged during the period of public consultation for the Draft EIS

DEWHA issues

The Commonwealth Department of the Environment Water Heritage and the Arts (DEWHA) raised a number of issues with the South Australian Department for Environment and Heritage (DEH) Many of these issues are pertinent to the Supplementary EIS and a copy of the response to these issues is provided in Appendix 1

Supplementary EIS for the temporary weir near Pomanda Island -2shy

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region

Submissions received and responses

A number of submissions suggested that the temporary weir was being considered in isolation and several suggested that there should be one encompassing environmental impact statement for actions being considered in the Coorong Lower Lakes and Murray Mouth (CLLMM)

The scale and complexity of the problems associated with lack of inflows to South Australia suggests that there must be a well coordinated set of solutions The South Australian Government has developed a multi-faceted strategy in response to the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region This involves development of a short-term strategy to protect the quality and access of major public water supplies to protect the local and regional environment from irreversible damage and to minimise adverse impacts on infrastructure and the regional community It also involves the development of a long-term management p lan Refer to tab le Summary of SA Government Projec ts in the Lower Lakes Coorong and Murray Mouth in Append ix 1 Question 3

Water security involves water quantity and quality to ensure a potable water supply to Adelaide and Regional South Australia The drought and anthropogenic1 uses have drastically reduced inflows to South Australia and water levels have dropped below Lock 1 (near Blanchetown) increasing salinity and exposing Acid Sulfate Soils (ASS) in the Lower Lakes The oxidation of ASS upon drying can result in acidic water and mobilised metals some of which are toxic to humans above certain concentrations The temporary weir aims to ensure adequate weir pool level for operation of the pumps supplying water to Adelaide and regional South Australia in addition to presenting a physical barrier to acidic andor saline water migrating upstream towards the pump stations from the Lower Lakes

The temporary weir is not considered the only solution to issues in this region The South Australian Government is writing a long-term p lan the initia l version entitled The Coorong Lower Lakes and Murray Mouth Directions for a healthy future This was released for pub lic comment during May 2009 Following a period of public consultation community feedback and with scientific input the final version of the long-term plan will be completed in October 2009 and submitted to the Australian Minister for the Environment Heritage and the Arts (MEHA) as required under the Murray Futures Funding Deed

In addition to the long-term plan the South Australian Government has had to take a number of emergency measures which while separate in their own right form part of a strategy of inter-connected short-term actions

The South Australian Government has referred five proposals to the MEHA for consideration under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) These are

A referral to establish a temporary weir near Pomanda Island (EPBC 20073484) which was determined to be a controlled action in July 2007 (the subject of this EIS process) The South Australian Government has stated that this temporary weir would only be constructed as a last resort and that the Government is continuing to pursue options for a freshwater solution The weir if approved and constructed would be a temporary weir aiming to protect the water supply of Adelaide and many country towns The draft EIS was released for public comment on 12 March 2009 This Supplementary EIS is prepared in response to public submissions that closed on 9 April 2009

A referral to upgrade the Pomanda Peninsula causeway to allow access to the temporary weir embankment site on Pomanda Island (EPBC 20084674) was referred to the MEHA on 23 December 2008 The Minister decided on 23 January 2009 that this p roposa l was not a c ontrolled ac tion

1 of relating to or resulting from the influence of human beings on nature

Supplementary EIS for the temporary weir near Pomanda Island -3shy

A referral to open the barrages that separate the Lower Lakes from the Coorong (EPBC 20084618) as a last resort should this prove necessary The aim of this proposal is to allow the controlled entry of a limited amount of seawater to maintain the water level in the Lower Lakes above the critical trigger level of acidification The proposal has been deemed a controlled action The final guidelines for the Content of a Draft Environmental Impact Statement were released on Friday 13 March 2009 (Note that The Murray-Darling Basin Ministerial Council approved a Real time management strategy to avoid acidification in the Lower Lakes (November 2008) involving the introduction of seawater through the Barrages when certain trigger points are reached The Council recognised the threat of acidification and approved this strategy essentially as a last resort)

A referral to construct a below ground pipeline that is capable of delivering 30 GL annually from the River Murray (at Jervois) to the Langhorne Creek and Currency Creek landowners was submitted on 18 February 2009 (EPBC 20094743) The pipeline will deliver irrigation water to communities and industries in the region that are currently reliant on the Lower Lakes for their water supplies This was assessed as not being a controlled action if undertaken in a particular manner and completion is scheduled for late 2009

An emergency first response referral to mitigate the multiple adverse impacts of Acid Sulfate Soil exposure in the Goolwa channel and its tributaries (Finniss River and Currency Creek) was submitted on 6 April 2009 (EPBC Reference No 20094833) This involves the construction (1) a temporary environmental flow regulator within the Goolwa Channel near Clayton (2) a temporary low-level regulator in the mouth of the Finniss River (3) a temporary low-level regulator in the mouth of Currency Creek The referral also involves pumping water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel This was assessed as not being a controlled action if undertaken in a particular manner

If more fresh water could be secured to flow into South Australia and Acid Sulfate Soil managed to mitigate impacts on water quality then the temporary weir would not be needed

Supplementary EIS for the temporary weir near Pomanda Island -4shy

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir

Submissions received and responses

Submissions discussed in this section generally relate to the content contained in the Draft EIS Chapter 5 titled Proposed Works to be Undertaken The major sections of that Chapter include weir location design parameters and time constraints construction environmental constraints and site selection alternative design options operation decommissioning and removal

Written comment received on Chapter 5 from the public and government agency respondents raised a wide range of issues A gap relating to the temporary weir and the effect of flood was identified and there was a significant cluster of submissions related to triggers for removal or decommissioning the temporary weir

Other submissions relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir

Murray-Darling Basin Authority submission

A submission from the Murray-Darling Basin Authority (MDBA) stated that approval for the construction of the temporary weir was required under clause 49 50 and 63 of the Murray-Darling Basin Agreement and detailed exactly what was required as part of the approval process The South Australian Government subsequently wrote to MDBA (15 May 2009) seeking approval for the construction of the temporary weir

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process However many of the details requested are relevant to the temporary weir

The MDBA sought details on

Quantifiable triggers for removal

The time required to remove the temporary weir

The method of removal if a flood is travelling down the river when the level of Lake Alexandrina is low

The effect of increased salinity levels

The effect of the potential increase in heavy metals and

The effect of an increased sediment rate of acid production around Pomanda Island

On 30 June 2009 the MDBA approved plans for the proposed weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

The time required to remove the temporary weir

Refer to discussion on floods below

Floods

The MDBA submission has requested information about the removal of a temporary weir during a flood

Response

Given the exceptionally low storage levels in the Murray-Darling Basin system it would take considerable rain over a prolonged period of time and throughout a significant proportion of the Basin to generate a flood of sufficient flow resulting in all the decommissioning triggers

Supplementary EIS for the temporary weir near Pomanda Island -5shy

specified in section 58 the draft EIS being met Should a flood event signal the achievement of the weir decommissioning triggers the decommissioning and removal would only proceed after the flood has passed

Nevertheless advice has been sought from relevant authorities regarding both the specific level of rainfall necessary to create flood conditions in the Murray-Darling Basin catchments and the lead time available to remove the temporary weir in the unlikely event of a flood

Any significant flood moving down the river is most likely to have originated in the upper reaches of the river system and therefore can be expected to take up to six weeks to reach the location of the temporary weir During this time an assessment will be possible as to the appropriate method of management of the structure of the temporary weir

The temporary weir contains a spillway which is designed to pass 15 GL a day with a minimal rise in the upper weir pool level This flow rate was given by the MDBA as a nominal upper flow limit for normal river management and represents a 15 fold increase from the current flow past Wellington of approximate 1 GL per day A design for higher flood events was not included in the draft EIS due to the expected very low probability of occurrence plus the expectation that if flood event were occurring then the river system would have recovered and the temporary weir would not be required

The impact of flood flows over the temporary weir are being reviewed and initial indications are that flows much greater than 50GL per day could be passed without the upper weir pool level rising above the normal full supply level (FSL) of 075m AHD

In the unlikely event of a significant flood two reactions are available Firstly the flood could be allowed to pass over the temporary weir or secondly a breach in the temporary weir could be made to assist passage of the additional flow

The choice of the best option depends on the flood flow size the water level in Lake Alexander and the degree to which it could be flushed by the flood and the likelihood that the temporary weir will still be required after the flood (ie whether the conditions for weir removal have been met)

If the temporary weir is required after the flood then breaching the weir is unlikely to be a preferred option If the flood is allowed to pass over the temporary weir the likelihood of significant damage will depend on both the size of the flood flow and the downstream water level It is expected that flood damage should be low due to the width of the spillway (This is still to be confirmed by additional design analysis)

In a worst case situation a sufficiently large breach in the temporary weir could be done in the available time The method of removal remains the same however the work method will need to control all risks associated with different upstream and downstream water levels that may exist

The South Australian Government will work with the MDBA to develop a weir flood management plan Given the current exceptionally low water levels throughout the Murray-Darling Basin system it would take considerable rain over a prolonged period and over a significant proportion of the Basin to generate a flood of sufficient flow to require removal of the temporary weir The low water levels in storages and the River system also provide the opportunity to regulate a large percentage of high flows

Phytophthora at the temporary weir construction site

One submission claimed that impacts of weeds and pests such as Phytophthora cinnamomi were omitted and that therefore the weir construction could potentially have a significant environmental impact

Response

The Draft EIS (chapter 15) provides details on the environmental management framework for the temporary weir including Environmental Management Plan (EMP) to ensure management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Supplementary EIS for the temporary weir near Pomanda Island -6shy

Once a contractor has been selected the contractor is expected to manage the temporary weir project in accordance with best practice mitigation measures to effectively reduce the environmental risks and avoid adverse impacts associated with site level impacts during the construction operation and decommissioning of the temporary weir

It is recognised that weeds and pests if not managed appropriately can present a long-term threat and impact on the native plant communities in the area

Consequently weed and pest management in general and the specific management of Phytophthora a re a c ritic a l element of the c ontrac tor s Environmenta l Management Plan (EMP) Selection criteria for contractors also include specific environmental compliance and best practice evidence

As part of this project detailed weed assessments will be conducted as part of the risk assessment in the Construction Environmental Management Plan (CEMP) via desktop studies (especially for Phytophthora) weed surveys and expert advice Project-specific mitigation measures are then included in the EMP and a specific (during and post-construction) weed management plan Specific measures may include but are not limited to

Avoidance of weed-infested areas for land-based construction activities (for example by relocating stockpile areas etc)

Construction activities restricted to approve construction corridors only

Weed management plan endorsed by the South Australian Murray-Darling Basin Natural Resource Management Board (SA MDB NRMB)

Wash-bay areas established according to weed management plan

Record kept of hygiene measures conducted prior to entering the site (for example plant trucks materials working clothes shoes boots etc)

Phytophthora cinnamomi distribution is contained to the wetter areas of the state It is highly unlikely that this fungus would be spread at the temporary weir site

For more information see httpwwwenvironmentsagovaubiodiversityplantsshyanimalsdiebackhtml

Weir Causeway

A submission claimed that as the level of the causeway would be higher than the temporary weir this would form a barrier and create new flow patterns

Response

There is no evidence that a flow path across the causeway exists with normal water level conditions The existing causeway and beach area on the western side contain no wash ways On the contrary there is evidence that only minor amounts of water in storm-driven waves have moved over the causeway

Weir Site

A submission from the SA MDB NRMB requests a better explanation of why this site is the preferred site

Response

This is explained through extensive studies summarised in Section 56 of the Draft EIS which concluded that no other feasible site exists down stream from Murray Bridge

Weir Construction and Environmental Management Plans

Some submissions criticised the lack of an EMP

Response

Specific mitigation measures will be developed in consultation with State environmental agencies to ensure that they are consistent with the relevant Acts and regulations (for example the Environment Protection Act 1993 (SA) the Natural Resources Management Act 2004 (SA))

Supplementary EIS for the temporary weir near Pomanda Island -7shy

The EMP is reviewed and endorsed by a number of agencies before any works can be carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) for the overarching EMP SA Water Corporation and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Weir Materials

One submission states that information about sourcing of material is not complete and raises doubts as to whether materials can be transported Will pollutants be introduced to the water

Response

The draft EIS (section 542) addressed the first two issues raised

The issue of pollutants to the Lake from the embankment material is covered in the requirements for an EMP and CEMP in the Draft EIS

One submission claims that mud waving will create a structure fault where the weir embankment fingers join It also claims that the structure will slip

The possible impact of mud waves on the structure is recognised and is one of the key elements in the c ontrac tor s c onstruc tion method The stab ility of the struc ture is a norma l design issue that is mitigated by using a design review process

The EIS provides all the available knowledge on material sources As the contracting method leaves the material source decisions to the contractor no further information will be available until a contract is awarded

Weir Crest

The MDBA requires confirmation that the temporary weir crest can resist erosion from flow

Response

Specific details for the temporary weir crest design were incorporated in an application sent to MDBA on 15 May 2009 This is not related to the draft EIS or the Supplementary EIS

Pumping

One submission claimed that the option of relocating the pump stations would involve a short timeframe and thus avoid the environmental impacts of constructing a temporary weir

Response

The option of re-locating pump stations is stated in the Draft EIS to involve a risk of continuity of supply The submission has also not recognised that the timeframe for moving a pump station individually upstream of Lock 1 (near Blanchetown) is similar to building a larger pump station upstream of Lock 1 and laying the required connecting pipeline Both options would require feasibility studies and engineering designs as well as the necessary State and Commonwealth approvals and assessments Should an EIS be required for these options it is envisaged that the projects would not be in place to ensure a potable water supply to Adelaide and Regional South Australia within the next two years

Permanent Weir

One submission claimed that impacts of permanent weirs are severe and therefore another weir should not be built on the River Murray

Supplementary EIS for the temporary weir near Pomanda Island -8shy

Response

The impacts have been examined and reported (See for example Draft EIS Section 831) taking into account the temporary nature of the proposed weir The Draft EIS concludes that the impacts of not building the temporary weir when critical trigger points are reached are more signific ant as muc h of South Austra lia s wa ter sec urity is threa tened

Triggers for Removal

A number of submissions claim that triggers are inappropriate because they specify conditions that have not prevailed for more than a decade and that they lack detail and are unlikely to occur within the next decade References are made to water levels in Murray-Darling Basin storages salinity in Lake Alexandrina and general water quality risks in Lake Alexandrina

Response

Triggers

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria as agreed by the Water Security Council and accepted by the MDBA and stated in section 58 of the Draft EIS remain appropriate

Removal of the temporary weir is highly dependant on the seasonal conditions as well as decisions by Murray-Darling Basin Ministerial Council on water sharing water recovery and water allocation policies The South Australian Government has selected a nominal 3 year life for the temporary weir as indicative

Stages

The graph below is available on the MDBA website and shows that storage levels dropped below the long-term average in 2002 and have not exceeded this since that time The time to recover storages to these levels is primarily dependent on inflows and while based on historical data it might take a series of years to recover to average inflows equally it could be much quicker in a single year with high inflow For this reason the life of the temporary weir has been referred to as nominally 3 years

Supplementary EIS for the temporary weir near Pomanda Island -9shy

Salinity in Lake Alexandrina

Similarly the graph below shows historical salinity levels in Lake Alexandrina where the salinity did not increase above 3000 EC (Electrical Conductivity) until 200708 This graph shows salinity averaged at four sites - A4261157 (Milang) A4261158 (West Pomanda Point) A4261133 (Beacon 90) and A4261156 (West Point McLeay)

Water quality in the Lakes is unlikely to improve until additional freshwater flows down the river to either dilute the Lake water or flush it to the sea The third trigger has been purposely expressed as water quality rather than salinity to allow for possible acidification impacts and associated mitigation measures

As fresh water flows eventually increase the salinity level in Lake Alexandrina will initially fall due to dilution and the Lake will fill with freshwater Salinity levels will then fall further as lake water is flushed to the Coorong and the ocean The extent of flushing required to reach the trigger level is dependent on how long the higher flows persist

Salinity measuring locations

One submission suggests that the target of 3000 EC lacks detail on where it is to be measured Another submission suggests that the target on storages should be replaced with a target on-flow to South Australia

Response

The 3000 EC trigger is intended to be a general salinity measurement in Lake Alexandrina Specifying a single measurement location is not appropriate because there can be areas of localised higher salinity and some of the sites where salinity has been measured over many years are now out of the water The intent is to take a rolling 7 day average over the four representative existing sites (Milang Mulgundawa Poltallock and Raukkan) Data from these sites have been collected for many years and existing protocols will be continued As part of these protocols the sampling sites have moved to accommodate the shift in shoreline

The flow to South Australia comprises a combination of ordered water (and South Australias entitlement flow of 1850 GL is in this category) and unregulated flow which is water that cannot be captured in Murray-Darling Basin (MDB) storages normally due to rainfall in the

Supplementary EIS for the temporary weir near Pomanda Island -10shy

lower parts of the catchment It is therefore possible to get high flows in any single year but the MDB storages could still be empty at the end of the year

It is only when the Hume and Dartmouth reservoirs have returned to normal operating levels (and other decommissioning triggers specified in section 58 the draft EIS have been met) that the South Australian Government can have confidence that the temporary weir would no longer be required The MDBA state that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

Decommissioning

A respondent questions how a structure designed for 3 years can be reconciled with a possible continuing drought and the removal triggers

Response

The temporary weir is designed to a nominal three year structural life and is expected to be removed when current drought conditions abate sufficiently with confidence that the improved River Murray flows are sustainable Detailed information on the triggers for decommissioning are specified in section 58 the draft EIS

As indicated in chapter 4 of the draft EIS the Murray-Darling Basin is six years into the worst drought on record It has led to low water River Murray flows over the border No-one knows when the drought is expected to end or how much water is expected to become available so it is necessary to plan for the worst scenario

Modelling

A number of submissions raised concerns about modelling

Water level forecasts may be incorrect due to assumptions about net evaporation There were questions about whether drought is the fundamental cause of the problem considering recent rainfall history in the Murray-Darling Basin

Modelling is only carried out for a period of 3 years despite the unknown length of the proposed operation

That modelling is only reported for an allocation to South Australia of 896 GL

That there is a lack of modelling results for temperature turbidity and acidification

That the temporary weir will cut off low water inflows

That water level modelling is flawed and underestimates local winter inflows

That the temporary weir will stop salts moving into Lake Alexandrina and these salts will be forced back into the River channel and

Further modelling particularly related to a virtual weir was sought

Response

The following graph (Department of Water Land and Biodiversity Conservation 020709) shows the drop in water levels in Lake Alexandrina over recent years The falls are quite uniform and the projections are consistent with recent history The models used have been accurate in projecting water levels to date

Supplementary EIS for the temporary weir near Pomanda Island -11shy

_

Lake Alexandrina Level

-26

-24

-22

-2

-18

-16

-14

-12

-1

-08

-06

-04

-02

0

02

04

06

08

1

0100 0600 1100 0401 0901 0202 0702 1202 0503 1003 0304 0804 0105 0605 1105 0406 0906 0207 0707 1207 0508 1008 0309 0809 0110 0610

Date (monthyear)

Lake

Ale

xand

rina

Wat

er L

evel

(m A

HD

)

Modelling projections have only been made for a period of 3 years because of the low probability of a continued period of extended drought and increasing uncertainty about future management responses Modelling using 896 GL flow over the South Australian border was used as it reflected the water sharing agreement for South Australia This figure is considered the worst case flow into South Australia

Flows to the Lower Lakes are currently determined by the minimum River flow needed to ensure that the maximum salinity at Murray Bridge remains within potable limits The temporary weir will not cut off flows to the Lower Lakes and once the pool behind the temporary weir is filled water will flow over the temporary weir into Lake Alexandrina at the rate of at least 350GL per annum

Modelling does not support the contention that the temporary weir will not prevent saline water from moving upstream into the River channel This is fully described in the Draft EIS

The Draft EIS acknowledged limitations with the model used to predict the movement of saline water in the Lakes but also notes that it provides the best information available and was based on numerous model runs (Refer also to section 443 of the Draft EIS) It is considered that running the models for a broader range of scenarios would not substantially alter the advice on impacts of the temporary weir The salinity model cannot be calibrated to a high level of certainty simply because there is no historic reference The current conditions are outside the bounds of normal lake operation

An adaptive approach will be required for managing the filling process for the pool upstream of the temporary weir to ensure that there is an appropriate balance between the various competing interests This will need to take into account issues such as technical constraints related to the construction program potential environmental impacts on Lake Alexandrina during the period of no flow or low flow to the lake flow requirements for the proposed fishway through the temporary weir and possible impacts on wetlands reclaimed swamp areas levee banks and the river bank as the water level rises upstream of the temporary weir Some of these issues will only become clear as the water level rises and the filling process will need to be adjusted in response to these impacts

It is apparent from the early contractor engagement process that the initial construction method adopted for the modelling described in the draft EIS will be slightly modified due to

Supplementary EIS for the temporary weir near Pomanda Island -12shy

technical constraints In addition a fishway will be provided through the temporary structure As a result of these factors the basic refilling process has been modified from that proposed at the time the draft EIS was published

The current proposal (assuming the inclusion of a fishway through the temporary weir) is to have a minimum dilution attraction flow of 200 MLday past the structure at all times during refilling An initial period of refill of some 2 to 3 weeks is proposed when level will be raised from -15m AHD to -12m AHD and the flow past the temporary weir would be limited to the 200 MLday This will be followed by a period of approximately 25 to 3 months when the level is held at -12m AHD and the passing flow will be approximately 1500 MLday Finally there will be a period of approximately 2 to 25 months as the temporary weir is refilled from -12m AHD to the nominal pool level of +01m AHD and the passing flow will be limited to approximately 200 MLday

However it is proposed that this refill strategy will be modified in response to any impacts arising from the refilling process as identified above

Virtual Weir

A submission suggests models need to be used with caution and asks whether models have been run at lower levels and with salinities less than seawater and what flow past Wellington would be needed to make a virtual weir work

Response

It is agreed that the model used to predict the movement of saline water from Lake Alexandrina to the River channel needs to be used with caution There is limited data with which to calibrate the model

The value of the model is to better understand the mechanisms of how saline water moves upstream and how it is dissipated This information is included in section 443 of the Draft EIS

The model indicates that current flow rates are too low to ensure mixing of fresh and saline water and prevent a saline layer making its way up the River Murray The modelling indicates that flows would need to increase by a factor of 5-10 times before this issue could be resolved As indicated in the draft EIS if this volume of water was available then no saline water would enter the river channel

Since the release of the Draft EIS the MDBA engaged WBM-BMT to undertake further hydrodynamic modelling to investigate the potential for and risks associated with a virtual weir Modelling will incorporate several months of new data and involves a number of new scenarios in respect of water levels lake salinities and wind strength direction and duration

It is anticipated that the outcome of this work will be available progressively during July and August 2009 and will further inform the technical feasibility of implementing a virtual weir

Supplementary EIS for the temporary weir near Pomanda Island -13shy

4 Supplementary comment on expected impacts of the temporary weir on soils and water

Introduction

The draft EIS involved discussion of soil and water quality impacts within many sections of most chapters The chapters specifically detailing soil and water quality impacts were

Chapter 8 Potential impacts of the proposed temporary weir

Chapter 10 Changes in water levels and salinity

Chapter 11 Soil and Water quality impacts

A significant number of submissions and government responses to the draft EIS included comments related to soil and water quality Government agencies such as the Environment Protection Authority (EPA) the Department of Water Land and Biodiversity Conservation (DWLBC) MDBA and the SA MDB NRMB have suggested changes in the light of new data or further information DEWHA has requested further clarification

Submissions received and responses

The major points raised by the submissions are detailed below along with responses involving a discussion and conclusion in regard to the points raised

Acid Sulfate Soils (ASS)

Submissions raised the following questions and concerns

Who is completing monitoring for alkalinity in Lake Alexandrina and where is monitoring data being stored Can the public or other agencies access this data

The lack of information about rates of acidification and potential release of metals (and metalloids) the mobilisation and flushing of acidity and associated contaminants (for example metals nutrients) to the water and the impacts of ASS and acidification on the ecology and ecological processes for example risks to species

The need to make more use of the considerable experience from elsewhere when dealing with ASS

The need to study acidity risks and environmental impacts associated with rewetting of wetlands upstream of the temporary weir

The need for information and data on hydraulics relating to flow cessation into Lake Alexandrina and sea water introduction and acidification thresholds

Not enough information on immediate and long-term implications of building the temporary weir (for example medium to low confidence in modelling of tipping point for acidification)

The need for additional modelling of acid and metal release

The need to address remedial actions necessary in the Lakes because of the accelerated decline in water level

Quantification of the risk of acid mobilisation upon re-wetting of River channel wetlands upstream of the weir site in general more consideration is needed to be given to these water bodies and

What are the mitigation measures planned if alkalinity levels reach 25mgL CaCO3

Response

As indicated below independent advice from leading international and Australian ASS scientists has been sought in order to increase knowledge on sulfide oxidation rates generation of contaminants (for example metals and nutrients) transport mechanisms and neutralisation dynamics

In 2008 the South Australian Government commissioned several reports into acidity metal mobilisation and water quality risks for the River Murray and Lower Lakes and it is further

Supplementary EIS for the temporary weir near Pomanda Island -14shy

prioritising investigations to assist with ASS mitigation and management options such as bioremediation

Such investigations can take from several months to years but once more information is available the models underpinning acidity and metal mobilisation impacts for this region can be better refined

Since August 2008 the SA MDB NRMB has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (for example sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (Report 1 March 2009 Available May 2009 wwwepasagovau) The EPA also compiles the raw data in a spreadsheet available to South Australian Government agencies

Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on the potential impact refilling wetlands will have on water quality of the Main River channel and the ecological impact of further acidification of wetlands

The

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes

Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the Murray-Darling Basin Authority Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from a DEH project identifying acidification remediation options for the Lower Lakes

Construction of regulating structures and other on-ground works for remediation at priority wetlands

Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRMB is managing the Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t with a steering c ommittee of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRMB DEH DWLBC MDBA SA Water Corporation EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of +01m AHD An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of the wetlands will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island for example wetlands providing important aquatic refuges

Conclusion

In conclusion it is agreed that the impact to River channel wetlands is an important issue that needs to be managed This is true irrespective of whether a temporary weir is constructed or

Supplementary EIS for the temporary weir near Pomanda Island -15shy

not Measures are already in place to minimise the risk to water quality in the River channel Refilling these wetlands will provide important aquatic refuges

The submissions on acid acidity and ASS support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible and be fed back into the ongoing planning and measures undertaken

In the meantime it is noted that there is extensive experience in dealing with ASS elsewhere Leading international and Australian ASS scientists with industry specialists have been contacted to provide independent advice and an ASS risk workshop involving many of Austra lia s soil and hyd rology sc ientists was rec ently held for the Lower Lakes If a lka linity levels reach 25mgL CaCO3L immediate mitigation measures such as limestone slurry dosing of the water in affected areas are expected to be undertaken

Recent information on ASS bioremediation and dust issues for the Coorong Lower Lakes and Murray Mouth reg ion is ava ilab le from the South Austra lian Government s Environment web page httpwwwenvironmentsagovaucllmmfaqs-acid-sulfate-soilshtml

Water quality

Wind seiche

There were a number of submissions in regard to wind seiche impacting on water quality at the pump intakes Concerns included

Some suggested that the remaining area of the Lake above the temporary weir (weir pool) would still be large enough to allow significant wind seiching to occur Due to low inflows and a large weir pool surface area salinity would increase in the weir pool and these seiching events would still have the capacity to drive the saline water within the weir pool upstream to the pump intakes

It was suggested that the temporary weir will effectively impede if not completely stop the wind seiche effect across Lake Alexandrina and into the River thus stopping the mixing of the water in the River and substantially increasing the risk of algal blooms

It was suggested that the impact of wind seiche in the weir pool is not fully understood and

Concern was expressed about cutting off seiche events into the lower Murray providing nutrients and oxygenated water from Lake Alexandrina Seiching events also allow transport of pollutants to the Murray Mouth and may build up in the weir pool when there are inadequate seiche effects

Response

Wind seiche is believed to be an important part of the ecosystem within the lower reaches of the River Murray It is a transport mechanism for both up and downstream transporting oxygenated nutrient rich water from Lake Alexandrina into the lower reaches of the River and allowing flushing from the channel of excess nutrients and salt Additionally it provides variability in water levels important for the life cycles and habitat of some native species

If the River system and Lower Lakes were experiencing normal flows and water levels then the temporary weir would reduce the effects of seiche events At the proposed trigger level to install the temporary weir (-15 m AHD) the connection of Lake Alexandrina to the River channel will be minimal reducing the effects of wind seiche As indicated in section 443 of the draft EIS this is partly due to the natural bathymetry of the river channel where it connects to Lake Alexandrina

Modellers have incorporated the effects of winds seiche including those modelling scenarios with a temporary weir in place There are also real world examples The draft EIS made a comparison between seiche effects above and below Lock 1 and noted that the effects were less pronounced above the lock Additionally BMT-WBM modelling indicates that by December 2010 under ongoing low flow conditions both scenarios with and without a temporary weir show a marked drop in the effects of wind seiche and there is little difference between the two scenarios

The draft EIS also stated that the effects of wind seiching are expected to be reduced by approximately 50 with the temporary weir This is because the temporary weir will decrease

Supplementary EIS for the temporary weir near Pomanda Island -16shy

the effects of wind seiche within the River channel by disconnecting it from Lake Alexandrina which supplies a large amount of momentum for water seiching up the lower River Murray

Any water from Lake Alexandrina that did manage to travel up channel will also be highly saline acidic and have high concentrations of metals Currently water does not flow over the barrages and out the Murray Mouth and would not at the trigger level of -15m AHD The shoreline of much of Lake Alexandrina would in fact be kilometres north of the barrages by this stage

With a temporary weir in place flows over Lock 1 will continue supplying a constant source of freshwater in the weir pool helping to keep salinity low within that pool Additionally the temporary weir will prevent the transport of saline acidic water from Lake Alexandrina into the River channel These effects along with the reduction in wind seiche will ensure salinity and contaminants at the pump intakes are minimised However the reduction is unlikely to remove all wind seiche effects creating enough movement to reduce the risk of algal blooms and oxygenate the water

Conclusion

The effects of the temporary weir need to be considered in the context of what the situation will be when it is proposed that the temporary weir will be installed that is at a water level of -15 m AHD in Lake Alexandrina While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes Some effects such as blue-green algae formation and potential reduction in oxygen levels upstream of the weir pool (due to reduced flow velocities over the temporary weir itself) whilst undesirable can be managed by the treatment plant whereas other poor water quality (such as metal releases due to acid sulphate soil effects potentially created in the Lakes) would be more difficult to treat Oxygen levels may fall within the weir pool due to the reduction in seiche events and a lack of oxygenated water from Lake Alexandrina however some seiching and wind action will still occur within the wide weir pool reducing the likelihood of anoxic conditions from occurring

Impacts upon Coorong and Lake Albert

A number of submissions raised questions about the impacts on the Coorong and Lake Albert from the temporary weir

Response

These submissions are noted however the proponent contends that the Draft EIS contains sufficient evidence that conditions in Lake Albert and the Coorong will be unaffected by construction of the temporary weir The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170 mm only occurs during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD (including Lake Albert and the Coorong) is not a direct impact of the temporary weir It is therefore beyond the scope of the draft EIS

The draft EIS considered that impacts of the temporary weir on the Coorong and Lake Albert were not considered significant This is because at the time of the weir closure the surface water elevation of Lake Alexandrina will be below sea level preventing any movement of water to Lake Albert and through the barrages to the Coorong The introduction of a temporary weir will not change this situation

Since May 2008 water levels in Lake Albert have been maintained artificially at an approximate height of - 05 m AHD by pumping from Lake Alexandrina Continued low River Murray flows have made this practice unsustainable and funding for pumping ceased on 30 June 2009 as noted by the MDB Ministerial Council on 12 June 2009 The cessation of pumping in June 2009 will lead to a gradual lowering of the level of Lake Albert The introduction of a temporary weir will not change this situation

Supplementary EIS for the temporary weir near Pomanda Island -17shy

Conclusion

At the trigger level for the construction of the temporary weir the Coorong and Lake Albert waters will be disconnected from Lake Alexandrina so changes to soil and water quality are not significantly impacted on by the temporary weir

Dredging of Murray Mouth

The issue of whether the dredge at the mouth of the Murray will remain there if the temporary weir is put in was raised

Response

The Murray Mouth is the only site where water contaminants such as silt salt and nutrients can exit the Murray-Darling Basin There has been no significant release of water from the Lower Lakes via the barrages since November 2005 and connection at the Murray Mouth has been dependent on dredging

The dredging program should only be regarded as a temporary measure Increased environmenta l flows a re the Murray s only solution in the long term if we are to keep the mouth open and maintain the health of the Coorong

Water quality impacts near Narrung Narrows

Submissions suggested that conclusions on water quality impacts from the construction of a blocking bank at the Narrung Narrows need revising in the light of additional monitoring data

Response

The construction of the blocking bank took 16 days to closure after commencing on 16 April 2008 Water quality parameters were monitored before during and after construction but revealed little impact with fluctuating turbidity levels likely due to the effects of wind as shown historically in figure 11-5 of the draft EIS There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid once water levels rose Alkalinity concentrations showed little change during and after the construction

Turbidity

The EPA has undertaken monitoring at locations around Lakes Alexandrina and Albert since the commencement of the construction of the Narrung Narrows blocking bank EPA water quality monitoring reports p repared for the b loc king bank p rojec t s steering c ommittee noted tha t some localised turbidity impacts were observed but this did not translate into widespread impacts in Lake Albert Figure 11-7 (below) shows turbidity readings for five locations and demonstrates that there is little correlation between the installation of the blocking bank the subsequent pumping and turbidity in both Lakes The variability in turbidity is principally related to climatic conditions at the Lakes For example the Lakes are shallow and the area experiences wind events which regularly create turbulence which is able to mobilise sediments thus increasing turbidity The spike at Meningie in December 2008 is not likely to be related to the blocking bank as it is nearly six months after construction

Supplementary EIS for the temporary weir near Pomanda Island -18shy

Turbidity at Monitoring Stations near the Narrung Narrows

0

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120408 70508 10608 260608 210708 150808 90908 41008 291008 231108 181208 120109 60209 30309 280309

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Lake Albert - 1km offshore Meningie jetty Lake Albert - Near narrows 3km NE of Reedy point

Lake Albert - Near water level gauge 11km N of Meningie Lake Alexandrina Poltalloch

Lake Alexandrina - Beacon 90

Figure 11-7 Turbidity (NTU) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Acidity

Water column pH has remained relatively constant with readings predominantly between 86 and 89 (Figure 11-8 of the Draft EIS) There was a pH drop in Lake Albert at the time of completion of the blocking bank with the closest monitoring point recording a pH of 79 These lows were recovered to normal levels within the month after pumping commenced

These results show there may be some localised effects to pH through the exposure of sulfidic sediment However the buffering capacity of the water and the quantity of exposed sulfidic sediment reduce the risk to the effects of pH to the Lake as a whole

pH at Monitoring Stations near the Narrung Narrows

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120408 10608 210708 90908 291008 181208 60209 280309 170509

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-8 pH at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Supplementary EIS for the temporary weir near Pomanda Island -19shy

Alkalinity

All stations with the exception of the Lake Albert station closest to the blocking bank have had relatively constant alkalinity concentrations The largest decrease in pH did not correlate with a reduction in alkalinity however later reductions in pH in August and November 2008 and January 2009 did Due to the continued exposure of sulfidic sediments over this time it is unlikely the effects are due to the blocking bank construction

Alkalinity at Monitoring Stations Near the Narrung Narrows

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120408 10608 210708 90908 291008 181208 60209 280309 170509

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-9 Alkalinity (mgL) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Conclusion

Water quality parameters were monitored before during and after the construction of the Narrung Narrows blocking bank and monitoring revealed little impact with fluctuating turbidity levels likely due to the effects of wind There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid Alkalinity concentrations showed little change during and after the construction

Algal blooms

There were many concerns about possible increases in algal blooms within the weir pool through reduction in flows and nutrient fluxes impacting on water quality

Response

The risk of algal blooms in the River is influenced by a number of interacting factors including weather conditions flow and turbulence and nutrient supply It is therefore not possible to precisely predict the extent and intensity of blooms However it is generally accepted that blue-green algae are favoured by waters with reduced turbulence reduced turbidity and increased nutrients A change to turbulence only increases the risk if sufficient nutrients are present to support the bloom The reduced flow in the River as a result of the drought will increase the likelihood of algal blooms The temporary weir will also reduce the flow and turbulence during the weir pool filling period and may therefore also tend to increase the risk of algal blooms Precise prediction of the frequency and intensity of algal blooms is not possible but it could be expected to be similar to the permanent structures upstream

Supplementary EIS for the temporary weir near Pomanda Island -20shy

There is a range of information mainly from studies overseas that lakes and rivers that experience frequent andor prolonged algal blooms display an array of ecosystem properties that may have impacts on water quality biological communities and ecosystem services

Some impacts of algal blooms may be direct including possible effects of toxins on fish invertebrates and other aquatic fauna or indirect including a reduction of submerged plants when plankton biomass becomes very high and changes in fish community structure due to hypolimnetic anoxia In lakes with dense blooms of blue-green algae accumulation of organic material in lake sediments and increased bacterial activity also may lead to anoxic conditions that alter the structure of benthic macro invertebrates Despite numerous case studies and a vast literature on species specific responses community level effects of blue-green algal blooms are not well understood

It must be noted however that these potential changes are associated with highly eutrophic environments that have frequent and persistent and often massive algal blooms These conditions are relatively extreme and unlikely to be encountered for extended periods in the River provided projected flows are maintained

The lower River Murray and other surface water storages within the Murray-Darling Basin regularly experience minor algal blooms due to seasonal stratification and periods of low flow These blooms have not been associated with the types of potential environmental effects that occur in the degraded systems with persistent blooms A case in point is the recent short-lived but highly visible bloom in the River Murray in NSWVictoria downstream of Hume Dam

It is not possible to make a precise prediction of the impact of the temporary weir on the risk of blue-green algal blooms However it is expected that the impacts will not be significant and will be similar to those in the permanent structures up stream

The water treatment plants in South Australia all have the capacity to remove algal cells and the toxins taste and odours that they produce and are able to mitigate any detrimental effects of algal blooms on water supplies

Summary of water quality impacts

One submission highlighted that the summary of water quality impacts in Chapter 11 of the draft EIS did not include all of the impacts to water quality particularly salinity

Response

The construction of the blocking bank at the Narrung Narrows was examined to determine what impacts on water quality if any were identified during and after construction of the blocking bank Using the blocking bank as an example it is expected that the construction of a temporary weir near Pomanda Island may have impacts on water quality both up and down stream

Water quality issues which may result within the weir pool include a reduction in flow velocity an increase in temperature and evaporation and a decrease in dissolved oxygen levels and in the effectiveness of wind seiche events to provide mixing and transport of salt nutrient and contaminants This may lead to temperature and salinity stratification and an increase in blue-green algal blooms in the weir pool It is expected that these impacts will be similar to those relating to the permanent structures that already exist in the River Murray up stream from Lock 1 and that the potential environmental risks will therefore not be significant

The construction of the temporary weir itself will create localised sediment waves as material placed in the River channel displaces sediment This sediment wave is likely to contain sulfidic materials that will oxidise and form acid Based on the experience of the Narrung Narrows blocking bank the provision of mitigation and management measures as outlined in the CEMP is adequate It can be expected that there will be localised impacts to turbidity pH and alkalinity but minimal effect at a distance

Once the weir construction is complete there will be a reduction in inflows to Lake Alexandrina while the weir pool is filled (see page 13 -14) Modelling indicates that during this time there will be a temporary increase in salinity in the waters of Lake Alexandrina However it has indicated that in the long-term the d ifferenc es in sa linity between the weir and no weir op tion under continued low inflows become insignificant

Supplementary EIS for the temporary weir near Pomanda Island -21shy

The reduction of flow during the filling of the weir pool (see page 13-14) predicts the volume of water in the Lake such that a further 5200 ha of sulfidic soils are exposed in Lake Alexandrina under the worst case scenario This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage ASS will need to be implemented across the Lake in this case

When these impacts are compared to the conditions likely to be present when water levels reach triggers for the temporary weir to be installed at viz 15 m AHD it is likely that the impacts of the temporary weir on water quality in Lake Alexandrina will be an increase in salinity for up to 3 months and bringing forward a potentially rapid pH reduction in Lake Alexandrina by 2 to 3 months For a detailed discussion of likelihood of Lake Alexandrina acidifying during the no flow period refer to Appendix 1 Question 7

For a detailed discussion of reasons underlying the 25 to 3 month disconnect of Lake Alexandrina refer to Appendix 1 Question 9

Connectivity of Surface and Ground Waters

Surface Waters

A few submissions questioned what the tributaries of Lake Alexandrina were and when they would disconnect

One submission was received stating that the drop in water level predicted to occur as a result of building the temporary weir should not have been expressed as an average but as a range

Response

There are four tributaries from the Eastern Mount Lofty Ranges (EMLR) to Lake Alexandrina namely

Angas River

Bremer River

Currency Creek

Finniss River

The surface waters of these tributaries will be disconnected at -15m AHD from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into the Lake and were the first to disconnect at a water level between +01 m and + 03 m AHD The Angas and Bremer have been disconnected since 2007

At times of medium to high outflow from these tributaries there is likely to be some reconnection of surface water with or without the temporary weir

The South Australian Government commenced construction of a temporary environmental flow regulator at Clayton in June 2009 The Goolwa Channel (and Currency Creek and the Finniss River tributaries) will be disconnected from Lake Alexandrina during construction of this regulator (EPBC Reference No 20094833)

The figures in Chapter 10 of the draft EIS show a selection of graphs of predicted water level impacts of the temporary weir From these the greatest reduction in water level during the weir pool filling phase in the first year is shown to be approximately 210 mm near the tributaries (points 63 and 64 Figures 10-13 and 10-14)

Conclusion

All tributaries except the Goolwa Channel are now disconnected from Lake Alexandrina and will remain so with or without a temporary weir

The construction of an environmental low flow regulator at Clayton will disconnect Currency Creek and Finniss River from Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -22shy

Reconnection of surface water in Angas and Bremer Rivers with Lake Alexandrina is likely at times of medium to high outflow from these tributaries This situation is unlikely to change with the construction of the temporary weir

Groundwater

A few submissions questioned the detail on surface waters and groundwater interactions

Response

In terms of groundwater connection it is assumed that the sediments in the tributaries and Lake Alexandrina will have some hydration from groundwater even at water levels of less than -28 m AHD

During development of the EIS DWLBC hydrogeologists were consulted on whether the p red ic ted dec rease in Lake Alexandrina s water level of 210 mm near the tributa ries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the drought induced water level drop which has already occurred

Conclusion

Tributaries are likely to remain connected to Lake Alexandrina through groundwater at levels less than -28 m AHD and the 210 mm difference in water level induced by the construction of a temporary weir is unlikely to have a significant impact on groundwater flux

Supplementary EIS for the temporary weir near Pomanda Island -23shy

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels

Introduction

Submissions discussed in this Section relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir as outlined below The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

Another issue of concern raised by many submissions and respondents is the potential impact of increased salinity within the Lower Lakes upon aquatic biota The following discussion adds considerable detail relating to predicted salinity changes and the likely biotic response endeavouring to provide greater breadth and clarity around this issue

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Upstream impacts

Impacts of altered water regime in weir pool

Several submissions argued that conditions in the weir pool created upstream of the temporary weir would favour exotic species such as Common Carp and disadvantage native species including EPBC Act-listed species such as Murray Cod Such an impact would be contrary to the goa ls of the MDBA s Native Fish Stra tegy

There was also a concern that flora species such as the common reed cumbungi and willows (an introduced species) in the riparianlittoral zones might respond in a way that could impact on matters of NES

Response

aspec ts of the p roposed temporary weir tha t interac t with ray-finned fishes of NES (page 15-13) should be expanded to include The list of

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

The list of potential impacts of the temporary weir upon aquatic fauna (Section 15415 pages 15-24) should be expanded to include

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

Advice from the South Australian Research and Development Institute (SARDI) Aquatic Sciences is that mitigation of improved spawning conditions for Common Carp in the Pomanda Island weir pool is not practical due to the scale of the issue Similarly measures to promote spawning of Murray Cod in the weir pool are not practical The potential impacts of the temporary weir upon EPBC Act-listed fishes in the River Murray channel upstream of the

Supplementary EIS for the temporary weir near Pomanda Island -24shy

temporary weir due to altered hydrology and increased exotic fish abundance appear to be unavoidable

The following aspec ts of the temporary weir tha t interac t with ripa rian flora such as Phragmites (common reed) Typha (cumbungi) and willow (introduced species) in the upstream wetlands and consequent effects on matters of NES (fauna) should be taken into consideration

The vegetation type and distribution in the upstream wetlands is expected to change due to the change in water level from (historic) +05m AHD - +08m AHD to a new level of +01m AHD and reduced wind seiche noting that current water levels are substantially lower than this

The change to a shallower wetland regime is expected to favour Phragmites and Typha which are invasive

The impact of changed vegetation pattern on matters of NES (EPBC-listed fish and birds) is expected to be negligible considering their preferred habitat

The impact of changed vegetation pattern on the EPBC-listed Southern Bell Frog is expected to be either to maintain or improve the preferred habitat for breeding

Impacts to Pelican Lagoon and Nalpa Station

Several submissions raised concerns regarding Pelican Lagoon and wetland habitats on Nalpa Station Pelican Lagoon is a large fringing wetland located directly upstream from the temporary weir site Previous surveys at the wetland and the Nalpa property have determined the area to be a biodiversity hot-spot hosting significant species such as the southern bell frog southern pygmy perch white-bellied sea eagle golden-headed c istic ola Lewin s ra il Australasian shoveler and various aquatic plant species As the wetland has been dry since early 2007 there is an inherent assumption that these species are lost therefore the impact of the temporary weir can be negated However further impacts upon these species are possible

Response

It would be desirable to resurvey the area particularly the small inundated area from which stock and domestic water are accessed to determine which species of significance remain and what measures can be taken to protect them

The local landholders have also shown an interest in undertaking management actions for the betterment of the wetland environment Support could be provided in the form of a wetland management plan for the site to determine the most effective way to manage the wetland

Weir Footprint Impacts

Impacts of Habitat LossDegradation

Several submissions argued that potential impacts to flora and fauna due to the clearance or disturbance of vegetation at the weir construction site were understated or unclear These flora and fauna included EPBC Act-listed species Among the fauna of concern were the Southern Bell Frog Orange-bellied Parrot La tham s Snipe (Gallinago hardwickii) White Bellied Sea Eagle and Great Egret Flora of concern included Phragmites australis Typha domingensis Senecio longicollaris Shrubby Groundsel (Senecio cunninghamii var cunninghamii) purple Loosestrife (Lythrum salicaria) and a range of samphire species

Response

A native fauna and flora survey of the approach works footprint and the subaqueous weir footprint was conducted by ecological consultants in SeptemberOctober 2008 (Ecological Associates 2008) Habitat impacts in the immediate weir footprint area were identified to be minimal

It is highly likely that the temporary weir will cause the loss of some of the reed beds at or near the construction site through physical disturbance

Supplementary EIS for the temporary weir near Pomanda Island -25shy

Impacts of mud disturbance upon salinity

One submission claimed that mud disturbance around the temporary weir site during construction would turn the water saline and impact on all fish species

Response

There is no available data which suggest that disturbance of submerged sediments can lead to an increase in the salinity of surface water

Impacts upon fish migration

A significant number of submissions argued that the temporary weir may impede upstream and downstream movement of juvenile and adult fish including EPBC Act - listed species and that this is an unacceptable impact upon upstream and downstream ecosystems and commercial fishing activities

Response

Due to concerns raised in submissions about the lack of a fishway (fish passage) a process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species

SARDI has indicated that it has sufficient knowledge to be able to design a fishway without the need for further site survey work SA Water Corporation is working with SARDI to design a suitable fishway into the temporary weir

SA Water Corporation is progressing a concept design for a fishway in the temporary weir with URS Australia

The concept design for the fishway is expected to be completed in July 2009 and a draft Concept Design Report should be available before the end July 2009 The report will include sketches of the concept and will also show the impact on the temporary weir design

The concept (although still to be finalised and confirmed) is for a rock ramp fishway in the centre of the temporary weir at the western end of the spillway This position places the fishway as close as possible to the deep channel to the west near Pomanda Island The rock ramp would be around 50 metres wide and slope downstream on a 130 gradient The deep centre section would be a metre deep (at full pool level) and the sides of the ramp would slope upwards to provide shallower and slower paths for smaller fish Stop logs at the top of the ramp will allow dewatering of the fish passage

Although the impacts on the temporary weir design will not be certain until the concept design is finalised the indicative impacts of such a concept include the following

The fishway hydraulic design will maintain an upper weir pool water level of 00m AHD with a flow of 600 MLday

A small auxiliary spillway is needed adjacent to the fishway to provide an attraction flow and this will pass 360 MLday the remainder of the average daily flow of 960 MLday (350 GLyear)

At a flow of 960 MLday the upper weir pool will be +01 m AHD with the fishway open (ie identical to the no fish passage design)

At a flow of 1200 MLday the upper weir pool will be +017 m AHD with the fishway open

For automatic operation the bottom of the auxiliary spillway will be inclined from +01 m AHD to +02 m AHD between the fishway and the main spillway

The main spillway crest will be raised to +02 m AHD to ensure that average daily flows remain confined to the fishway and auxiliary spillway Initially a spillway level of +01 m AHD had been established as the upper pool level to be retained by the weir

Supplementary EIS for the temporary weir near Pomanda Island -26shy

However the desire to have a ll flow pass through the fishway during norma l river flow that is 960 Mlday with the upper pool level maintained at +01 m AHD necessitates a reconfiguration of the main spillway of the temporary weir

The main spillway will be slightly shorter (around 1150m wide instead of 1200m wide) so that the fishway can be constructed on the western edge of the better foundation material

To ensure that water entering the downstream pool from either the fishway auxiliary spillway or main spillway remains continuous and provides an attraction path to the fishway the centreline of the auxiliary spillway and main spillway will be moved slightly downstream between the fishway and the eastern abutment

The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Impacts of noise upon wetland birds

One respondent sought clarification on the level of noise the weir construction is anticipated to create given that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB as stated in the Draft EIS

Response

There are no wetlands on the eastern side near the abutment It is anticipated that any areas around Low Point populated by birds will receive noise levels similar to that from a busy highway The same will apply to the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels which would presumably cause them to move further north into the wetland area

Monitoring during constructiondecommissioning

A number of submissions questioned how the Monitoring of EPBC-listed spec ies referred to on page 15-24 of the Draft EIS will ensure that construction operation and decommissioning activities do not impact on EPBC-listed species More information was sought on the fauna inspection to be carried out in the construction area before any vegetation clearance (Table 15-9 on pp 15-2526 of the Draft EIS)

Response

Monitoring during operation of the temporary weir will be coordinated as part of the SA MDB NRMB s na tura l resource condition monitoring program It will include additional monitoring efforts as per expert advice

of the EPBC-listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life and breeding cycles The monitoring focus will be of an observational nature in regards to compliance monitoring This is to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by the Commonwealth and the South Australian Native Vegetation Council) and that the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora and fauna expert advice if warranted In addition the Contrac tor s EMP will identify based on a risk assessment whic h spec ific mitiga tion and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations needs to be recorded

It is rec ognised tha t the monitoring

A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water Corporation and DEH (Ecological Associates 2008) This knowledge has been considered by the Commonwealth More specific instructions on how this can be used will be included in the CEMP The project will ensure that expert advice is available throughout the duration of the construction phase

Supplementary EIS for the temporary weir near Pomanda Island -27shy

Timing of construction and presence of migratory species

One respondent commented that the Draft EIS did not appear to consider the interaction between the timing of construction and the presence of migratory species eg Orange-bellied Parrot potentially present from March to early November

Response

The Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to help protect Orange-bellied Parrots might however impact on other species Migratory shorebirds for example return in late August and spend the entire summer at the site

Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coorong_S urvey_lowpdf

Downstream impacts

Impacts of water level changes upon aquatic vegetation

A respondent noted that in Section 1246 on page 12-11 of the Draft EIS under the heading Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion are

considered insignificant as many of these species reproduce sexually and through wind or bird-d riven seed d ispersa l This is only a c onsidera tion of impac ts upon rep roduc tion not a consideration of whether the plants will even survive to reproduce

Response

Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately +035 m AHD At a water level of -15 m AHD (when the temporary weir would close) this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the water body and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long-term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the Lake be refilled with freshwater to its pre-drought level (+05 to +08 m AHD) while the below-ground storage organs remain viable

Impacts of temporary increase in salinity upon aquatic biota

A significant number of submissions raised concerns regarding the impact of the temporary weir upon salinity in the Lower Lakes and consequent impacts upon biota There were also concerns that not all Matters of NES potentially impacted by the temporary salinity increase caused by the temporary weir had been adequately addressed One submission predicted the salinity increase would cause a mass die-off of Common Carp which would lead to poor water quality in Lake Alexandrina

Response

The scope of the EIS dictates that it consider the impacts of the temporary weir upon biota that are listed as threatened under the EPBC Act or that contribute to the ecological character of the Coorong Lakes Alexandrina and Albert Ramsar site These include all of the freshwater diadromous and estuarine fish species of the freshwater units (Lower Lakes) as well as a large number of bird taxa many of which are piscivorous (Phillips and Muller 2006) Taxa other than fish and birds need only be considered by the EIS if impacts upon them are likely to be transferred into a significant impact upon fish or bird communities

Supplementary EIS for the temporary weir near Pomanda Island -28shy

The impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake (Fig 10-5 in the Draft EIS) The salinity of Lake Alexandrina is predicted to be higher than both the limits of acceptable change (700 EC (Phillips and Muller 2006)) and the typical seasonal maximum (1500 EC) from January 2010 onwards at all loc a tions under both the weir and no weir sc enarios Modelling shows tha t the d ifferenc e in salinity in Lake Alexandrina (modelling assuming continued pumping to Lake Albert however on 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009) under the weir and no weir sc enarios va ries with location At all sites modelled salinity is similar in early 2011 one year after weir construction under both the weir and no weir sc enarios (Sec tion 10) However immediately following weir construction a temporary increase in salinity three to five months in duration is predicted at most sites The magnitude of the salinity increase varies between sites but is pronounced at several sites

A salinity threshold that is important in terms of the maintenance of ecological character is the salinity tolerance of the resident native freshwater fish species of the Lower Lakes Salinity tolerance varies between species but for the temporary weir to have no significant impact upon native fish species its construction should not cause salinity to exceed the tolerance of the most salinity-sensitive species

Several species of rare or threatened small-bodied native freshwater fish that are resident in the Lower Lakes under pre-drought water levels (+04 to +08 m AHD) are unlikely to be present in Lake Alexandrina at a water level of 15 m AHD Yarra Pygmy Perch have probably become locally extinct in the CLLMM as a consequence of the current low water levels (Bice and Ye 2009) Mountain Galaxias Murray Rainbowfish and Southern Purple-spotted Gudgeon are all very rare possibly extinct from the CLLMM with no records for a number of years (Bice and Ye 2009) All of these small-bodied species are associated with fringing aquatic vegetation They are unlikely to be present in Lake Alexandrina when water levels have declined to the extent that all fringing aquatic vegetation has become disconnected from the water body

Prior to the drought the only part of the Coorong Lower Lakes and Murray Mouth where River Blackfish had been recorded were the upper reaches of the Eastern Mt Lofty Ranges tributaries that enter Lake Alexandrina (Bice and Ye 2009) The species prefers permanently flowing freshwater streams with cool clear water where it is strongly associated with the in-stream cover habitats provided by undercut banks and boulders (Khan et al 2004) It is unlikely to be present in the open water habitat of Lake Alexandrina that is disconnected from fringing aquatic vegetation and other forms of cover

A number of short-lived (lifespan generally 3 years or less) small-bodied native freshwater fish species could potentially be present in Lake Alexandrina when the water level reaches

15 m AHD These species are dependent upon fringing or benthic aquatic vegetation during part of their lifecycle particularly egg and larval stages (Lintermans 2007) with the exception of Australian Smelt which is a more pelagic species Therefore conditions in Lake Alexandrina are likely to be unfavourable for their persistence due to the disconnection of fringing vegetation and the water body Although unlikely it is possible that these species may persist providing important remnant populations that could potentially increase in abundance and repopulate the Lake when water levels return to pre-drought levels Due to their brief lifespans the salinity tolerances of all stages of the life cycle are relevant to the potential impacts of the temporary weir upon them Egg and larval stages typically have the lowest salinity tolerance (Bice and Ye 2009) Because breeding occurs in spring and summer for most of these species (Lintermans 2007) the summer-autumn timing of the short-term increase in salinity levels caused by weir construction could have implications for breeding success and thus persistence of these short-lived species in the Lower Lakes The species and salinity tolerances of their most salinity-sensitive lifestage are Southern Pygmy Perch (15500 EC (adult tolerance - egg and larval tolerance not known)) Murray Hardyhead (80000 EC (low confidence)) Carp Gudgeon complex (9800 EC) Flat-headed Gudgeon (19200 EC) Dwarf Flat-headed Gudgeon (10800 EC) Australian Smelt (92200 EC (adult tolerance - egg and larval tolerance not known)) and Unspecked Hardyhead (68300 EC (adult tolerance - egg and larval tolerance not known)) (Bice and Ye 2009)

The large-bodied native freshwater fish of Lake Alexandrina all have a lifespan of at least several years Thus a short-term (three to five month) increase in salinity that exceeds the tolerance of eggs or larvae does not represent a significant impact to the species if adults are unaffected and can subsequently successfully reproduce when salinities return to tolerable

Supplementary EIS for the temporary weir near Pomanda Island -29shy

levels for sub-adult life stages Large-bodied native freshwater fish species potentially present in the Lake Alexandrina at a water level of 15 m AHD and their respective adult salinity tolerances are Murray Cod (24 500 EC) Silver Perch (25 000 EC) Eel-tailed Catfish (28 000 EC) Golden Perch (Callop) (51 500 EC) and Bony Herring (54 500 EC) (Bice and Ye 2009)

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9) Thus construction of the temporary weir causes salinity to shift from tolerable to intolerable for the eggs or larvae of Carp Gudgeon complex Dwarf Flat-headed Gudgeon and possibly Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead Although the period of intolerable salinity is temporary it will lead to declines in their abundance in the Lower Lakes There are no modelled sites at which salinities will shift from tolerable to intolerable for large-bodied species

Carp Gudgeon complex Dwarf Flat-headed Gudgeon Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead

Declines or complete loss of small-bodied native freshwater fish

from Lake Alexandrina if this occurs is anticipated to be temporary All of these species occur in the River Murray channel and their downstream migration past the temporary weir (which is to feature a fishway) into the Lower Lakes is anticipated to recommence following the period of reduced flow (see page 13) during weir construction Therefore any declines in abundance due to the short-term increase in salinity levels associated with weir construction are likely to be temporary

Adult Common Carp have a salinity tolerance of ~23 500 EC (Bice and Ye 2009) Modelling indicates that the temporary increase in salinity levels caused by weir construction will not cause salinity to increase from tolerable to intolerable for adult Common Carp at any site Most of Lake Alexandrina will remain below the salinity threshold for this species Therefore the temporary increase in salinity caused by the temporary weir is not anticipated to cause a mass die-off of Common Carp or associated water pollution

Recently collected data puts the above discussion into context Fish surveys conducted during weeks 13 17 April 2009 in the Goolwa channel (between Clayton and Goolwa barrages) indicated the obligate freshwater fish community of this area of the Lower Lakes was composed primarily of three species Australian Smelt Flat-headed Gudgeon and Bony Herring (SARDI unpublished data) Salinities at Clayton during the same period ranged from ~18000 to ~24000 EC (DWLBC 2009) These three species are clearly able to persist in the Lower Lakes despite loss of connectivity with fringing aquatic vegetation and elevated salinity Their persistence indicates that both their habitat and feeding requirements are met When the water level in the main body of Lake Alexandrina falls to 15 m AHD triggering weir construction it is likely that the obligate freshwater fish community will be comprised primarily of these three species The temporary increase in salinity levels anticipated will not lead to salinities in excess of those that these species are currently experiencing in the Goolwa channel

The above discussion illustrates that the temporary increase in salinity levels caused by the construction of a temporary weir near Pomanda Island is unlikely to have a significant impact upon the resident native freshwater fish species of the Lower Lakes The temporary increase in salinity levels will cause salinity in Lake Alexandrina to shift from tolerable to intolerable for a small number of short-lived small-bodied native freshwater fish species However at the time of weir construction these species are likely to be in decline or absent due to other factors primarily the loss of fringing aquatic vegetation habitat unrelated to weir construction Additionally the unfavourable salinities caused by weir construction are predicted to be temporary and repopulation of the Lower Lakes via downstream migration from the River Murray channel is anticipated to occur following weir construction Ongoing fish monitoring of the lower lakes will provide further information regarding impacts to native freshwater fish

The above discussion has focussed primarily upon obligate freshwater fish of the Lower Lakes However a number of diadromous and estuarine species are also common in the Lower Lakes (Phillips and Muller 2006) The salinity tolerances of these species are much higher than those for obligate freshwater fish species (Bice and Ye 2009) and the temporary increase in salinity levels due to weir construction is not anticipated to have a significant impact upon diadromous or estuarine species

Supplementary EIS for the temporary weir near Pomanda Island -30shy

It is likely that the impacts of the temporary weir upon fish in the Lower Lakes will be transferred to piscivorous birds Given that the temporary weir is unlikely to have a significant impact upon obligate freshwater diadromous or estuarine native fish species a significant impact upon piscivorous birds due to declines in native fish abundance is also unlikely Therefore piscivorous birds are not anticipated to be significantly impacted by weir construction

The impact of the temporary increase in salinity levels upon the invasive polychaete tubeworm Ficopomatus enigmaticus should be examined in the light of the research being undertaken by Dr Sabine Dittmann for the SA MDB NRMB The tubeworm itself has not been identified as a Matter of NES however changes to its abundance may impact upon Matters of NES

The Long-necked Tortoise is not listed as threatened under the EPBC Act nor is it considered a Ramsar-significant species or a primary determinant of ecological character for the CLLMM (Phillips and Muller 2006) The Long-necked Tortoise population of the CLLMM is therefore not a matter of national environmental significance and the impact of the temporary weir upon it is outside the scope of the EIS

Impacts upon tributary wetlands

A number of submissions were received regarding the impacts upon the ecosystems of the tributary wetlands of disconnection of surface waters and groundwater interactions caused by construction of the temporary weir

Response

The Swamps of the Fleurieu Peninsulas geographic distribution include swamps fringing Currency Creek Finniss River Goolwa Channel and Lake Alexandrina near Milang These swamps have already disconnected from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into Lake Alexandrina and were the first to disconnect at a water level of approximately +03 m AHD

The Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton (EPBC Reference No 20094833) The South Australian Government commenced construction of the regulator in June 2009 This regulator is expected to be completed in August 2009 and will result in the Goolwa Channel Currency Creek and Finniss River being disconnected from Lake Alexandrina

The Hindmarsh Island channels disconnected at approximately +01 m AHD These well-vegetated water bodies were significant habitat for the EPBC-listed Yarra Pygmy Perch and thus a captured breeding and recovery program has been implemented to ensure that the populations survive the current drawdown and can be released once water levels and habitat conditions improve

In terms of groundwater connection it is assumed that the tributaries and Lake Alexandrina will remain connected through groundwater at water levels less than -28 m AHD and thus could potentially be impacted upon by construction of the temporary weir During development of the EIS DWLBC staff were consulted on whether the predicted decrease in the Lake Alexandrina level of 210 mm near the tributaries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the water level drop caused by drought and over-allocation already experienced

Impacts upon the Milang Snipe sanctuary

One submission argued that the Draft EIS had not adequately addressed impacts upon the Milang Snipe Sanctuary

Response

The Milang Snipe sanc tuary is a very signific ant refuge for Japanese (La tham s) Snipe a recognised migratory species under the EPBC legislation and a listed species under the China Australia Migratory Bird Agreement (CAMBA) Japan Australia Migratory Bird Agreement (JAMBA) and the Republic of Korea Australia Migratory Bird Agreement (ROKAMBA) In

Supplementary EIS for the temporary weir near Pomanda Island -31shy

addition the presence of mature aquatic vegetation and the mosaic of ponds have provided excellent habitat for a suite of other waterbird species

The Japanese Snipe requires freshwater wetlands and vegetated meadows and preferably seasonal or semi permanent freshwater swamps Under a different hydrological regime the inundation frequency of the wetlands will change and the habitat will no longer remain optimal This site is a very good example of a wetland that may become compromised by altered hydrology

The Milang Snipe sanctuary is inundated when water levels in the Lower Lakes are high The site is currently dry The temporary weir is not anticipated to impact upon the water regime at the Milang Snipe sanctuary and therefore no significant impact upon the ecosystem of this site is predicted as a consequence of weir construction and operation

Impacts upon primary determinants of ecological character

One respondent noted that the summary of ecological impacts upon the primary determinants of ecological character (pg 12-20 section 126) appears to relate more to current drought-related ecological impacts and not specifically to the additional (likely to be small in comparison) ecological impacts of temporarily reducing flow to Lake Alexandrina

Response

This is agreed Additional comment is as follows Section 12-6 of the Draft EIS summarises the predicted impacts of the temporary weir upon the primary determinants of ecological character of the CLLMM Ramsar site It covers impacts to two primary determinants keystone aquatic plant species and habitat availability However it does not address the other four primary determinants outlined in the ECD It also fails to clarify the difference between drought impacts and weir impacts upon the primary determinants The following changes are proposed

In Section 12-6 pages 12-20 under the dot point Hab ita t ava ilab ility add the following four dot points

Salinity assigned a red light highlighting that conditions in 2006 were leading to loss of species (including keystones) and that salinities in the saline-estuarine units needed to be reduced urgently in order to maintain ecological character

Turbidity and sedimentation patterns assigned an orange light assessment highlighting that knowledge was poor and improved flows were required in 2006

Water levels assigned an orange light assessment highlighting that the regime in 2006 was counter-seasonal to the natural one and too static to support the full complement of the Lakes b iota and

Water regime particularly flow patterns in relation to inflows from the River Murray assigned a red light assessment highlighting that change to the ecological character of the site is largely a consequence of reduced flows from the River Murray

Additionally the first paragraph on page 1221 of the Draft EIS should be replaced by the expanded discussion under the six sub-headings which follow

Impact upon keystone species

Keystone aquatic plant species and assemblages in the Lower Lakes and tributary wetlands have become disconnected from the water body threatening their ongoing persistence Disconnection occurs at water levels below approximately +035 m AHD and is a consequence of the drought and upstream diversions Modelling indicates that disconnection will continue indefinitely under anticipated low flow conditions (see Section 10) with or without the weir in place The temporary weir will not alter the duration of disconnection between the keystone aquatic plant species and the water body The impact of the temporary weir upon this primary determinant of ecological character is therefore considered insignificant

Impact upon habitat availability

Habitat availability (particularly spatial and temporal connectivity) has been dramatically reduced by the drought due to the disconnection between the various parts of the system Key water levels for disconnection include

Supplementary EIS for the temporary weir near Pomanda Island -32shy

+05 m AHD disconnection between the freshwater and saline-estuarine units occurs (permanent barrage closure is required to prevent seawater incursion into the Lower Lakes)

+035 m AHD disconnection between fringing aquatic vegetation of the Lower Lakes and the water body

03 m AHD disconnection between Lake Alexandrina and Lake Albert occurs and

12 m AHD disconnection between the Goolwa channel (and associated tributary wetlands) and Lake Alexandrina occurs

Water levels of lt 15 m AHD will persist for the 2010-2012 period (the nominal lifespan of the temporary weir) should low flows continue (896 GLyr at the SAVic border) whether the temporary weir is built or not (Section 10) Thus the temporary weir will have no impact upon connectivity within the Ramsar site connectivity having already been lost due to the drought However the temporary weir will have an impact upon connectivity between the River Murray channel upstream and the Coorong Lakes Alexandrina and Albert Ramsar site downstream The impact upon this loss of connectivity upon fish and potential mitigation measures is discussed in Section 1353 of the draft EIS

Impact upon salinity

As discussed on page 31 the impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9)

Impact upon turbidity and sedimentation patterns

The turbidity and sedimentation patterns in the Ramsar site are not predicted to be significantly impacted by the temporary weir The impact of current and ongoing low water levels upon this primary determinant of ecological character is anticipated to overwhelm any additional impact caused by the temporary weir The potential for temporary increases in turbidity during the construction phase of the temporary weir will be addressed by mitigation measures discussed in Sections 114 and 115 of the draft EIS

Impact upon water levels

The impact of the temporary weir upon water levels is discussed extensively in Section 10 of the d ra ft EIS Under both weir and no weir sc enarios wa ter levels in the Lower Lakes will be well outside those recommended by Phillips and Muller (2006) ie +01 to +08 m AHD Modelling shows that the temporary weir leads to lower water levels in Lake Alexandrina than would occur if it were not constructed but that the effect is reduced as time post construction increases (Table 10-7) Of particular note is the impact of weir construction upon the timing of exposure of sulfidic sediments in Lake Alexandrina Construction of the temporary weir is anticipated to lead to the critical water level of 15 m AHD which is expected to lead to acidification of the Lake being reached earlier than would occur if it were not constructed However modelling indicates that such water levels will be reached irrespective of a temporary weir being constructed should low flows continue Measures to avoid acidification are discussed in Sections 1126 and 15412 of the draft EIS

Impact upon water regime

The impact of the temporary weir upon water regime particularly flow patterns is considered insignificant

As indicated on page 32 the Angas and Bremer have been disconnected since 2007 and the Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton

Lake Albert was disconnected with the cessation of pumping from Lake Alexandrina on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -33shy

By mid to late 2010 the water level in Lake Alexandrina will be at approximately 15 m AHD Thus the Lake will be disconnected from all other parts of the Ramsar site (ie the Coorong)

Thus any impact of the temporary weir upon water regime affects only Lake Alexandrina and the small area of the Ramsar site located upstream of the weir site The impact upon Lake Alexandrina is a temporarily increased rate of water level decline with various consequences discussed above The impact of increased water level upon the area of the Ramsar site upstream of the temporary weir and upon the River Murray channel upstream of the Ramsar site is considered to be positive provided acidification can be avoided or mitigated

Impacts upon migratory shorebirds

A number of submissions argued that the potential impacts of the temporary weir upon migratory shorebirds had not been adequately addressed Additionally several submissions expressed concern that by limiting the discussion of impacts to regularly recorded migratory shorebirds important impacts could be overlooked It was argued that species recorded infrequently and in low numbers should be a priority for protection as it is likely that they are more susceptible to localised impacts

Response

The temporary weir is unlikely to impact negatively upon the abundance of migratory shorebirds using Lake Alexandrina Under previous management arrangements the Lake was surcharged with water each year and only small areas of exposed mudflat were useable by shorebirds Over the past 18 months the wa ter line has rec eded and the Lake s edges have a t times been used preferentially (compared with the Coorong) for foraging purposes (Wainwright and Christie (in press))

Section 14 of the Draft EIS examines the likely interactions should the temporary weir proceed All migratory shorebirds are listed as matters of NES under the EPBC legislation The separation of seven spec ies into a group desc ribed as regula rly rec orded rela tes to the abundanc e of these species in comparison with any other migratory shorebird and tern species that have been observed a t Lake Alexandrina The regula rly rec orded group a re a t least two orders of magnitude more common Waterbird data collected monthly from 16 sites (2003 to current) around Lake Alexandrina informs this thinking

Impacts upon Australian Painted Snipe

A number of submissions argued that the Draft EIS should have addressed impacts upon the Australian Painted Snipe

Response

The Australian Painted Snipe is nomadic and adopts wetlands opportunistically It requires freshwater and well vegetated wetlands with internal complexity Recent records from Lake Alexandrina are scarce (Letch 2007) presumably because the recent drought has eliminated all suitable habitats However historic records suggest that the fringing habitats around Lake Alexandrina when intermittently favourable have been frequented by the species Recent information suggests that the Australian Painted Snipe may be present close to the site of the temporary weir

Low water levels in the Lower Lakes appear to have led to a significant loss of habitat for the Australian Painted Snipe However given the suggestion that it may be present in the vicinity of the temporary weir construction area it should be considered in the EMP to be prepared for weir construction

Impacts upon Orange-bellied Parrot

One respondent noted that discussion of the Orange-bellied Parrot did not mention the importance of samphire habitat to this species One submission argued that potential impacts upon the Orange-bellied Parrot had not been properly addressed in the Draft EIS

Response

Within South Australia the Orange-bellied Parrot appears to be less dependent than previously suspected on samphire vegetation Recent observations in South Australia suggest that the

Supplementary EIS for the temporary weir near Pomanda Island -34shy

species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

The Orange-bellied Parrot is critically endangered and interactions with proposed weir operations are considered possible The species is known to use a range of habitats including highly disturbed areas Accordingly it is a subject discussed in Chapter 13 of the draft EIS

Impacts upon Great Egret Cattle Egret and Caspian Tern

One respondent expressed concern that the Great Egret Cattle Egret and Caspian Tern are not dealt with satisfactorily One submission noted problems with the nomenclature concerning egrets

Response

The two Egret species being discussed in Section 761 are the Great Egret Egretta (Ardea) Alba and the Cattle Egret Ardea ibis Both species are listed migratory species under the EPBC legislation The Cattle Egret is listed as a migratory species using the binomial Ardeola ibis The reference in Section 77 to the White Egret for consistency should read Great Egret Both are recognised English names for the species Egretta (Ardea) Alba

The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in south-eastern Queensland and north-eastern New South Wales (Marchant and Higgins 1993)

The movements of Caspian Tern are poorly understood they are partly resident partly dispersive and possibly partly migratory (Marchant and Higgins 1993) The species is commonly observed on fresh and marine waters foraging on the wing for fish

Impacts upon pelagic birds

One submission argued that potential impacts upon pelagic bird species had not been properly addressed in the Draft EIS

Response

Pelagic bird species listed in the draft EIS (including all listed Albatross species Blue Petrel Giant Petrels and the Soft-plumaged Petrel) are all oceanic species that have no dependence on Lake Alexandrina for food or habitat Their presence at the site is fortuitous Records are mostly of ocean beach-washed specimens or live animals temporarily blown inland during storm events The weir construction has no effect on their endurance

Impacts upon bush birds

One submission argued that potential impacts upon bush bird species had not been properly addressed in the Draft EIS

Response

The Black-eared Miner Red-Lored Whistler Malleefowl and Regent Parrot are all species that require mallee or woodland habitats that are now largely absent from the edges of Lake Alexandrina These bird species are now locally extinct from the Lakes area because of landscape scale changes to adjacent woodland and mallee habitats Recent observations of these spec ies in the reg ion (as c ited in The Natura l History of Stra tha lbyn and Goolwa Distric ts 2000) are from locations that support very different habitats to those immediately adjacent to

Supplementary EIS for the temporary weir near Pomanda Island -35shy

the Lakes It is highly unlikely that any of these species would be affected by the temporary weir

The Spotted Quail-Thrush is now considered extinct in the Mount Lofty Ranges and Fleurieu Peninsula

Impacts upon Mt Lofty Ranges Southern Emu Wren

Several submissions argued that potential impacts upon the Mt Lofty Ranges Southern Emu Wren had not been adequately addressed in the Draft EIS

Response

The Mount Lofty Ranges Southern Emu-Wren is recognised as an endangered species that inhabits fragmented wet and dry heath in the vicinity of the proposed weir site The nearest known rec ords of the spec ies (sourc e Biolog ic a l Da tabases of SA ) determined by extensive surveys are 35 kilometres from the temporary weir site at the top of the Finniss estuary It most unlikely that the temporary weir proposal would impact negatively on the species however it has been considered in the discussion about impacts in Chapter 13 of the Draft EIS

Impacts upon White-bellied Sea Eagle

One submission argued that potential impacts upon the White-bellied Sea Eagle had not been properly addressed in the Draft EIS

Response

The White-bellied Sea Eagle is regularly observed but not so commonly recorded in the Lower Lakes and Coorong area The species exploits the protected waters at both sites for fishing A recent sighting of a juvenile bird suggests that local breeding also occurs The implications of the temporary weir on this species are outlined in Chapter 14 of the draft EIS

Issues of scope adequacy and definition

Adequacy of species and communities examined

There were a significant number of submissions on this issue and one respondent who argued that the Draft EIS was inadequate in its assessment of ecological impact because the range of species and communities examined was too limited The Draft EIS assessment was constrained to the Matters of NES listed in the EPBC referral documents Submissions raise the criticism that all components of the Ramsar site should be assessed not just nominated Matters of NES because they are interconnected and interdependent

Response

This statement is true in terms of defining changes to ecological character of the Ramsar site And if the temporary weir were to be built under normal operating conditions all ecological components would have been assessed However the impacts of the temporary weir per se were restricted to those ecological components that would occupy the Ramsar Type O (permanent freshwater lakes) wetlands at a water level of -15 m AHD because this will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir

It is also assumed that at -15 m AHD there will be little or no aquatic vegetation in the Type O wetland because historical high turbidity and static water levels have precluded growth of plants that far out into the Lakes The water body that remains would generally be several kilometres from the existing aquatic plant seedbank and would remain very high in turbidity and experience high energy water movement Thus it is not predicted that keystone aquatic plant species will colonise this area before construction of the temporary weir The benthos was not assessed specifically and further research into the species and distribution of benthic fauna at very low lake levels would improve this draft EIS particularly given the dependence of EPBC-listed fish and bird species on benthic fauna

Impacts on other Ramsar Wetland Types (that is the rest of the Ramsar site) were not considered because the impacts of the drought and over allocation were considered to be the primary determinants of change in ecological character for those wetlands

Supplementary EIS for the temporary weir near Pomanda Island -36shy

Current status of waterbirds

One submission noted that the current status of waterbirds and migratory shorebirds at the CLLMM had not been adequately stated and that recent research (Kingsford 2009) had not been referred to

Response

Most waterbird species are migratory to some degree Some species have predictable movements but most species respond opportunistically to climatic events that bring about favourable changes in habitat quality or food resources Local and continental rainfall patterns have a strong influence on the abundance of waterbirds using the Lower Lakes At the continental scale there were significant changes in the amount of rainfall (and subsequent change in area of wetland habitat) between November 2007 and early 2009 In late 2007 the Murray-Darling and Lake Eyre Basins were both drought affected During 2008 South-eastern Queensland and northern New South Wales received record rainfall and a 1-10 year flood occurred in the Lake Eyre Basin The entire populations of some species (Pink-eared Duck for example) respond to these events adopting the most favourable habitat available The large amount of variability in waterbird numbers is expected and it is a strategy waterbirds use to survive the natural variability in the Australian climate

Regular bird survey work at 23 sites around Lake Alexandrina during the last 12 months suggests that there are no detectable changes in the species richness of waterbirds using the Lower Lakes There are more obvious changes in abundance and as a generalisation waterfowl numbers have decreased while shorebird abundance has increased

Adequacy of EPBC Act threatened species and communities lists

One submission argued that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the Murray-Darling Basin including the CLLMM region are currently being evaluated for EPBC listing

Response

The scope of the EIS is confined to Matters of NES Only nationally listed threatened species or nationally listed migratory species or those that contribute to the ecological character of a Ramsar site are matters of NES Species and communities that are under evaluation for listing as threatened but not yet listed are not matters of NES

Adequacy of discussion of EPBC Act-listed species

One submission argued that the discussion of EPBC Act-listed species in the EIS is incomplete and superficial

Response

Additional detail regarding potential impacts to EPBC Act-listed species is provided in several chapters of this supplementary EIS

Omitted flora and fauna records

Natura l History of Stra tha lbyn and Goolwa Distric ts (2000) (Stra tha lbyn Natura lists Club Inc ) and the Tolderol Wetland Management Plan Severa l submissions mentioned tha t the

c onta in information on a number of EPBC Act-listed species that have been recorded in fringing wetlands of the Lower Lakes but were not discussed in the EIS

Response

Natural History of Strathalbyn and Goolwa Distric ts (2000) and the Tolderol Wetland Management Plan may revea l EPBC Act-listed species that have been recorded in the CLLMM in addition to those mentioned in the draft EIS However given the current disconnection of the wetland habitats of the area and the predicted absence of any impact of the temporary weir upon their water regime the temporary weir is not anticipated to cause a significant impact upon the wetland-dependent species of the fringing wetlands of the Lower Lakes

A more thorough examina tion of the litera ture foc ussing on the

Supplementary EIS for the temporary weir near Pomanda Island -37shy

Definition of keystone species

Severa l submissions a rgued tha t the term keystone spec ies had been misused in the Dra ft EIS It was argued that all species that are critical to food chain processes in the Lower Lakes (ie keystone species) should be identified and discussed and that conceptual models detailing the importance of these key biota would help the reader to understand the processes

Response

The Ecological Character Description (ECD) for the site (Phillips and Muller 2006) describes the keystone species of the CLLMM The draft EIS uses the same language and examples of keystone species as does the ECD Correcting an incorrect ECD is beyond the scope of the EIS

Species considered of particular significance

One submission argued that Murray Hardyhead Yarra Pygmy Perch and Murray Cod should be on the partic ula r signific anc e list

Response

list (Section 7-5 of the Draft EIS) The impact of the temporary weir upon these species is examined in Chapter 13 of the Draft EIS

Murray Hardyhead Yarra Pygmy Perc h and Murray Cod a re on the partic ula r signific anc e

Adequacy of description of different wetland types

A number of submissions argued that the ecological information regarding each of the 15 wetland types of the CLLMM was inadequate to assess impacts of the temporary weir upon them

Response

The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170mm occurs only during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD is not a direct impact of the temporary weir and thus is beyond the scope of the draft EIS

Regional importance of the Coorong Lower Lakes and Murray Mouth

It was noted in several submissions that the Chowilla Ramsar wetland has been disregarded as it is greater than 200km from the Lower Lakes and Coorong The EIS needs to consider the regional implications of a degraded Lakes and Coorong and the use of aquatic habitats by migratory bird species If environmental water is not being delivered to the Lower Lakes and Coorong provision for suitable aquatic habitat needs to be made in other areas of the state as a minimum

Response

The proponent notes that both the CLLMM and Chowilla Ramsar sites are regionally significant and that adequate inflows to maintain the ecological character of both are required This issue is outside the scope of the Draft EIS

Australia s Ramsar obligations

A number of submissions raised the issue that Australia does not appear to be committed to wise use of the Coorong and Lakes Alexandrina and Albert Ramsar site and its obligations

under the Ramsar Convention in terms of proposing that this temporary weir be built

Response

The principal factor impacting on the Ramsar site is the low flow of freshwater to the site particularly over the last few years of drought and over-allocation across the Murray-Darling Basin ra ther than a lac k of c ommitment to wise use

Supplementary EIS for the temporary weir near Pomanda Island -38shy

6 Notes on significant issues outside the scope of the draft EIS

For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities

Notes on social and economic issues raised in submissions

In this section a number of significant concerns and ideas detailed in submissions by individuals organizations and local government are canvassed

These concerns and ideas do not focus on Matters of NES protected under Part 3 of the EPBC Ac t and as suc h a re outside the sc ope of Guidelines for the Content of a Dra ft Environmenta l Impact Statement on the Proposed Temporary Weir at Pomanda Island near Wellington South Australia Environment Protection and Biodiversity Conservation Act 1999 (Reference Number 2007 3484) da ted 30 August 2007

However they are registered here because they reflect strong community positions

These concerns and ideas will be taken into consideration during the development of the long term plan for the Coorong Lower Lakes and Murray Mouth region The first step in developing the long-term plan was the release of the Directions for a healthy future document for public c omment during May 2009

Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

One submission raised concern that Ngarrindjeri People has to compete for attention in the consultation process

An additional concern is that the Ngarrindjeri People is not recognised as Traditional Owners

The Coorong District Council emphasized that the Coorong and Lower Lakes have particular significance to the Ngarrindjeri and

Another submission (supported by the River Lakes and Coorong Action Group) stated tha t the Dra ft EIS d isp lays little or no understand ing of the importanc e of c ultura l flows to the Ngarrindjeri

Social and economic issues

A number of submissions noted the lack of content in the Draft EIS on social and economic measures associated with the temporary weir

Generally submissions from individuals organizations and local government indicate that the current social and economic conditions in the Coorong Lower Lakes and Murray Mouth area (as a result of drought lack of fresh water River flows and over allocation of water resources across the Murray-Darling Basin) are very negative When putting forward these concerns submission writers did not usually make clear how the construction of the temporary weir will further contribute to enhancing negative social or economic trends

A submission from the Southern Alexandrina Business Association Inc claims that the boating industry in the region under current conditions is losing $200 million per annum

A detailed submission from the Boating Industry Association of SA Inc claims that business of the leisure tourism and recreational sector and those that support them are suffering enormously from the existing droughtover allocation conditions The

Supplementary EIS for the temporary weir near Pomanda Island -39shy

submission proposes that we need to replenish water stocks including water for the environment Water for the Community and water for the EconomyTertiary Sector

The Rural City of Murray Bridge is concerned that professional fishermen can move up and down the River

The Coorong District Council notes that the dairy industry irrigated horticulture fodder production and beef cattle production have been negatively impacted by lack of access to water Property values have declined by 50 per cent in some cases and most of the 17 dairies in the Coorong District have closed or relocated Council rate revenue is down and

One submission (endorsed by other submission writers) provides a researched and extensive argument about the predominance of contemporary social and economic ideas which favour growth for example of expansionary plantings of a variety of unsustainable crops and growth of human populations and notes the South Australian population expansion in the South Australia Strategic Plan The writer suggests that new ideas about limitations and replenishments are required as well as a move towards adoption of tools like the Genuine Progress Indicator rather than reliance on indicators like Gross Domestic Product

Climate change

One submission asked for a rethink of the Draft EIS based on additional scenarios to the d rought sc enario whic h preva ils in the d ra ft EIS This sc enario is based is the worst

case climate scenario to date

Dust and health

A number of submissions raise concerns about current health problems caused by excess dust being blown from the dry lake bed

Other themes

A number of submissions a rgued tha t the temporary would nec essarily bec ome permanent and some of these argued that a navigable Lock with fish passages would therefore be preferable

A number of submissions argued for a seawater solution rather than a limited inflow to control the possible risks associated with ASS

Some submissions especially from government agencies or Non Government Organisa tions (NGO s) pointed out tha t further approva ls will be required in add ition to those cited in the Draft EIS The MDBA advised that it will require at least six weeks to undertake its approval processes from the time that the additional details are provided On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

Supplementary EIS for the temporary weir near Pomanda Island -40shy

7 Suggested text changes errata additions clarifications and

references

Page Issue raised by submission(s)respondent(s)

Recommended changes

vi Page vi acid sulfate soils box last sentence should read See Chap ters 6 8 11 and 15 for d eta ils

Make suggested changes

115 Pg 1-16 section 152 Environment Protection Act 1993 The Environment Protection (Air quality) Policy could also be included in this section as it applies to potential dust and noise impacts

Reword sentence 1 paragraph 1 section 152 page 115 to read

The Environment Protection Act 1993 (the Environment Protection Act) and the Environment Protection (Air quality) Policy provide legislation for the protection of the environment and the establishment and definition of the powers and functions of the Environment Protec tion Authority (EPA) in South Austra lia

116

12

27

Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

Apparent inconsistency in water usage figures between Table 1-1 and pages 2-4 and 2-12

Pg 2-7 section 24 Red uc ed ra infa ll and

dec rea sed evapora tion should be increased evaporation (many of these inconsistencies throughout document)

Reference to Section 1554 should be changed to Section 15412 Acid Sulphate Soils Safeguards and Mitigation Measures and Table 15-6 titled Potential mitigation measures to manage acid sulphate soils

Appendix 1 question 91 provides clarification

Page 27 rep lac e text Red uc ed ra infa ll and d ec rea sed evapora tion with text Red uc ed ra infa ll and inc reased eva p ora tion

Supplementary EIS for the temporary weir near Pomanda Island -41shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

27 Issues raised concerning the accuracy of the data in Table 23 page 27

Update Table 2-3 to include the following

200607 Inflows

Total flow at the SA Border 1436 GL

Eastern Mount Lofty Ranges estimated inflow 39 GL

200607 Use and Loss

Net Loss(1) 1262 GL

SA Water pumped extraction(2) 245 GL

Irrigation Extraction(3) 377 GL

Total System Deficit -448 GL (4)

(1) Net loss is inclusive of evaporation seepage rainfall EMLR inflows unmetered diversions

(2) SA Water pumping from the River Murray includes 60 GL of water pumped to the MLR reservoirs for use in 200708

(3) note as in document

(4) Deficit is defined as Inflow at SA Border - losses - SA Water pumping - irrigation extraction and corresponds with the fall in water level in Lakes Alexandrina and Albert

2-13

213 219

215

References to 696 GLyr of dilution flow should be clarified

2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Pg 2-15 section 26 Current water level statement (-05m AHD) was incorrect at the time of EIS publication and should be updated and referenced

Appendix 1 questions 9 and 88 provide clarification

Reference to 940 GL on pages 213 and 219 should be changed to 896 GL

The water level in Lake Alexandrina is now at a new record low of -095 m AHD (reference Murray Darling Basin Authority Murray River System Drought update issue 18 APRIL 2009)

The MDBA drought upd a te sta tes tha t During winter in the absence of significant inflows reduced evaporative losses should allow the water level to remain fairly steady and even under a worst case scenario Lake Alexandrina is unlikely to reach the estimated acidification trigger of -15 m AHD prior to February 2010

Supplementary EIS for the temporary weir near Pomanda Island -42shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

215 The salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences

Delete Table 2-4 from the document It is not referred to in the text and therefore serves no purpose Add following text to section 26 para 3

Historic a lly Lake Alexand rina wa s a p red omina tely freshwater system with only brief periods of seawater intrusion during low outflow periods that did not extend beyond Point Sturt (Sim and Muller 2004) DEH is in process of contracting more work to The University of Adelaide to verify this understanding of the pre-European salinity regime of both Lakes Alexandrina and Albert by studying diatom species distribution in dated cores It is predicted that by May 2009 water in the Lake is expected to be at ~6000 EC (Figure 2-11) which is considered to be saline in terms of ecological func tiona lity (Williams 1986)

2-16 11-9 Section 1554 does not exist

The reference to section 1554 should read section 15412 Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant

334 Pg 3-34 Environment Protection (Water Quality) Policy 2003 The Environment Protection (Water Quality) Policy 2003 should be listed under legislation rather than policy section of this table

337 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

337 Pg 3-37 Table 3-5 The National Water Quality Management Strategy should be included in Table 3-5 as this is tool that is being utilised in this region for integrated catchment management to achieve improved water quality outcomes

349 Pg 3-49 Table 3-9 ASS and water quality the Centre for Water Research model should be grouped under this section together with EPACSIRO

4-4 Details and status of SA Water Corporation pump station upgrades

Update Table 3-4 beginning page 331 such that Environment Protection (Water Quality) Policy 2003 is listed under South Austra lian Leg isla tion instea d of und er Sta te Polic y and Pla nning Frameworks

In Table 3-5 Page 337 and anywhere else in the doc ument it is mentioned d elete referenc e to Na tiona l Ac tion Plan (NAP) and rep lac e with Caring for our Country (CFC)

Include National Water Quality Management Strategy in Table 3-5

In Table 3-9 inc lud e Centre for Wa ter Researc h a long with EPA CSIRO in row 3 c olumn 3

Upd a ted sta tus d eta ils of SA Wa ter Corp ora tion s pump station upgrades are provided in Appendix 1 question 14

Supplementary EIS for the temporary weir near Pomanda Island -43shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

442

5-8

510

517

61

Page 4-8 sta tes Costs for undertaking a similar ac tion for Ad ela id e s off takes from the Lower Murray are expected to be very significant (see table 4 3) and the implementation period would be approximately 3 yea rs from initia tion

58 states that once the water level exceeds +01m AHD the temporary weir will cease to serve any useful function

The last paragraph in section 542 should be rep la c ed with The fina l most viable solution may involve multiple rock types from multiple sources to achieve the optimum construction cost within the limited time frame Rock sources with clays fine silts and sands while suitably geotechnically may not be utilised to reduce the potential for environmental impact through turbidity and sedimentation

Insert the following for Section 563 Section 563 of the draft EIS only partially refers to the environmental safeguards and mitigation measures Section 563 should be ignored and Chapter 15 be referred to for safeguards and mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Management Plan (EMP)

Paragraph 1 page 6-1 needs to include rainfall on the Lakes as an input to the system

Delete reference to Table 4 3 from the document

Appendix 1 question 52 provides clarification

Page 510 make suggested changes

At the end of section 563 page 517 add the sentence

Chap ter 15 should b e referred to for sa feguard s a nd mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Ma nagement Pla n (EMP)

Reword sentence 2 paragraph 1 page 61 to read

Freshwa ter from the River Murray the Eastern Mount Lofty Ranges (EMLR) catchments Upper South East (USE) drainage scheme direct rainfall onto the lakes and from groundwater as well as salt water from the Southern Oc ea n a ll input to the Coorong a nd Lower Lakes site

Supplementary EIS for the temporary weir near Pomanda Island -44shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

61 Last paragraph of 61 needs to include a further condition in the list - that of the MDB before the advent of white people as that is the condition that has determined which species live amp belong here

For the sc ope of the d ra ft EIS the baseline c ond itions of the CLLMM are those that existed when the site was listed as a wetland of international significance under the Ramsar convention These conditions are discussed in the Ecological Character Description (ECD) for the site (Phillips and Muller 2006) The draft EIS correctly uses the ECD as a baseline regarding condition It should be noted that many parameters that describe the conditions of the CLLMM are currently beyond the acceptable limits of change as outlined by the ECD due to drought and over-allocation of water

63 Issue raised concerning wording of paragraph 4 page 63

63

65

Issue raised concerning impact of static water levels page 63

Issue raised concerning Barra ge Opera tion Page

65

Change text in paragraph 4 p 6-3 to read

Aquatic vegeta tion has sinc e declined due to static water levels such that only a fringing band of vegetation around the +03 to +06 m AHD water marks remains of the extensive submerged and emergent beds that extended several kilometres into the Lakes pre-European settlement (Sim and Muller 2004)

Remove first bullet point under Figure 6-1 d egra d ed shorelines in sheltered a rea s

Add text below as a new fourth and fifth paragraph under barrage operation (p 6-5)

The b a rrages impede ec o log ic a l c onnec tivity between the fresh estuarine and more saline parts of the Ramsar Of particular concern are the adverse impacts on fish migration and transfer of recruits from one part of the system to another Fish passages have been installed on some gates to facilitate fish movement during periods of barrage opening and the Barrage Operating Strategy seeks to optimise ecological outcomes with each barrage release

The Lower Lakes barrages have not been opened since October 2006 thus there has been no hydrological connectivity between the fresh and estuarinesaline a rea s of the Ramsar site sinc e then

66 Issue raised concerning Ripa ria n La nd

Ma nagement page 66

Add text below as second paragraph under Riparian land management (p6-6)

Inva sion of pest p la nts a nd a nima ls into the wetland s is also a major issue particularly given the close proximity of the agricultural land and the large expanses for wind and water borne weed s to b e d ispersed

69 Issue raised concerning keystone species listed on page 69

Change text in second bullet point under the keystone species for freshwater lakes include (p 6-9) to read

Assemb lages of emergent p la nts (eg Sc hoenop lec tus sp Baumea sp Phragmites australis) along the fringes of the lake and EMLR tributa ries

Supplementary EIS for the temporary weir near Pomanda Island -45shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

610 Issue raised concerning list of factors that influence aquatic plants bottom of page 610

Reword the statement at the bottom of page 6-10 of the Draft EIS with the following

Ganf (2000) identified four issues influenc ing the productivity distribution and community composition of macrophytes

salinity

turbidity

water regime and

wind and wave action

These factors combined mean that submerged aquatic plant growth is restricted to the littoral zone of the mod ern lake environment (Phillip s and Muller 2006)

612 Issue raised concerning wording of caption for Figure 66 page 612

612 Issue raised concerning section 63 page 612

614 A Respondent questioned page 6-14 section 65 of the Draft EIS determinants or drivers

72 73 Bool amp Hacks Lagoons are not upstream of this temporary weir as is implied in the text

74 Page 7-4 section 733 An error messages appears

75 736 Type M permanent rivers streams amp creeks -Lake Alexandrina also takes the flow from the Rivers Angas amp Bremer amp Mosquito Creek between Milang amp Langhorne Creek

Pg 6-12 Figure 66 c ap tion should rea d d rivers a nd levers (not d rivers and levels )

Section 63 shy Pg 6-12 Include the following text as sentence 2 of paragraph 3

Direc t ra infa ll on the lakes a nd evapora tive losses a re key components of local climate that have the potential to impact greatly on the resultant water reg ime of the site

Sec tion 65 first p a ra graph rep lac e The p rima ry d rivers for ecological character includ e with The p rima ry determinants of ecological character are (Phillips and Muller 2006)

Reword sentence 1 paragraph 2 section 73 page 72 as follows

Banroc k Sta tion Wetla nd Complex Riverland wetla nd s and Hattah-Kulkyne Lakes are located more than 200 km (minimum) upstream of Pomanda Island and are unlikely to be a ffec ted by the temporary weir

Following sentence 1 add additional sentence

Bool and Hacks Lagoons are located outside of the MDB and over 200 km from Pomanda Island and will therefore b e una ffec ted b y the temp ora ry weir

Rep la c e text Error Referenc e sourc e not found With text Figure 7-2

The Rivers Angus and Bremer and Mosquito Creek are classified as wetland Type N -seasonalintermittentirregular riversstreams and creeks These tributaries should be referred to in Section 737 of the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -46shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

731 756 Plant associations in close proximity to the temporary weir Only one of the 11 dot points is actually a plant association

Reword the sentenc e The p lant a ssoc ia tions in c lose p roximity to the temp ora ry weir site inc lud e to read

The d ominant or c o-dominant plant species in close proximity to the temp ora ry weir site inc lud e

Replace dot point Muehlenbeckia florulenta tall open shrub land with Phra gmites a ustra lis with two d ot points

Muehlenbec kia florulenta

Phra gmites austra lis

732 Page 205 - Table 7-6 should be checked for accuracy Cattle Egret is not EPBC listed migratory species

According to the EPBC Act website Cattle Egret is a listed migratory species therefore its listing in Table 7-6 is correct See

httpwwwenvironmentgovaucgishybinspratpublicpublicspeciespltaxon_id=59542`

Chapters 4 and 9

101

102

102

Text in the executive summary chapters 4 and 9 erroneously includes the use of toxins when the intended meaning is in fact toxicants Toxins are substances produced by living cells such as algal toxins etc whereas toxicants are a broader range of chemicals that produce a toxic response in living organisms

Correct the assertion in 102 Existing drought conditions that the dropping of Mungkuli (Lake Alexandrina) to below sea level for the first time in 7500 years is due to drought

Chapter 10 - Figure 10-1 -Lake Alexandrina water level 1962-2008 Full supply level = +075m AHD - EIS is incorrect

Tookayerta Creek is a tributary of the Finniss River and not Lake Alexandrina as stated Further the Finniss River and Currency Creek flow into the Lower Murray not into Lake Alexandrina

Delete the word toxins from c ha p ters 4 a nd 9 and rep la c e with the word toxic a nts

Change sentence to read

In rec ent times the wa ter level in the River Murray Coorong and Lower Lakes has been significantly lowered by the existing drought conditions and over-allocation of water associated with the entire MDB (Table 10 1)

It is the proponents understanding that +075 m AHD is referred to as full sup p ly level and tha t wa ter levels above this a re referred to as a surc ha rge

Reword sentenc e The EMLR tributa ries tha t d isc harge into Lake Alexand rina a re to read The EMLR tributaries that discharge into Lake Alexandrina and the Lower Murray a re

Delete d ot point Tooka yerta Creek from the bottom of page 10-2

Reword d ot point Finniss River to rea d Finniss River (inc lud ing Tookayerta Creek)

Supplementary EIS for the temporary weir near Pomanda Island -47shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

104

1013

1030

1030

Figure 10-3 Goolwa amp Lake Alexandrina Salinity Survey results - September 2008 EIS in error re the salinity level of Lake Albert This figure 10-3 states that 7300EC (which is approx

sea wa ter) is semi-saline

1035 - Predicted water level in Lake Alexandrina -water levels are also affected by rainfall which is not mentioned

To say that potable water supply is less than 2500EC is pushing the boundaries PIRSA documents state a salinity of 1000mgL (1666EC) is generally palatable to most tastes but up to 1500mgL (2500EC) can be acceptable in areas where better quality water is not available

The tolerable salinity limits for freshwater species needs to take into account peak levels not average levels

The d efinition of semi-sa line is p rovid ed in Tab le 2-4 of the draft EIS and refers to salinities between 5001 and 11666 EC Thus the document is consistent

Reword first sentence of Section 1035 as follows

Historic a lly wa ter levels in La ke Alexand rina have varied on a seasonal basis with water rising in winter through increased winter inflows direct rainfall and decreased evaporation and falling in summer through red uc ed inflows a nd inc reased eva p ora tion

This point is noted however it has no bearing upon the temporary weir since salinities in Lake Alexandrina are predicted to reach gt2500 EC throughout the lake during 2009 with or without the temporary weir

In Section 1043 (page 10-30) delete paragraph 3 since it has no biological or ecological relevance Revise paragraph 4 to read

Pea k or maximum sa linities a re most important ecologically because all aquatic species have salinity tolerances that if exceeded even briefly can be fatal Table 10-9 presents modelled peak salinities at points in Lake Alexand rina und er without weir and with weir scenarios during the first year of weir operation For all points modelled peak salinity in the first year is higher und er the with weir sc ena rio

10-32 Reference to 685 GL as extra water available is misleading

Agreed Clarified in Appendix 1 question 32

Supplementary EIS for the temporary weir near Pomanda Island -48shy

a ns

Page Issue raised by

submission(s)respondent(s) Recommended changes

1113 Pg 11-13 Figure 11-5 This graph could be updated to 2009 using current EPA data

Update Figure 11-5 on page 11-13 with the following which includes the most recent data

Turbidity Lake Alexandrina - Poltalloch Plains

20

40

60

80

100

120

140

160

180

200

24-Jul-98 6-Dec-99 19-Apr-01 1-Sep-02 14-Jan-04 28-May-05 10-Oct-06 22-Feb-08 6-Jul-09

Date T

u rb

id it

y (N

T U

)

Lake Alexandrina - Poltalloch pl i Ecosystem protection guideline (ANZECC)

0

121 Section 121 It is certain that the temporary weir will interact with ecological values of lower river amp lakes

121 Pg 12-1 section 122 Bottom of page 12-1 In general temporary wetlands have few animal species than permanent ones is this referring to abundance or richness or what Too general and incorrect in some circumstances

122 Chapter 123 - Ramsar listed wetland upstream of expected weir site near Pomanda Island - EIS incorrect amp needs amendment

Delete the word may from sentenc e 1 p a ra grap h 3 section 121 page 121

Bottom of page 12-1 delete the following sentenc e In general temporary wetlands have fewer animal species than p ermanent ones

On pg 12-2 rep lac e the text There a re no Ra msar-listed wetla nd s between Loc k 1 a nd the temp ora ry weir site with the following There a re no Ramsa r-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ra msar site

Supplementary EIS for the temporary weir near Pomanda Island -49shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

125 Issues raised concerning wording of Table 123 commencing page 125

In Table 12-3 make the following changes

For Cla ss M ad d text to sixth c olumn Inc reased hea d pressure may result in increased drainage to the lakes and reduced groundwater baseflow in groundwater depend ent ec osystems

For Class M seventh column change existing sentence to read there is no interac tion of the weir with the surfa c e wa ter in these wetlands

For Class M add sentence to third column that reads Inc reased head p ressure of up to 21 c m may result in

c hang e in ground wa ter b a seflow

For Cla ss 4 und er Imp a c t of p roposed tempora ry weir within Ramsar wetla nd s to existing text ad d whic h oc c urs a t wa ter levels gt 087 m AHD

For Cla ss Xf und er Existing c ond ition (a p p roxima tely shy05 m AHD) rep la c e No rec ord ed c ha nge with Not connected to the main body of the lake Will only be a ffec ted b y ongoing d rought

For Cla ss Tp c hange text in sixth c olumn to read Most disconnected but some reconnection and marginal improvement from winter ra infa ll and tributa ry inflows

Formatting issue in title of sixth column the negative is there in the column heading but there has been line split between it and 15 so it looks like +15 m AHD not -15 m AHD (should be latter)

1215 Issue raised concerning wording of Section 125 page 1215

Reword Section 125 (pg 12-15) in its entirety to read

As d eta iled in Sec tion 1241 a ll wetland hab ita ts downstream of the proposed temporary weir location are expected to be affected by the drought and by 2012 only Ramsar-wetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flows as described on page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

1216 Issue raised concerning potential positive impact of rewetting of acid sulphate soils

Section 1251 page 1216 remove reference to re-wetting of acid sulfate soils and pH drop to 2 (last dot point) from positive impacts list

Supplementary EIS for the temporary weir near Pomanda Island -50shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

12-20 Table 12-4 only lists predicted changes for 2 out of 6 primary determinants of ecological character

Update Table 12-4 to include the following

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts

(2010 2012)

Salinity Discussed extensively in Section 10

Water Level Discussed extensively in Section 10

Water Regime Discussed extensively in Section 10

Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

1310 Issue raised concerning comprehensiveness of Table 133 page 1310

To Table 13-3 insert two additional rows

1st c olumn Intera c tion 2nd c olumn Disrup t d ispersa l of tadp oles

1st c olumn Spec ies p referenc e 2nd c olumn Present upstream and downstream of site but dispersal requirements of d ifferent p op ula tions a re unknown

141 Section 141 What is the definition of regularly recorded amp by whom were they recorded

In sec tion 141 p a ge 141 p a ragraph 4 rep lac e (see Chapter 7) with (Letc h 2007)

1519 pg 15-19 section 15412 Performance criteria The acid sulfate soil trigger levels are given in Table 15shy6 not Table 15-5 as stated in the document

In d ot p oint a t bottom of page 1519 rep lac e Tab le 15shy5 with Tab le 15-6

1519 Remove Table 15-5 There are no cross-references to the table

Table 15-5 is referred to on page 1519 and should be retained in the document

162 The summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Additional comment o be inserted in Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir) after text

The ECD of the Coorong and Lakes Alexa nd rina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Nationally listed threatened and migratory species are addressed elsewhere in this table Other species are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetla nd s will persist

Supplementary EIS for the temporary weir near Pomanda Island -51shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

Throughout document

Throughout document

Throughout document

Australia operates on SI system of measurements amp this includes the millimetre metre units of measurement amp does not include centimetres

Convert centimetres to millimetres or meters as appropriate throughout the document

Correct injustice throughout draft EIS of identifying Ngarrindjeri merely as custodians community or people (112 164 165 171 1522)

Cha nge Ngarrind jeri c ustod ians and Nga rrind jeri c ommunity to Ngarrind jeri Peop le as ap p ropria te

throughout the document (as per submission PTW00046)

Text in the executive summary and throughout the document (chapters 1 2 4 8 11 12 13 15 and 16) refers to the use of the wording heavy metals when in fact this is misleading and should simply be referred to as metals

Rep la c e a ll referenc es to hea vy meta ls with meta ls

Supplementary EIS for the temporary weir near Pomanda Island -52shy

References

Bice C and Ye Q (2009) Draft Report - Risk assessment of proposed management scenarios for Lake Alexandrina on the resident fish community South Australian Research and Development Institute (Aquatic Sciences) Adelaide South Australia

DWLBC (2009) River Murray Data Department of Water Land and Biodiversity Conservation Adelaide South Australia httpdatarivermurraysagovau

Wellington Weir Site Flora and Fauna Assessment (South Australian Water Corporation Adelaide South Australia) Ecological Associates (2008) Draft Report

Ganf G G (2000) Aqua tic and ripa rian vegeta tion in A Jensen M Good P Harvey P Tuc ker amp M Long (eds) River Murray Barrages Environmental Flows An evaluation of environmental flow needs in the Lower Lakes and Coorong report to MDBC pp 30 34

Khan M T Khan T A and Wilson M E (2004) Habitat use and movement of river blackfish (Gadopsis marmoratus R) in a highly modified Victorian stream Australia Ecology of Freshwater Fish 13(4) 285-293

Lintermans M (2007) Fishes of the Murray-Darling Basin An introductory guide Murray-Darling Basin Commission Canberra ACT

Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks (Oxford University Press Melbourne)

Williams WD (1986) Conductivity and salinity of Australian Salt Lakes in Australian Journal of Marine and Freshwater Research 37177-182

Supplementary EIS for the temporary weir near Pomanda Island -53shy

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA)

General comments

1 Lots of inconsistencies particularly in figures Several of these are the result of some sections of the EIS having been updated to reflect the current environmental conditions but not others however some are just contradictions

Response Inconsistencies are corrected in the Supplementary EIS

2 In general at -15m AHD many wetland types will have already disconnected so the weir will not cause further impacts but it will slow down any potential recovery from drought impacts Please discuss and quantify these implications

Response The temporary weir will cause a 17cm drop in Lake Alexandrina water levels during the weir pool filling period under modelled worst-c ase sc enario however in the longer term there is little difference in the water levels and salinity values between weir and no weir sc enarios Quantific a tion of the amount of wa ter tha t would be

needed to refill desiccated Acid Sulfate Soils remains a knowledge gap that could be filled through field trials

3 There is a general lack of detail on what measures will be used to mitigate impacts on species (eg on pg 13-6 it says measures should be taken to ensure the wetland vegeta tion and assoc ia ted c ommunities a re not c ompromised without going into any further detail) Please review any proposed measures and provide details and commitments to undertake measurable actions

Response Detailed measures will be written in the CEMP OEMP and DEMP by SA Water The d ra ft EIS EMF and EMP outline wha t SA Water s EMP s should add ress

expec ted etc Please clearly state where you are committing to do something A table showing actual commitments would be useful

4 Vague and uncommitted language throughout the whole document

Response The South Australian Government is committed to the following actions in relation to the weir near Pomanda Island

Development of a CEMP OEMP and DEMP and submission of the EMP to relevant authorities including the SA EPA prior to any works being undertaken Incorporation of a fishway to suit large and small species A detailed submission to the MDBA for approval under the Water Act 2007 (Cwth) On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure Mitigation strategies and monitoring program as detailed in the EMP and in the amended Table 15-3 (see question 5 below) o The CEMP will be based on a risk management framework and an

environmental impact assessment (EIA) o Monitoring of water quality will be included in a water quality report to be

made available through the SA EPA

Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth

A summary of all projects follows Projects highlighted in green are completed or currently underway Orange highlighted projects are those currently being investigated and are likely but not certain to be undertaken Pink highlighted projects are those either in the early stages of planning and may be difficult to implement or are considered only a last resort solution due to other undesirable implications

Supplementary EIS for the temporary weir near Pomanda Island -54shy

Project StatusTiming Completed or Underway

Pipelines Potable Lower Lakes districts Irrigation Langhorne amp Currency Creeks

Potable construction completed January 2009 Irrigation EPBC referral (20094743) not controlled action if undertaken in particular manner due for completion October 2009

Feasibility study Long term management plan for adaptive management

30 March 2009 - Version 1 - under review prior to public consultation May 2009 Public Consultation on Version 1 30 June 2009 - Version 2 August - public consultation on Version 2 30 September 2009 - Final

Lake Albert Blocking bank in Narrung Narrows Pumping from Lake Alexandrina Lake Albert Future paper Pumping ceases 30 June 2009 Bioremediation

Blocking bank completed in May 2008 Pumping began 02 May 2008 Expert workshop held 8 April 2009 Paper prepared On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from the end of June 2009 and that a bioremediation program will be instituted

Dredging Murray Mouth Ongoing almost continuous operation since October 2002

The Living Murray (TLM) Icon Site management Icon Site condition monitoring Modelling Indigenous partnership Communications and consultation Water bids

Coorong planning document completed TLM progress report sea level impact assessment and alternatives to keep Murray Mouth open underway Condition monitoring ongoing Monitoring methodology plan completed sent to MDBA Modelling Stages 1 2A completed 2B December 2009 Interim modelling results for LLCMM due June 2009 Indigenous partnership program ongoing

Regulators Goolwa Channel Mouth of Finniss River Mouth of Currency Creek

EPBC referral submitted for public notice on 6 April 2009 Initial closure of the regulators 17 July 2009 Commencement of pumping water from Lake Alexandrina to Goolwa Channel 17 July 2009 Practical completion of the regulator within the Goolwa Channel 17 Sept 2009

Assessment of acid sulfate soils Rapid Risk Assessment Lock 1 to Wellington

Fieldwork for both completed Laboratory analysis underway completed for 24 priority wetlands below Lock 1 Survey work and modelling undertaken on inlets to 24 priority wetlands below Lock 1 Identification of priority sites creation of an action plan and application for funding underway

Lower Murray Reclaimed Irrigation Areas (LMRIA) Program

Completion of Program by June 2009 Completion of all mandatory works achieved 2008 Non-mandatory works nearing completion Post-program review to be instigated in near future

Upgrade of Pomanda Peninsula Causeway

EPBC Referra l not a c ontrolled ac tion 23 January 2009 Works currently underway in preparation should it be necessary to construct the temporary weir

Currently Being Investigated

Mitigation of acid sulfate soils using Mulch Revegetation Liming

Trials for all three currently underway Large scale application dependent on trial results and acidification time of the lower lakes

Supplementary EIS for the temporary weir near Pomanda Island -55shy

Project StatusTiming Increase inflows to Coorong South Lagoon REFLOWS Upper South East Drainage scheme (USED) water via Salt Creek Fairview Drain link

REFLOWS funding available REFLOWS cultural heritage underway REFLOWS native vegetation assessment almost complete REFLOWS landholder consultation complete REFLOWS community perceptions survey complete USED second stage feasibility study due 30 June 2009 USED 3 to 4 years to investigate and then implement Fairview initial landholder engagement commenced on hold until Reflows and Bald Hill decision made

Temporary Weir near Pomanda Island Draft EIS released for public consultation Supplementary EIS in progress Construction works to begin if Lake Alexandrina levels drop to -15 m AHD Could be avoided if sufficient freshwater flows obtained Early Planning Stages

Salinity build up in Coorong South Lagoon Dredging between north south lagoons Pump hyper-saline water to ocean

Both under preliminary investigation Pumping could only be done during autumnwinter to allow flows to replace pumped out water hence may not happen till 2010

Seawater intrusion into the lower lakes As a last resort to mitigate acid sulfate soils

EPBC referra l (EPBC 2008 4618) c ontrolled ac tion requiring EIS The final guidelines for the EIS released 13 March 2009 EIS targeted September October 2009

The projects can be divided into three categories

1 Long term plans looking to address the bigger picture with sustainable solutions Projects such as

Potable pipelines around lower lakes districts Irrigation pipelines Langhorne and Currency creeks Feasibility StudyLong Term Plan for Adaptive Management for CLLMM Lake Albert Future paper The Living Murray (TLM) programs Lower Murray Reclaimed Irrigation Areas (LMRIA) Program REFLOWS Upper South East Drainage scheme (USED) water into the Coorong via Salt Creek and Fairview Drain to Coorong link

2 Emergency measures designed to mitigate urgent issues with severe impacts Most are not long term and are designed to address a specific issue

Blocking bank in Narrung Pumping from Lake Alexandrina to Lake Albert2 Dredging Murray Mouth Goolwa Channel regulator Finniss River low level regulator Currency Creek low level regulator Pump water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel Rapid Risk Assessment of acid sulfate soils Assessment of acid sulfate soils from Lock 1 to Wellington Mitigation of acid sulfate soils

2 On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -56shy

o Bioremediation using mulch o Bioremediation using revegetation o Liming of exposed lake beds and o Liming of inflows

Salinity build up in Coorong South Lagoon o Dredging between north south lagoons and o Pump hyper-saline water to ocean

3 Last resort emergency measures only to be undertaken at critical trigger points when all other alternatives have been exhausted

Temporary weir near Pomanda Island Seawater intrusion into the Lower Lakes

Further details on each project are available if required

5 In several places throughout Chapter 15 monitoring is proposed as a mitigation measure by itself monitoring does not mitigate an impact it can only help inform when to implement a mitigation measure Please provide an actual mitigation response linked to monitoring

Response The Environmental Management Plan in Chapter 15 of the Draft EIS has been augmented in the Supplementary EIS SA Water is responsible for preparing the CEMP OEMP and DEMP Environmental Management Plan that will detail the mitigation strategies and monitoring program This will be written in conjunction with the contractor

SA Water will be responsib le to ensure tha t the c onstruc tion c ontrac tor s EMP inc ludes adequate monitoring protocols for water quality and other environmental issues throughout the construction phase The EPA DWLBC SA MDB NRMB NVC local council and other relevant agencies will be consulted on the content of any environmental risk assessment and mitigation measure In addition specific State approvals will be obtained these usually stipulate specific conditions to be included in an EMP or similar management tool

The Contractor EMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

See also 80

Table 15-3 has been amended

Table 15-3 Potential mitigation measures for water quality parameters

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Develop and implement a Soil Erosion and Drainage Management Plan in accordance with the Stormwater Pollution Prevention Code of Practice for Local State and Federal Government

Works are expected to be planned and carried out to minimise the effects of runoff and erosion on the site and downstream areas

Surface water quality

Ensure that erosion and sediment control measures are in place prior to commencing any earthworks

Supplementary EIS for the temporary weir near Pomanda Island -57shy

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Sediment control structures are expected to be established around all areas prone to erosion including stockpiles batters and drainage lines Careful placementremoval of embankment material to reduce turbidity

Scouring mud waves and bank slump are a potential consequence of installation of the temporary weir Scouring and mud waves may be reduced by controlling flows and spillway width while area of impact associated with bank slump is expected to be reduced by weir design and careful placement of embankment materials

Use of sediment curtains around weir placementremoval to limit effects of turbidity created with placement of material and subsequent mud-wave Stabilisation of River banks immediately following constructiondecommissioning Treatments may include

Revegetation

Placement of geofabric

Obtain EPA Endorsement of the proposed approach to surface water

Exception to allow placement of fill material to create weir structure

Wetland management Develop and implement a Wetland Management Plan to manage the change in flow patterns resulting from the construction operation and decommissioning of the proposed temporary weir

Develop and implement a Groundwater Management Plan for the project

Groundwater

Groundwater is expected to be monitored throughout the construction operation and decommissioning phases of the temporary weir project

Groundwater parameters which may require monitoring include

Confined and unconfined water levels

Salinity

Hydraulic gradient

Supplementary EIS for the temporary weir near Pomanda Island -58shy

Project PhaseParameter Potential mitigation measure

Monitoring is expected to take place both upstream and downstream of the temporary weir

Existing monitoring programs which may be relevant include

DLWBC OBSWELL database

RMCWMB groundwater monitoring program

CSIRO Water for a Healthy Country

Obtain endorsement of the proposed approach to groundwater monitoring from DWLBC andor the EPA

Develop and implement a water quality monitoring program based on existing programs and monitoring stations

Monitoring

If water quality parameters are exceeded the following measures may be implemented

Increase use of geofabrics and turbidity curtains to address inadequacies in turbidity management

Cease work if turbidity if triggers are exceeded until such time as the triggers return to desired levels

Aeration should monitoring indicate that oxygen is required

Mixing to prevent temperature stratification of weir pool

Mixing aeration to prevent temperature stratification of weir pool

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

6 The extent of the Ecological Character (EC) of the Ramsar site is greater than the fringing Wetlands It includes the bodies of water in the lakes the species in on and above Although the individual aspects of the EC are mostly noted in the EIS the summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Response Additional comment o be inserted in Errata Chapter Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir)

The ECD of the Coorong and Lakes Alexandrina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Those species that are not listed nationally are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetlands will persist

7 Is it likely that the water body of Lake Alexandrina will acidify during the no-flow period given the drop in water level If so how does SA propose to manage this Does this mean that the weir closure period will bring the real time management strategy water level acidification trigger forward

Response See page 22 and 23 of the Supplementary EIS

Supplementary EIS for the temporary weir near Pomanda Island -59shy

The South Australian Government is investigating and implementing a range of acid sulfate mitigation measure including application of limestone and bioremediation The possible use of seawater is also being examined (EPBC Act reference 20084618 and an EIS is currently being prepared Introduction of seawater will only be undertaken if the temporary weir is in place the acidification triggers are reached and relevant approvals in place

Water quality monitoring in Lake Alexandrina (eg at -10 m AHD) indicates alkalinity is high (between 170 and 250 mgL as CaCO3) which means the water has relatively good buffering capacity depending on the transport of acidity (fluxes) from exposed sediments During periods of no flow pulses of acid can be transported to the water by rainfall or seiching (wave action) events However given that sulfuric materials have already formed over large areas the higher risk of acidification comes with refilling of the waterbody when mineral salts can be dissolved and acidic porewater can diffuse into the water column (note some research indicates this could occur with freshwater or saltwater ingress)

Management trigger levels for alkalinity and pH have been developed and trends are being monitored fortnightly If any of the trigger levels are approached (ie at different alert levels) the Government of South Australia will instigate certain actions such as monitoring at a higher frequency or implementing limestone slurry dosing programs

The biogeochemical modelling points to waterbody acidification at either a pH less than 6 or water levels below -15 m AHD Further refining of the modelling and investigations of sulfide oxidation rates and acidity transport are being undertaken and early indications are that waterbody acidification is more complex than relating it just to water level As such the weir closure period may not necessarily bring forward Lake Alexandrina acidification

8 The EIS states there will be a number of plans that do not appear to be available yet it is difficult to assess the effectiveness of mitigation without seeing these plans When will these be provided

Response Development of plans and actions is ongoing Response to 4 above lists many of these including the Long Term Plan Many plans have been provided to DEWHA as they are prepared

9 The EIS indicates that disconnection is likely to occur for 2-35 months even though under worst case scenarios it could be up to 7 or 8 months (Table 10-6) The EIS assessment is based on no flow period of 3 months Is the reason for this because SA is currently receiving 896GL over the border and they anticipate getting at least this amount in the 2009-2010 water year and subsequent years Or is there other justification for the reasons for using 25-3 month disconnection This difference in time period could change the likely impacts on hydrology and water levels which are key determinants of ec olog ic a l c harac ter DEWHA s assessment will take into ac c ount the worst case scenario

Response South Australia is now guaranteed a flow of at least 896GL during 2009-10 as the 200GL required for Critical Human Needs has already been secured and is held in reserve Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream The estimated time for disconnection for the 696 GL scenario is not relevant

The Errata chapter includes replacement of references to 940 GL with 896 GL on pages 2-13 and 2-19 of the Draft EIS

The time required to fill the weir pool from approximately -15m AHD to +01m AHD will be approximately 25 3 months If it is necessary to fill the weir pool more slowly (eg to minimise damage to upstream wetlands banks and levees) the flow at Lock 1 will not be reduced and any additional water will be delivered into Lake Alexandrina through a by-pass structure

10 As specified in 1(g) of the EIS Guidelines can you please detail the interaction between this action and others in the CLLAMM

Response Discussed at 4 above

Supplementary EIS for the temporary weir near Pomanda Island -60shy

11 In Part 3 of the EIS Guidelines you are required to take into account the long-term options for the CLLAMM While the Department acknowledges the actions that are being undertaken to develop a long term solution how will this action limit long term options

Response As discussed in the Supplementary EIS South Australia considers that the weir if constructed will not limit long term options Long term options are being actively planned in the knowledge that the temporary weir may be constructed

12 Section 11 of the EIS Guidelines require the objectives of the EPBC Act to be addressed Can you please provide further information addressing these objectives

Response The Draft EIS endeavoured to address the Guidelines for the Proposed Temporary Weir This Supplementary EIS supplements this by the addition of the community consultation report and a detailed review of issues raised

The response to question 4 details all related actions that the government is taking in the Coorong and Lakes Alexandrina and Albert Ramsar site including the development of a comprehensive long term environmental plan that shortly will be released for community consideration

Objects of the EPBC Act

(a) In the face of unprecedented environmental degradation of the Ramsar site and matters of national environmental significance caused by low freshwater inflows we are undertaking substantial conservation and remediation work involving many South Australian Government agencies These are outlined in the Supplementary EIS

(b) (c) (d) Further specific actions to conserve natural resources and bio-diversity are likely to be announced shortly in conjunction with the Australian Minister for Climate Change and Water It is expected that majority of these actions will be undertaken by local government the community land holders and the Ngarrindjeri People

(e) As the South Australian agency responsible for the Environment and Heritage and one of the custodians of the internationally listed Ramsar site the Proponent seeks to c oopera tively imp lement Austra lia s interna tiona l environmenta l responsibilities

(f) (g) The South Australian Government acknowledges the Ngarrindjeri People as traditional owners within the area of their current Native Title Claim within the context of the Aboriginal Heritage Act 1988 The Ngarrindjeri People collectively and individually have been consulted and given an opportunity to comment on the Draft EIS along with all other stakeholders and members of the c ommunity The State Government is endeavouring to develop a formal overarching agreement with the Ngarrindjeri in relation to consultation and negotiation on a range of environmental and cultural matters of joint interest

Work with Aboriginal people to manage biodiversity cooperatively and contribute to the reconciliation of past actions

Comments on ESD are included at question 25

More specific comments

13 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

Response Noted Corrected in Errata

14 On pg 4-4 it says that 3 of the 4 pumping stations are complete with only Murray Bridge to be completed but in Table 4-4 on the same page and on pg 2-3 it says Swan Reach is the only pumping station still to be completed

Response Mannum and Tailem Bend are complete Swan Reach was completed late December 2008 Murray Bridge has 2 pumps modified for lower water level operation but we are delaying some work on one pump at Murray Bridge in order to test it (unshymodified) in order to be better able to confirm the lower limit of operation

DEH s Corp ora te Plan inc lud es the objective

Supplementary EIS for the temporary weir near Pomanda Island -61shy

15 Orange-bellied Parrot sec tion 752 doesn t mention samphire hab ita t

Response Firstly in the history of documentation relating to this EIS on the preferred habitat of the Orange-bellied Parrot There appears to have been some confusion over the use of the words saltmarsh and samphire

Samphire is used interchangeably in South Australia to describe

a) species in the genera Sarcocornia and Tecticornia (formerly Halosarcia and Sclerostegia) and

b) habitat dominated by such species

Thus saltmarsh and samphire are interchangeable terms to describe the same habitat

Food plants associated with samphire (or saltmarsh) habitat are certainly known to be used as feeding habitat by the Orange-bellied Parrot in the lower lakesupper Coorong with recent records from this habitat from the Snake Pit (Tauwitchere Point) and Sir Richard Peninsula (Beacon 19) in recent years (06-08) predominantly from Sarcocornia

However it appears that within South Australia the Orange-bellied Parrot is less dependent than previously suspected on samphire vegetation Recent observations in South Australia (2003-) suggest that the species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

While most records are within 10km of the coast Orange-bellied Parrots were recorded in winter in the Tolderol area (north-western shore of Lake Alexandrina) between 1981 and 1985 (John Eckert sightings lodged with Birds Australia) and there is an anecdotal record of this species foraging in the Wellington area at Nalpa Station

In the referral for the Pomanda Island causeway (EPBC 4676) it is stated that the Causeway upgrade could at worst disturb less than 014 ha of samphire shrubland With 1289 ha of this habitat within the Ramsar boundaries the maximum loss of samphire species would be 001 In addition Ecological Associates (2008) identify that samphire species regenerate relatively quickly after disturbance

16 The Great Egret Cattle Egret and the Caspian Tern are not dealt with satisfactorily (pp 7-3334)

Response The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in SE Qld and NE NSW (HANZAB3)

The movements of Caspian Tern are poorly understood partly resident partly dispersive and possibly partly migratory (HANZAB1) The species is commonly observed on fresh and marine waters foraging on the wing for fish

17 The potential decommissioning impacts (pg 8-7) says tha t The impac ts a re expec ted to be further assessed during the planning for the decommissioning p rojec t as the

3 Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks Oxford University Press Melbourne

Supplementary EIS for the temporary weir near Pomanda Island -62shy

decommissioning is part of the referred action details will need to be provided to determine what the potential impacts are

Response The nominal design life for the temporary weir is 3 years and therefore not all impacts of the decommissioning are able to be assessed at this point in time For example it is difficult to be able to identify projects where the removed rock can be usefully employed

There a re no Ramsar-listed wetlands between Lock 1 and the p roposed temporary weir site however the Coorong and Lakes Alexandrina and Albert Ramsar site extends someway upstream of the weir site

18 On pg 12-2 the EIS sta tes

Response The Coorong and Lakes Alexandrina and Albert Ramsar site extends approx ten kilometres upstream of the proposed weir site (at the apex) to a point that represents the confluence between Lake Alexandrina and River Murray proper The relevant sentence on Pg 12-2 has been reworded to say There a re no Ramsar-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ramsar site

19 On pg 12-15 the EIS says tha t the weir will ac c elera te d rops in wa ter level during the period of d isc onnec tion however all the downstream wetlands will supposedly have already disconnected due to drought conditions with the exception of wetland type O whic h is not expec ted to d isc onnec t It is not c lear what period of d isc onnec tion is being referred to

Response The period of disconnection being referred to is the time during which there will be reduced flow over the temporary weir from the River Murray channel into Lake Alexandrina nominally 25 3 months (as discussed under question 9 and page 13)

Reword Section 125 (pg 12-15) in its entirety to read

As deta iled in Sec tion 1241 a ll wetland habitats downstream of the temporary weir location are expected to be affected by the drought and by 2012 only Ramsarshywetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state

Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flow see page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

20 Throughout Chapter 12 the EIS refers to impacts on EPBC-listed flora and fauna species only but it should be considering all flora and fauna within the Ramsar site

Matters of Na tiona l Environmenta l Signific anc e as a matter of p riority however implic it in the EIS and in our Ramsar obligations are the impacts upon all flora and fauna within the Ramsar site Tortoises and Japanese Snipe are good examples of non-threatened species that have been or are likely to be affected by altered hydrology or water quality There is an infinite list of taxa that could be considered in detail some of which we know little about but much of this work falls outside the scope of the EIS

Response The EIS foc uses on threa tened spec ies and

The EIS refers to Matters of NES (eg EPBC- listed flora and fauna) that will still be occupying Type O wetlands which will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir Impacts on other Ramsar Wetland Types (ie the rest of the Ramsar site) were not considered because the impacts of the drought were considered to be the primary determinants of change in ecological character for those wetlands Further discussed in Supplementary EIS

Pred ic ted c hanges to p rimary determinants of ec olog ic a l c harac ter ) only lists the p red ic ted c hanges for 2 out of the 6 p rimary determinants

21 Table 12-4 (titled

Response Update Table 12-4 to include the following

Supplementary EIS for the temporary weir near Pomanda Island -63shy

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts (2010 2012)

Salinity Discussed extensively in Section 10 Water Level Discussed extensively in Section 10 Water Regime Discussed extensively in Section 10 Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

22 Sec tion 127 (Summary of Chapter 12) doesn t summarise the impac ts as a result of the weir only the impacts from the drought

Response Discussed in Supplementary EIS

23 There doesn t appear to be any c onsidera tion of the interac tion between the timing of construction and when migratory species will be present (eg no consideration on pp 13-78 of whether the timing of construction (potentially October-January) will impact on when the Orange-bellied Parrot will be there (potentially March-early November))

Response As indicated in chapter 13 of the draft EIS there is a low risk that construction will impact on OBPs Construction works are localised and OBP habitat is not affected The only impacts to migratory birds including OBP may occur during the actual construction phase (displacement and habitat loss) and are expected to be short lived

Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to minimise the impact on Orange-bellied Parrots may result in construction occurring when other migratory species are present Migratory shorebirds for example generally return in late August and spend the entire summer at the Lower Lakes

24 In Table 15-9 on pp 15-2526 it says that a fauna inspection will be carried out in the construction area before any vegetation clearance and that any fauna located within the construction area shall be either relocated or dealt with in accordance with recommendations made by the qualified persons more information is needed eg a decision tree flowchart

Response A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water and DEH This knowledge has been considered by the Commonwealth It is acknowledged that more specific instructions on how this can be ac hieved will be inc luded in the Contrac tor s EMP The p rojec t will ensure tha t expert advice is available throughout the duration of the construction phase

25 Please re-consider 163 ESD whole approach The purpose of the weir is to protect water supplies not to prevent degradation

Response They have become one and the same over the life of the project To secure water quality is to secure supply The emergence of acid sulfate soil threats has presented us with a major risk for the water to become un-potable

The transitory effects of the temporary weir are far less than the long term effects of low freshwater flows

Principles of Ecologically Sustainable Development Guidelines Attachment 1 Part 3A

(a) The social and economic consequences of a city of 12 million not having a secure water supply are incalculable

(b) The threats of serious or irreversible environmental damage are discussed extensively in the EIS Whilst there is no full scientific certainty we are continuing to undertake extensive measurements modelling trials and emergency actions to minimise environmental degradation caused both by low freshwater inflows and the short term impact of the temporary weir

with the purpose of the weir in mind Not South Austra lia s

Supplementary EIS for the temporary weir near Pomanda Island -64shy

(c) Both the construction of the temporary weir if required and the actions being taken throughout the Ramsar site will benefit the present and future generations

(d) Whilst the purpose of the temporary weir is to protect water supplies we will take all reasonable steps to minimise any impact of the temporary weir on biological diversity and ecological integrity For example we are now proposing to include a fishway

(e) South Australia is a buyer in the water markets as required and supports the COAG initiatives to improve water markets and trade water information and research and an enhanced urban water reform framework We see no specific application of the ESD principles of improved valuation pricing and incentive mechanisms in the case of the temporary weir

26 If pumping to Lake Albert was not continued beyond June 2009 how would this affect the projections for impacts on the site (water levels the no flow period ASS exposure salinity levels)

Response On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009

The potential for acidification in Lake Alexandrina is based on worst-case scenario rainfall and inflows during 2009 South Australia receives most of its rainfall in winter and spring so the extent of inflows and how trigger points may be favorably impacted by improvements will not be known until later in 2009 Over winter and into 201011 there will be some recovery in the water level (as has occurred each winter over the last three years of minimum flows) above the critical acidification level due to reduced losses and local rainfall Once losses increase during the warmer months the water level would again fall without any additional inflows

As described in the draft EIS under worst case conditions and with continued pumping to Lake Albert it was projected that the water level in Lake Alexandrina will reach the critical acidification water level of -15 m AHD at the beginning of January 2010

However with 220 GL delivered to Lake Alexandrina during 200910 the water level could be maintained above trigger level for the remainder of the 200910 water year 170 GL of the 220 GL requirement is now being secured by no longer pumping to Lake Albert The remaining requirement of 50 GL has already been secured by South Australia through the purchase of temporary water during the 200809 water year

The South Australian Government has assessed the potential savings that could be made by the decision to cease pumping to Lake Albert and how these savings combined with other water sources may delay the need to construct the temporary weir The 170 GL which now will be retained in Lake Alexandrina each year must still flow past Wellington to ensure that the salinity at the major pumping station at Murray Bridge remains below 1400 EC and therefore cannot be retained up-stream of Murray Bridge and used for other purposes

In conjunction with the additional 50 GL already purchased by South Australia (making a total of 220 GL for the full year) this will delay reaching the critical acidification level in Lake Alexandrina until mid to late 2010 maintain lake salinities at lower levels during this period than would occur if water levels continued to fall and maintain lower ASS exposure during this period

Updated model projections for both water level and salinity in Lake Alexandrina are presented below

Supplementary EIS for the temporary weir near Pomanda Island -65shy

_

Lake Alexandrina Level Forecasting from 16 May 2009

-24

-23

-22

-21

-2

-19

-18

-17

-16

-15

-14

-13

-12

-11

-1

-09

-08

-07

-06

-05

-04

-03

-02

-01

0

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Wat

er L

evel

(m A

HD

)

Projected Level w ith Maximum Net Evaporation (1982) Conditions

Level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Level

Critical Acidif ication Level (-15m AHD)

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Losses Maxmimum Net Evaporation (1982) Conditions

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 and no irrigation in 200910)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD unless stated

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank filled to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -66-

_

Lake Alexandrina Salinity

Forecasting from 16 May 2009

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

11000

12000

13000

14000

15000

16000

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Sal

inity

(E

C)

Projected Salinity w ith Maximum Net Evaporation (1982) Conditions

Salinity w ith level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Salinity

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Salinity Salinity of Flow to SA varies from 200 to 350 EC (f low rate dependent)

Losses as stated

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 no irrigation 200910 onw ards)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank f illed to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -67-

Water supply

the weir is expec ted to have negligible effects on sa linity between Loc k 1 and Wellington

27 On pg 10-22 the EIS sta tes tha t then why is the weir needed to protect water

quality

Response The temporary weir will have minimal impact on water quality upstream of the temporary weir in terms of the inputs (particularly salinity) from upstream The primary purpose of the temporary weir is to prevent contaminated water from Lake Alexandrina being pushed into the River Murray channel upstream of Wellington through wind seiching Monitoring and modelling have demonstrated that even at the relatively low salinities in the lake currently incidents where water with a salinity in excess of the maximum target level of 1400 EC penetrates upstream to Tailem Bend may occur

28 Figure 1-3 (pg 1-4) shows a water level of -15m AHD (ie the critical acidification date) being reached in January 2009 What is the interaction between this and the proposed Clayton blocking bank which would bring the critical acidification date forward by at least 2 weeks into December 09

Response Pumping water to the Goolwa Channel will bring forward the time when the trigger water level of -15m AHD is reached by about 2 weeks however the critical acidification date will be delayed with the 220 GL delivered to Lake Alexandrina during 200910 (see response to question 26)

Should more than 896 GL year be ava ilab le [flowing ac ross the SA border] the potential effects of the proposed temporary weir are likely to be reduced in the Lower Lakes Does this mean that any water in excess of 896 GL will be allowed to flow into the lower lakes

29 On pg 10-7 it says tha t

Response Water allocated to South Australia in excess of 896 GL plus private and state carry-over will be allocated on a priority basis within the state Some of this may be allowed to flow to the Lower Lakes The application of any water in excess of 896 GL per year has not been determined and it is also dependent on the reason why there is exc ess wa ter For example unregula ted flows whic h a re flows tha t the MDBA is not able to capture a re likely to flow to the lakes while regula ted flows a re ava ilab le for allocation to support irrigation

30 The 201 GL critical human needs volume is based on level 5 water restrictions (pg 4-6) what is the plan for moving SA onto level 5 water restrictions considering only 896 GL is expected in 2009-10 (pg 1-3)

Response The total volume available to South Australia in 2008-09 is currently predicted to be at least 1140 GL Areas in South Australia reliant on River Murray water are currently on enhanced level 3 water restrictions The extra saving in moving to level 5 is 17 GL which is negligible in terms of the Lower Lakes

The Metropolitan Adelaide water supply is derived from two sources Inflows in the Mount Lofty Ranges during winter 2009 will impact on any decisions on water restrictions There is currently no plan to increase the restriction level from the current enhanced level 3 restrictions as the difference may be provided by additional MLR inflows

what is the increase in SA water use based on Population growth

31 Fig 2-2 on pg 2-5 shows 40 GL more being demanded than supplied by 2025

Response The 40 GL is the net effect of increasing demand further water conservation initiatives as described in the Water Proofing Adelaide strategy and reduction in available sources of water due to the impact of climate change

The weir is expec ted to a ffec t the amount of wa ter held between Lock 1 and Wellington and provide confidence that an extra [emphasis added ] 685 GL is ava ilab le for South Austra lians The 685 GL represents the amount of water needed to fill the weir pool from -15m AHD to +01m AHD but is not extra water that is available for extraction

32 On pg 10-32 the EIS says tha t

this needs to be clarified

Response Agreed The extra volume could only be available as a last resort and drawing down this weir pool would jeopardise water quality (salinity) as there would be no through flow to the Lower Lakes

Supplementary EIS for the temporary weir near Pomanda Island -68shy

33 On pg 2-2 the EIS states that roof run-off stormwater and recycled water are used for non-potable purposes how much Has this reduced reliance on Murray water Also mentions desalination plant will this reduce reliance on Murray water

Response Use of roof-runoff and stormwater particularly in the northern suburbs of Adelaide has provided additional water to reduce the demand on the traditional sources River Murray and the Mount Lofty Ranges Predominantly these have provided non-potable water for new development and as such are preventing increased demand from the traditional sources

It is clear that in critical periods of drought the 100 GL Adelaide desalination plant currently under construction will reduce reliance on the River Murray

While the desalination plant will reduce reliance on the River Murray this does not necessarily have a direct impact on the flow to South Australia required to maintain salinity at a satisfactory level (target lt1400EC at Murray Bridge) None of these nonshytraditional sources will remove reliance on the River Murray and it should be noted that a minimum flow to South Australia of about 900 GL per year is required to maintain salinity at Murray Bridge at less than 1400EC which is required for all potable use whatever the level of demand for Adelaide and regional South Australia

what is their estimated reduced reliance on Murray water Pg 4-17

34 Strategies 1 and 2 on pg 4-13 same question

Response Water conservation and recycling reduce the average water extracted from the River Murray and the recently released Water for Good plan quantifies this However in periods of extreme drought the same water savings are traditionally achieved through water restrictions and consequently these initiatives do not greatly reduce the need for River Murray water during critical periods

35 What is the safe operating height of SA Water pumping off-takes (pg 4-2)

Response Following modification to the pumps the safe operating level is currently -22m AHD Prior to the modifications the safe operating limit was around -04m AHD The estimates of the critical limits for the pumping stations have varied over time as the river level has dropped and the pumps could be tested outside of their normal operating ranges

36 If the pumps can pump down to -22m AHD then why is the weir pool at +01m AHD Does this factor in evaporation of the weir pool during times of low flow which would lower the water level Or is this considering the water quality of the lower lakes How can this be the case when the weir expected to have negligible effects on salinity between Lock 1 and Wellington

Response This level is set taking into account the requirements of the temporary weir during the recovery phase If Lake Alexandrina becomes saline the temporary weir needs to maintain a physical separation between the river and the lake as the lake level increases to allow the saline lake water to be flushed to sea

The level of 01m is a compromise While a higher level (up to 075m AHD or higher) would be preferred to facilitate flushing of lake water to the sea the foundation conditions for the temporary weir are not suitable for such a high weir if the lake levels continue to drop

c areful p lac ement remova l of embankment material

37 In Table 15-3 on pg 15-17 it says there will be what does this mean

Response Careful placement removal of the weir embankment material during constructionremoval will minimise both the area and quantity of disturbed bed material and hence minimise the immediate water quality impacts (mainly turbidity) and the inadvertent release of sulphuric acid from the sediments

38 SA has previously indicated it would legislate to ensure removal of the weir has this been done When will it be done

Response No The temporary weir will be removed when the decommissioning criteria (as agreed by the Water Security Council and accepted by the MDBA) are met

39 How will additional water secured through SA water security strategy and efficiency measures be managed ie will any be provided to Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -69-

Response See response to Q29

40 Are there any the implications of predicted future water demand in SA on the period of time that the weir is in place

Response This is not expected to be material during the expected life of the temporary weir

Predicted future demand for potable water for the major off-takes will have minimal impact on the time the temporary weir is needed The temporary weir is required to prevent saline or acid contaminated water from the Lower Lakes entering the river channel until such time as the quality in Lake Alexandrina no longer provides a threat to these water supplies whatever the demand

41 Will salinity increase behind the weir in the weir pool Given that saline water sinks the water overtopping the weir may potentially be fresher water Will salinity levels in the weir pool build up to a point where it might impact on the offtakes

Response Large quantities of salt flow down the River Murray every day but it is largely mixed and therefore will not separate and sink Therefore salinity levels in the pool between Lock 1 and the temporary weir are not expected to impact on the offtakes (Note that there are saline groundwater inflows to the river which can cause localised pockets of salinity but this occurs in normal river operation and is independent of the construction of a temporary weir These pockets of high salinity eventually mix and the salt is carried away in the general water body)

In the absence of a temporary weir when more saline water from the lakes is forced under wind seiche into the river it does sink to the bottom rather than mix with the less saline river water and the saline water then moves upstream This is exacerbated by the differing depths of the water at Pomanda Island and in the river channel upstream of Wellington

Modelling indicates an initial rise in upstream salinity during the weir filling period and then after that no major change in the long-term Provided there is no significant input of highly saline water from Lake Alexandrina (the purpose of the temporary weir is to stop this) the salinity gradients generated by evapoconcentration of the relatively low salinity river water will not be sufficient to resist the natural mixing as temperatures and wind conditions change This has been demonstrated by the natural break-up of the saline intrusions on the bottom of the river due to inflows from Lake Alexandrina which have been identified through monitoring over the past year

42 Can SA provide the modelling on the 696GL scenarios with and without the weir on water levels the no flow period ASS exposure

Response Refer to the response to Q9

The flow scenario proposed is unrealistic as South Australia is guaranteed a minimum flow of over 896 GL in 2009-10 (including the reserve for Critical Human Needs and private carry-over) Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream

The requested modelling results will be provided but should not be taken as representative of any realistic scenario

Removal triggers (pg 1-6)

norma l opera ting levels in rela tion to Hume and Dartmouth and what period of time these levels have to be sustained for

43 No definition of

Response The MDBA states that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

44 How long to fill Hume and Dartmouth Dams and how likely is this What is the worst case scenario Best case Is the filling and operation of these dams likely to be impacted by MDBstate water management

Response It is not possible to predict how long filling these storages to this level may take Hume storage in partic ula r is quite vola tile and c ould easily fill and spill within less than one year Dartmouth storage is more likely to take longer but the average end of season

Supplementary EIS for the temporary weir near Pomanda Island -70-

level is commensurately lower Under continuing worst case conditions the storages will not reach these trigger levels

The filling of these storages could be affected by decisions by all jurisdictions regarding the management of the Murray-Darling Basin including future sharing and reserve arrangements

45 Why was this trigger chosen rather than one focussed around water made available to South Australia from shared River Murray water or based on discontinuationreduction of dry-inflow contingency

Response These triggers were determined because they are open and transparent They are based on the best available technical advice

The triggers were agreed by the Water Security Council and accepted by the MDBA

need to meet a ll triggers Can SA provide any indication about the likely timeframe in which all triggers would be met

46 The timeframes on the removal triggers are unclear

Response Removal triggers are directly related to the drought and how much water is expected to become available It is not known when these triggers will be met

The MDBA notes that the specific timing of removal is highly dependant on the seasonal conditions at the time Lake Alexandrina next fills above +01 m AHD

no water quality impacts from Lakes water quality in the lakes is unlikely to improve with the weir in place so how realistic is this as a removal trigger If it is decided that seawater needs to be introduced to manage ASS this is likely to delay removal of the weir given the inability to meet this trigger

47 Regarding the 3rd removal trigger

Response Water quality in the lakes is unlikely to improve until additional fresh water flows down the river and either dilutes the lake water or flushes it to the sea If inflows to the lakes over the temporary weir exceed evaporation the water quality will begin to improve through dilution Major improvement in quality will not occur until there is a discharge of water from the barrages which cannot occur until the water level is restored to at least +05m AHD The critical salinity level in the lakes has been calculated at 3000 EC If inflows are predicted to reduce the lake salinity to less than this value the potential impact of lake water on major water supply offtakes is considered acceptable If seawater has been introduced to prevent acidification the volume required to dilute discharge salt to the extent that this target of lt3000EC can be met will be greater than if no seawater has been introduced However the volume of inflows required to improve lake water quality to an acceptable level if the lake has been allowed to acidify is likely to be even greater

This trigger has been purposely expressed as water quality rather than salinity because no decision has been made on whether seawater is to be used to manage acid sulphate soils (EPBC Reference 20084618) or whether an alternative strategy is to be adopted

If seawater is not introduced acidification may introduce a number of other water quality issues that need to be resolved before the temporary weir can be removed

48 In relation to the salinity trigger how much water is required to flow in to reduce salinity levels to below triggers stated What is the likely timeframe on getting this volume

Response The volume of water required to dilute salinity in Lake Alexandrina to meet the removal trigger will depend on the quality of water remaining in the lake and when the dilution occurs At the time of closure of the temporary weir it is predicted that the salinity in Lake Alexandrina will be approaching 10000EC Salinity will increase to about 28000EC within 12 months due to river inflows and evapo-concentration and will be significantly higher if seawater is introduced

Figure 211 in the Draft EIS shows how salinity in Lake Alexandrina continues to rise with continued low inflows The volume of fresh water eventually needed to reduce the lake water below the trigger level depends on how long the drought continues Typically the salinity of water in Lake Alexandrina will be diluted by 30 just by re-filling the lakes to 01m AHD

49 If the Australian Drinking Water Guidelines (2004) say that 275 to 550 EC is the acceptable salinity of drinking water (pg 10-4) then why is the removal trigger set at 3000 EC

Supplementary EIS for the temporary weir near Pomanda Island -71-

Response The desirab le sa linity ta rget for d rinking wa ter supp lies in South Austra lia has been identified as 800 EC based on AWRC and WHO guidelines Many supplies do not always meet this desirable limit The removal trigger for salinity in the lakes has been set at 3000 EC higher than the maximum limit set for Tailem Bend (1400 EC) and much higher than the desirable limit for drinking water of 800 EC because based on experience and from the modelling results the risk of water from Lake Alexandrina raising the salinity at the major water supply off-takes above the maximum target level of 1400 EC is acceptable

50 No definition of what the water quality risks are and how these would be measured

Response Refer to response to Q47

The primary water quality risk is salinity and this is dealt with comprehensively throughout the document Additional water quality risks arise from water moving upstream for Lake Alexandrina if the lake has acidified (heavy metals metalloids nutrients) These risks are closely monitored through existing water quality sampling programs associated with a major public water supply Algal blooms (potentially toxic cyanobacterial in particular) present an additional water quality risk that is addressed in the Supplementary EIS The presence of algae is monitored closely through a program established when lake and river water levels started to decline This program which is in addition to the normal sampling for public water supply purposes includes regular airborne videography and infrared photography with immediate ground truthing of any sites identified through the aerial survey work

It is not possible to quantify all of the water quality risks unless the management strategy for ASS is known in particular whether a preventive approach using seawater is to be used or a remediation approach The full impacts of these options are currently being investigated for the EIS to allow seawater into the Lakes

51 Fourth removal trigger is subjective what does this mean in practice Confidence is immeasurable this alleged removal trigger is more on outcome of the other removal triggers being met than a trigger in itself

Response The confidence required is in the consistency and robustness of River Murray water resource projections in relation to being certain we will not return to a similar situation of extreme low water levels as we are currently experiencing in the near future which may require re-instatement of the temporary weir

To some extent the comment that this trigger is an outcome of the first 3 triggers is correct However this trigger is intended to allow for the considerable uncertainty around the management regime for ASS and changes to operating rules in the MDB

52 58 states that once the water level exceeds +01m AHD the weir will cease to serve any useful function How will the structure of the weir albeit below water level change flow rates past the submerged weir

Response The temporary weir will have very limited impact on flows once water levels return to greater than +01m AHD in the lakes When the water level exceeds 01m AHD the temporary weir becomes drowned but it still provides a (partial) barrier to saline river water moving upstream

The submerged weir will still allow the prevailing flow to pass Should flow rates exceed the design of the temporary weir action would be taken to widen the flow path

Additional modelling will be undertaken to identify any backwater impacts from high flows in a situation where the temporary weir has not been removed (eg 50 000 MLday) The presence of the temporary weir would still provide some benefit in restricting any saline flows from Lake Alexandrina in to the River Murray channel even if the temporary weir was d rowned

Wetlands

53 In section 1246 on pg 12-11 under the head ing Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion is c onsidered insignific ant as many of these species reproduce sexually and wind or bird-d riven seed d ispersa l This is only a consideration of impacts upon reproduction not a consideration of whether the plants will even survive to reproduce

Supplementary EIS for the temporary weir near Pomanda Island -72-

Response Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately 035 m AHD At a water level of -15 m AHD this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the waterbody and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the lake be refilled with fresh water to its pre-drought level (05 to 08 m AHD) while the below-ground storage organs remain viable

54 In Table 12-3 on pg 12-6 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type O it says that the slightly quicker decrease in water levels as a result of the weir is expected to bring forward the exposure of some sediment (including acid sulphate soils) that would otherwise have been exposed within 9 months how much acid sulphate soils Is this the 5200 ha mentioned on pg 11-7

Response Yes it is 5200 ha and this is reiterated in the Supplementary EIS As discussed in the Supplementary EIS the reduction of flow during the filling of the weir pool reduces the volume of water such that a further 5200 ha of sulfidic soils is exposed in Lake Alexandrina This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage acid sulfate soils will need to be implemented across the Lake in this case

55 In Table 12-3 on pg 12-8 for wetland type XI how can there be no recorded change at shy05m AHD but complete disconnection at -15m AHD

Response Presumably the comment refers to wetland type Xf not wetland type XI In Table 12-3 for wetland type Xf under Existing c ond ition (app roximately -05 m AHD) rep lac e No rec orded c hange with Not c onnec ted to the ma in body of the lake Will only be a ffec ted by ongoing d rought

Covered in Supplementary EIS

56 In Table 12-3 on pg 12-8 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type 4 the EIS says the weir is not expec ted to further impac t the management of seasonally flooded agricultural land when are they seasonally flooded Are the 25-3 months following weir closure going to prevent this seasonal inundation

Response In Table 12-3 for wetland type 4 under Impac t of p roposed temporary weir within Ramsar wetlands to existing text add whic h oc c urs a t wa ter levels gt 087 m AHD At the trigger level for weir construction (-15 m AHD) water levels will be 237 m below those that lead to inundation of surrounding agricultural land With or without the temporary weir in place water levels will remain well below 087 m AHD for the 25 3 month period following weir construction if it proceeds

Covered in Supplementary EIS

57 In Table 15-1 on pg 15-2 in the row on acid sulphate soils the EIS says that contingency measures may be c onsidered if a lka linity dec lined to a spec ified level what is this level How and where will this be measured What contingency measures would be implemented

Response Table 15-1 refers to Table 15-6 Potential mitigation measures to manage acid sulfate soils which contains the levels (100 and 25 mgL as CaCO3) In Table 15-6 for dot point 2 it c ould be c hanged to If a lka linity c onc entra tions dec line to 25 mgL as CaCO3 then immediate mitigation measures such as limestone slurry dosing are expec ted to be undertaken

Since August 2008 the SA MDB NRM Board has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (eg sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC

Supplementary EIS for the temporary weir near Pomanda Island -73-

It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (report 1 March 2009) The EPA also compiles the raw data in a spreadsheet available to South Australian government agencies

58 How will the Wetland Management Plan (Table 15-3 pg 15-17) manage the change in flow patterns Does have any suggestions on how to mitigate the impacts of the no-flow periodfirst year reduced flows period

Response Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

59 In Table 15-3 on pg 15-18 it mentions several potential water quality protection measures including use of a turbidity curtain stabilisation of river banks etc Under what conditions would each of these measures be implemented Same for contingency measures for acid sulphate soils outlined in Table 15-6 on pg 15-20

Response The EPA has pointed out that the EMP scope should include monitoring and managing turbidity impacts during construction and any EMP should be approved by relevant authorities including the EPA prior to any works being carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) which contains the overarching EMP SA Water and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Table 15-3 has been amended

60 Will there be any interactions with other referrals Will the presence of the weir impact on the Goolwa Channel referral

Response The temporary weir is part of a planned progressive response by the South Australian Government to worsening conditions in the Lower Murray in South Australia This Cabinet approved response plan is based on water levels in the barrages weir pool The critical trigger for the temporary weir is -15m AHD The trigger for the project to pump water to Lake Albert was -05m AHD and the trigger for the proposed Goolwa Channel Water Level Management Project is -12m AHD These actions are all linked as part of the overall response strategy The presence of the proposed temporary weir will not impact on the Goolwa Channel project as the latter project will be constructed well prior to the proposed temporary weir near Pomanda Island

61 It is likely that the presence of the weir may adversely impact on the recovery and management of the ecological character of the and therefore in the implementation of the long term plan for the site Does SA have any suggestions about how this will be managedmitigated

Response The temporary weir will not adversely impact on the recovery and management of the ecological character and will assist in preserving the range of options that can be considered under the long-term management strategy If the temporary weir is not constructed and the area acidifies or a greater volume of seawater is required to prevent this the detrimental impacts on the long-term plan will be greater

62 Page 10-25 will SA be purchasing water to ensure that the hydrological disconnection associated with the filling of the weir pool is reduced from 3 to 1month Please provide details under what circumstances would this occur

Response The South Australian Government is committed to pursuing a fresh water solution for the Lower Lakes including the purchase of water from the market However

Supplementary EIS for the temporary weir near Pomanda Island -74-

no commitment of additional water to the Lower Lakes can be made until the winter 2009 inflows are known

Re-wetting of upstream wetlands

63 Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

THIS SECTION DOES NOT EXIST and they do not appear to be described elsewhere (pg 10-10 also mentions likely changes to groundwater interactions and the re-wetting of dried sulfidic sediments and the associated ecological effects that would result and refers to Ch 15 for management tha t s in p lac e) mitiga tion measures mentioned aga in on pg 11-9 but no details

Response The reference to section 1554 should read 15412 and has been corrected in the Errata to the Supplementary EIS Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant Further details are provided in the response to question 64 in regards to ASS mitigation and management of wetlands above Pomanda Island All appropriate approvals for structures will be sought through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project

64 As the weir pool fills and upstream wetlands are re-wetted there exists a real potential for the introduction of low pH water with high metal concentrations into the River Murray (pg 11-8)

Response Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on potential impact refilling wetlands will have on water quality of the Main River Channel and ecological impact of further acidification of wetlands

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the MDBC Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from DEH project identifying acidification remediation options for the Lower Lakes Construction of structures and other on-ground works for remediation at priority wetlands and Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRM Board is managing the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project with a steering committee comprising of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRM Board DEH DWLBC MDBA SA Water EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of 01m AHD CSIRO have undertaken a preliminary assessment of the ASS hazard for each of the 75 wetlands An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of each wetland will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and

Supplementary EIS for the temporary weir near Pomanda Island -75-

ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island eg wetlands providing important aquatic refuges

65 Which wetlands will be re-wetted What are their sizes water levels condition etc

Response Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at +01m AHD The Table below provides information of the c ommenc e to fill level surfac e a reas and ASS management assessment for eac h of the 25 wetlands

NAME

SA (ha) at pool (~075m AHD)

SA (ha) at 02m AHD

commence to fill m AHD

Require ASS management

Riverglades 446 196 -051 Yes

Wellington Marina lt 191 lt 191 lt -080 Needs reassessment

Saltbush Flat 855 88 -025 No

Teal Flat Hut 202 15 -019 Yes

Walker Flat South Lagoon 888 601 -010 Yes

Wellington North (Murrundi) 9 32 -010 Yes Lake Carlet 3457 2998 -065 Yes

Devon Downs North 2627 822 -040 Yes Lake Bywaters 388 321 -017 No Marks Landing 1929 1453 -060 No

Coolcha Lagoon 1284 436 -045 Yes

Tailem Bend 957 811 -057 Yes

Younghusband 223 23 -010 Yes Younghusband West 1089 887 -062 Yes Caurnamont 903 464 -021 No Craignook 369 208 -002 Yes

Forster Lagoon 80 641 -022 No Henley Park 224 177 -027 No Bow Hill 475 140 -033 No Mannum Swamps 1977 1450 -035 Yes Mason Rock 258 91 -046 Yes Reedy Creek 986 436 -004 Yes Priess Landing 5 29 -069 No

Teal Flat 82 476 -011 No

Wongulla Lagoon 124 365 -046 No

Total 24449 13161

66 In the final paragraph on pg 12-16 the EIS says that re-wetting could potentially cause water in these wetlands to become acidic (if acid sulphate soils are re-wetted) which c ould c ause the following ac id ity would then remob ilise meta ls c onta ined within the sediments causing disease or death in fish due to metal toxicity Should this be experienced management measures identified in Chapter 15 will need to be undertaken What a re the management measures How will SA know if this has occurred (ie monitoring)

Response Refer to response in Ref 64 in regards to management of potential risk of ASS in wetlands inundated at 01m AHD The Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project incorporates the development of a monitoring program to assess the success of the ASS mitigation strategies and ecological impacts This will include the monitoring of water quality metals biota such as fish groundwater and vegetation

67 What will be the objectives of the management plan for re-wetting exposed acid sulphate soils How will it achieve these objectives (Table 15-6 pg 15-21)

Response The objectives of the management plan for re-wetting exposed acid sulphate soils are

To mitigate the risks of acid and metal mobilisation to the main River channel water quality and biota of the River Murray and associated wetlands

Supplementary EIS for the temporary weir near Pomanda Island -76-

Mitigate the risk of acid and metal mobilisation within the wetlands above Lock 1 when they are refilled and Ensure the development of ASS mitigation methods incorporate the environmental values of each of the wetlands

The objectives will be achieved through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project which will develop site-by-site management options for ASS hazards The risk assessment has been undertaken which has identified 14 wetlands that require management of ASS hazard Management options are currently being developed and may include regulating structures and other methods such as neutralising agents mulching and revegetation with the aim of ameliorating the risk to the main River channel due to the rewetting ASS hazard wetlands

68 Will the rewetting strategy for ASS areas in the weir pool affect the time it takes to fill the weir pool and therefore prolong the period of no flow to Lake Alex

Response The refill volumes for each of the 25 wetlands that will be inundated at 01m AHD with the construction of a temporary weir near Pomanda Island are currently being calculated using modelling and survey work It expected that the total volume of water required to refill these wetlands will be insignificant in relation to the volume of water required to fill the River channel and would not prolong the period of no flow to Lake Alexandrina

With only 3 of the 75 wetlands in this reach currently wet due to the low River levels it is important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island The re-wetted wetlands will provide important aquatic refuges and breeding opportunities for biota

Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

Threatened and migratory species

69 On pg 13-13 the EIS says The lac k of c onnec tivity [ie as a result of the weir b loc king migration] is expected to also hinder gene flow between populations potentially leading to a decrease in diversity in both Murray Cod and Murray Hardyhead populations if it c ontinues for a suffic ient period What would be a suffic ient period in this c ase Would three years (the design life of the weir) be a sufficient period Obviously for Murray Hardyhead even one year of interrupted reproduction could be significant as the species only lives for 2 years (pg 13-14)

Response A fishway to suit large and small species will be included in the weir design and design is currently underway

70 At what water level will the Swamps of the Fleurieu Peninsula disconnect from the main body of Lake Alexandrina (as per pg 13-4)

See page 32 of the supplementary EIS under the heading Impacts upon tributary wetlands

71 Lack of detail in section on Orange-bellied Parrot (pg 13-8) to exactly where will vehicle movement be spatially restricted How will the creation of new tracks be limited What vegetation will be cleared and how much

Response Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coor ong_Survey_lowpdf

In order to gauge the potential impact of the construction of the temporary weir on local biodiversity a thorough ecological survey of the immediate area in Spring 2009 is

Supplementary EIS for the temporary weir near Pomanda Island -77-

desirable Survey results can then inform relevant mitigation strategies to be included in the EMP

Construction activities on (Pomanda Island) will be restricted to along the northern edge of the island and locally around the abutment It is expected that the temporary weir will cause a minor loss of some of the reed beds along the western access road to the construction site due to the need to construct a wider road for truck traffic The construction footprint will be minimised as far as practically possible by minimising the road width and avoiding the reed beds where practically possible Construction activities on the eastern side will be localised to the immediate area around the abutment The landscape on the Eastern side is characterised by farmed paddocks Hence no reeds (and no habitat of the Orange bellied Parrot) are expected to be impacted on the Eastern side

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

72 In Section 1352 on pg 13-9 rela ting to the Southern Bell Frog it doesn t mention tha t the frogs have been found at Pelican Lagoon (pg 7-24) the section goes on to mention that the site at which the southern bell frog was recently recorded is expected to be disconnected from the water when Will the regulated pumping system continue to operate

Response The main body of Pelican Lagoon where Southern Bell Frogs (SBF) have previously been recorded (River Murray Wetlands Baseline Survey 2005) has been dry since 2007 It is unknown as to whether SBFs are still located in the dredged area closest to the river It is expected that this dredged area will remain inundated at +01m AHD but the rest of the wetland will remain dry

73 Where is the previously occupied southern bell frog habitat near Wellington How will the raised water level help frogs to recolonise this habitat (pg 13-10)

Response The previously occupied site for the Southern Bell Frog near Wellington is called Ferry Crossing (Coordinates139386 -35337) The recording was in the 2000 frog census on 15 September 2000 numbers were identified as few The only other areas where they have previously been recorded within the Lower Lakes are at Tolderol Game Reserve and Clayton (Dunn Lagoon) These sites are to the West of Wellington on the shores of Lake Alexandrina

The raised water level of the weir pool will re-hydrate the wetland and provide re connection with the main river channel This in turn enables the re-establishment of emergent and submergent vegetation within the wetland providing suitable habitat for the species to colonise and reproduce Reproduction requires still or slow moving water (Australian Government 2009)

Australian Government 2009 Significant Impact Guidelines for the vulnerable growling grass frog (Litoria raniformis) EPBC Act Policy Statement 314

74 An Environmental Management Plan is proposed as mitigation to the likely impact of disruption to Southern Bell Frog tadpole migration (Table 16-1 pg 16-3) how will the EMP mitigate this impact Need more information on the potential for the weir to disrupt the dispersal and migration of southern bell frog tadpoles (pg 13-10)

Response This response takes into consideration the history of inter-governmental documentation on this point in relation to the proposed Pomanda Island Temporary Weir and a lso the Dra ft EPBC Ac t Polic y Sta tement 314 Signific ant impac t Guidelines for the vulnerable growling grass frog (Litoria raniformis) [= southern bell frog] (Feb 2009)

Environmental conditions habitat and breeding

The preferred habitat for breeding of the southern bell frog is high emergent vegetation cover (eg Phragmites and Typha) and still or slowly-moving water (Stratman 2007 DEH 2009) Current conditions in the Lower Lakes region are poor and breeding is unlikely to be occurring in the region at the moment It is unlikely that breeding will occur immediately downstream of the temporary weir in the short-term Immediately upstream of the temporary weir it is likely that habitat conditions will be maintainedenhanced (see also page 30 of this document)

Supplementary EIS for the temporary weir near Pomanda Island -78-

Migration of southern bell frog

It is now considered that the original comment in the draft EIS of The likely impacts on this species are confined to possible Interruption to dispersal and migration of tadpoles Additional pressures resulting from the construction and operation of the temporary weir include short term changed water regimes water chemistry and localized noise As no individuals have been recently recorded at the proposed site these local disturbances are not expected to impact the population was incorrect in its reference to tadpoles The adults of the species are highly mobile (movement of up to 212 m in a single night has been recorded referred to in Schultz 2008) Less is known about the mobility of tadpoles Tadpoles may be involuntarily swept over the temporary weir during significant flow events The top height of the proposed temporary weir is lower than the normal operational sill level at the Goolwa barrages so the structure will only present a barrier to dispersal of the Southern Bell Frog during unfavourable conditions such as those that have prevailed for the last 18 months

Since adult frogs are highly mobile the causeway and abutments associated with the temporary weir may impact on the movement of adults along the banks of the river corridor Experimental developments in Victoria have used culverts or pipes placed beneath roads as corridors to try to link populations however Bell Frogs have not been observed using them to date (G Heard personal communication)

Survey

The SAMDB NRMB advised that a targeted frog survey was needed to determine whether Southern Bell Frogs still remain in the vicinity of Pelican Lagoon prior to the development of the Environmental Management Plan

DEH undertook a habitat preference survey during March 2009 and a follow-up survey is planned for Spring and Summer 2009 to assess population numbers The rapid assessment of suitable habitat for the Southern Bell Frog (March 2009) was conducted around the perimeter of Lake Alexandrina and Lake Albert with survey sites stretching along the edge of Lake Alexandrina from Milang to Wellington then Wellington to Meningie along Lake Albert around to Narrung The result of this habitat assessment is a proposed targeted species survey in line with the original project objectives

As indicated in Figure 7-4 of the Draft EIS L raniformis has been detected at wetland habitats around Lake Alexandrina and in the lower reaches of the Murray River upstream of the lake including locations near Narrung Point Malcolm Wellington and around Milang Most of the sites based on habitat mapping undertaken by DEH are characterised by permanent water and to some extent reedbeds

Mitigation

The comment on mitigation that was included in the draft EIS is relevant

All construction operation and decommissioning activities are expected to be done in accordance with an Environmental Management Plan A survey for this species is expec ted to be c onduc ted in 2009 to better understand the p resent d istribution The initial assessment to indicate likely target sites (preferred habitat survey) has now been completed and the follow-up survey is planned for spring summer later in 2009

75 On pg 13-11 the EIS says that the Yarra Pygmy Perch are more commonly found in the well-vegetated lake margins and the channels of Hindmarsh Island and the lower ranges of the eastern Mt Lofty Ranges tributaries but that these areas are currently disconnected from the main body of Lake Alexandrina (also on pg 14-1) When did the channels of Hindmarsh Island disconnect Yet it is stated in the EIS the eastern Mt Lofty Ranges tributaries (Currency and Finniss) a ren t expec ted to be d isc onnec ted until lake levels drop to -12m AHD (pg 10-1) do you mean Angas and Bremer

Response refer to the discussion on page 23 of the supplementary EIS regarding Connectivity of Surface and Ground Waters

76 Why do PIRSA Fisheries have a policy of not re-stocking fish species (pg 13-14) and what is different about these circumstances that would mean it is now a suitable option

Response PIRSA Fisheries advises that in the absence of a fishway stocking of fish to increase populations in a degraded habitat is unlikely to result in a net increase in the population However as the water is pooled upstream of the new temporary weir there could be some limited restocking as the environment improves to allay any concerns

Supplementary EIS for the temporary weir near Pomanda Island -79-

that cod populations have suffered from the weir works The PIRSA website has a policy paper4 which explains why large scale restocking is not supported (there are implications of spreading diseases in wild populations from those that have been housed in aquariumsgrown in aquaculture there is also the risk of limiting genetic diversity if stock have been bred from only a few source fish and a series of other issues)

In regards to the broader issue of re-stocking native fish species within the site that have been lost to the freshwater environment due to their complete disconnected from the lake re-stocking before recovery of the ecosystem is not appropriate Upon recovery of the ecosystem and re-establishment of an appropriate freshwater ecosystem these species will either re-colonise from elsewhere or if only located regionally re-introduced via a stocking program An existing program is in place whereby populations are being bred in captivity to allow later re-introduction in the future of EPBC listed (Yarra pygmy perch and Murray hardyhead) and regionally significant species (Southern pygmy perch River Blackfish and Southern Purple-spotted gudgeon) We are presently in the situation where for some species (those listed above) there are no remaining genetically-distinct populations remaining in-situ so the only option is to reintroduce those held in captivity if we want the population to persist Murray cod are believed to be a single genetic unit across South Australia and hence re-population from upstream populations should enable recovery This could be supplemented by a breeding program but would be subject to a complete collapse of the SA South Australian population and approval from PIRSA as would the re-introduction of other species presently held in captivity and would be subject to specific testing and satisfaction of relevant conditions

In addition to these potential activities a fishway is now being included in the design for the temporary weir to enable the egress of species from the lake environment into the river channel above Wellington

77 What is the evidence that Murray Cod and Murray Hardyhead are able to withstand high turbidity conditions (pg 13-15)

Response No data on the tolerances of Murray Cod and Murray Hardyhead to high turbidity conditions are available Evidence on tolerance to relatively high turbidity is correlative Both of these species are distributed across lower regions of the Murray-Darling Basin in areas subject to relatively high turbidity Turbidity in the River Murray in South Australia is highly variable and largely influenced by discharges from the clay-laden Darling River (Woodyer 1978) Turbidity at Morgan averaged 516 NTU between 1994 and 2004 with peaks as high as 304 NTU (Westwood and Ganf 2004) Turbidity in Lake Alexandrina is also highly variable with mean values between 1975 and 1978 varying from a high of 93 NTU to a low of 9 NTU with localised values as high as 150 NTU recorded (Geddes 1988)

78 What would the parameters be for reintroduction of Yarra Pygmy Perch andor Murray Hardyhead (pg 13-16)

Response The reintroduction of the Yarra Pygmy Perch and the Murray Hardyhead would be undertaken once the habitat has been rehydrated and the keys components to their survival are in place such as

There is a level of confidence inflows into South Australia will be able to sustain the habitat at least in the medium term Habitat structure has recovered (eg aquatic plants) sufficiently to provide for o Spawning o Shelter o Food source and o Predation avoidance Water quality parameters are within tolerances (specified in the draft EIS) of each species such as o Salinity o pH o Dissolved oxygen o Water temperature o Turbidity and o Concentrations of contaminants particularly Aluminium

4 httpwwwpirsagovau__dataassetspdf_file000950895Stock_enhancement_policy_Aug_07pdf

Supplementary EIS for the temporary weir near Pomanda Island -80-

For Murray Hardyhead the following ranges of parameters have been utilised for reintroduction at a Lower Lakes site

EC 2000 30000 EC

DO gt50 mgL (ANZECC WQ Guidelines)

Turbidity 2-200 ntu (ANZECC WQ Guidelines)

84PH 70

Yarra Pygmy Perch would have similar parameters but with a much lower salinity range

79 On Pg 14-7 it says that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB what noise levels will construction create

Response At this stage it is difficult to predict what the average noise level might be Presumably levels will fluctuate and for short periods of time the 56db level may be exceeded Important also in the equation is the distance of the waterbirds from the noise source If the equipment levels a re say 85dB(A) then they ll d rop to 45db (A) within 100m

There are no wetlands on the eastern side near the abutment We expect any areas around Low Point populated by birds to receive noise levels similar to that from a busy highway This same comment will apply for the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels so it is assumed they would occur further north into the wetland area

Monitoring of EPBC-listed species throughout the project is expected to occur to ensure construction operation and decommissioning activities do not impact on EPBC-listed spec ies how will monitoring ensure this This can only work if particular contingency measures are undertaken if a particular measure is observed during monitoring

80 On pg 15-24 it says tha t

Response Monitoring during operation of the weir Monitoring efforts will be coordinated as part of the SA MDB NRMB s na tura l resourc e c ond ition monitoring program It will include additional monitoring efforts as per expert advice

Monitoring during the construction and decommissioning of the weir It is recognised that the monitoring of the EPBC listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life breeding cycles The monitoring focus will be of an observational nature mainly in regards to compliance monitoring to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by Commonwealth and NVC) and the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora amp fauna expert advic e if warranted In add ition the Contrac tor s EMP will identify based on a risk assessment which specific mitigation and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations is recorded

Fishway

81 One of SA s river hea lth ob jec tives under the River Murray Ac t is Barriers to the migra tion of native species within the River Murray system are to be avoided or overc ome (pg 3shy36) The weir would obviously impede the migration of native species without appropriate measures eg fishways

Response As explained in the Supplementary EIS a fishway is now included in the design for the temporary weir SARDI have indicated that they have sufficient knowledge to be able to design a fishway without the need for further site survey work

82 On pg 5-5 the EIS says that no provision is necessary for fish passage

Response See response to 81

83 The weir may impede upstream movement of juvenile and adult (spawning) Murray Cod and would possibly affect the downstream drift of larvae into if lake if spawning in the

Supplementary EIS for the temporary weir near Pomanda Island -81-

river was to occur (pg 7-29) possibility of fishway to allow larvae movement or other mitigation measures

Response See response to 81

84 On pg 13-12 the EIS says that the weir is expected to limit migration abilities

Response See response to 81

85 Why wouldn t Murray Cod use the fishway (Tab le 15-9 pp 15-2526)

Response Due to concerns about the lack of a fishway a design process has been initiated with the assistance of consultants to determine a suitable design concept that would allow passage of both NES and other fish species A concept design is expected to be available in July 2009 The inclusion of a fishway has a number of challenges not the least of which is the initial desire of the fish specialists to pass all the normal flow of approx 1 GLday through the fishway rather than over the spillway

86 Construction of the weir embankment begins when water levels in Lake Alexandrina are between -05m and -10m AHD (pg 5-11) however on pg 12-17 it says construction is preposed to commence when lake levels are at -11m AHD which will occur in October 2009 according to Figure 1-3 and then in Table 16-1 on pg 16-2 it says that construction is proposed to commence at 9 months before Lake Alexandrina is predicted to reach shy15m AHD

Response We will commence work at the latest date regardless of the water level that will allow closure of the river by the required deadline date It is expected to take approx 9 months from the award of contract to closure of the river but the weir construction will not be completed until a number of months after the closure date

87 2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Response South Australia is guaranteed 896 GL of dilution and loss flow plus 201 GL of Critical Human Needs reserved from 2008-09 The figure of 940 GL was a possibility in December 2008 but should not be used

The graphs provided clearly state 896 GL flow for 2009-2010

88 A dilution flow of 696 GL per year is available to SA which is used to maintain salinity levels at Murray Bridge below 1400 EC (pg 2-13) however on pg 4-5 it says than 200 GL in addition to the 696 GL is needed to maintain the salinity at this level at Murray Bridge on pg 10-7 it says that 695 GL is the dilution flow

Response The dilution and loss component of Entitlement Flow guaranteed to South Australia under the Murray-Darling Basin Agreement is 696 GL per year This does not meet the normal system losses within South Australia (average about 1130 GL per year) and this flow does not dilute salinity sufficiently to maintain lt1400EC at Murray Bridge Modelling has shown that an additional 200 GL is required to maintain salinity at Murray Bridge at lt 1400 EC (ie a total flow of 896 GL)

As stated in the response to question 9 South Australia is now guaranteed a flow of at least 896GL during 2009-10 The 896 GL includes 201 GL extracted for Critical Human Needs

Note that the 201 GL for Critical Human Needs serves a dual purpose in that it also contributes to the dilution of the salt loads as well as being extracted mainly in the lower reaches of the river for use in the potable water supply system

89 The text on pg 2-15 says that it is predicted that by May 2009 salinity in Lake Alexandrina will be about 7260 EC however Fig 2-11 on the same page and Fig 1-4 on pg 1-4 show that salinity is predicted to reach only just over 6000 EC by May 2009

Response Both graphs are the same and by May 2009 it was projected that the salinity would be around 6000 EC Current salinities indicate that this projection will be accurate The figure of 7260 EC on page 2-15 is incorrect and is corrected in the Errata

90 It would require 220 GL in 200910 and 365 GL in 201011 to maintain the lakes at 10cm above the critical acidification level [ie maintain the lakes at 1-4m AHD (sic)] however it is unclear if this means water flowing over the weir or additional water purchased from upstream (pp 4-78)

Supplementary EIS for the temporary weir near Pomanda Island -82-

Response South Australia is committed to providing a minimum River Murray flow of 350 GL per annum to Lake Alexandrina via Wellington This minimum flow is required to maintain potable water quality (salinity not exceeding 1400 EC) at the SA Water Corporation major pumping station at Murray Bridge

The cessation of pumping from Lake Alexandrina to Lake Albert preserves approximately 170 GL per annum in Lake Alexandrina and reduces the additional water requirement for 200910 from 220 to 50 GL and the requirement for 201011 and subsequent years to 195 GL per annum The 170 GL annual savings is a subset of the 350 GL annual commitment

The additional 50 GL (200910) and 195 GL (201011) requirements are over and above the 350 GL commitment and could be sourced from improvements in River Murray flows improvements in eastern Mount Lofty ranges tributary flows better than worst-case rainfall directly over Lake Alexandrina (Lake Albert is now under alternative management) better than worse case evaporative losses and purchases from intra and interstate

91 In 2007-08 SA was supplied 1564 GL of water and the River Murray supplied 95 of this (Table 1-1 pg 1-2 2) however on pg 2-4 it says that in 2007-08 SA Water provided SA with over 176 GL of water 95 of this was sourced from the Murray

Response Table 11 may be poorly labelled The figure of 1564 GL in 2007-08 is the demand from the Metropolitan Adelaide Water Supply System It includes water pumped through the Mannum Adelaide pipeline system and the Murray Bridge Onkaparinga pipeline system so therefore covers Adelaide plus the surrounding areas supplied from these pipelines The 176 GL figure in 2007-08 represents the above demand plus the usage from the other two major pipeline areas supplied from below Lock 1 (ie Swan Reach amp Tailem Bend)

92 On pg 2-12 the EIS says that in 2006-07 SA Water provided SA with just over 245 GL of water approximately 90 of which came from the Murray however in Table 1-1 on pg 1-2 2 it says SA used 1805 GL 79 of which came from the Murray

Response See Response to 91 above

Supplementary EIS for the temporary weir near Pomanda Island -83-

Supplementary EIS for the temporary weir near Pomanda Island -84-

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report

85

1 Introduction

Community Consultation Report purpose The Community Consultation Report is a companion document for the Supplementary Environmental Impact Statement (EIS) for temporary weir near Pomanda Island This Report is the record of activities completed during the public consultation period and a record of the submissions received on the draft EIS

This document demonstrates that the Department for Environment and Heritage (DEH) created a public interest context for the Environmental Impact Statement process

The Department gathered processed and responded to public submissions so that the Supplementary EIS was appropriately produced

Objectives for this Report are

to meet the requirements of the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act)

to record the actions of the Community Consultation process

to record all submission summaries and a response to them This is a significant aspect of the Community Consultation Report (Appendix IX)

to demonstrate that a diligent transparent and effective process was in place which optimised receipt of public submissions relevant to the draft EIS

Summary This document overviews

four Community Information Sessions about the Draft EIS for the general public targeted consultations with Ngarrindjeri and ten other specialist groups media generated during the consultation period processes for receiving submissions and for developing the Supplementary EIS

2 Community Information Sessions Advertising and materials distribution prepared the way for the Community Information Sessions

Community Information Sessions were advertised using newspaper advertisements the DEH website and the Coorong Lower Lakes and Murray Mouth Project (DEH) email Bulletin lists (See Appendix VI)

Draft EIS materials (CD hard copy Executive Summary) were distributed widely free of charge The full text Draft EIS was also made available in appropriately targeted local government offices and schools and a number of full text Draft EIS Appendices were also available Hard copy Draft EIS were available for $100 from one Adelaide retail outlet (See Appendix VI Distribution List)

Four Community Information Sessions were held as follows

Murray Bridge Tuesday 24 March 2009 1000am - 1230pm Uniting church Worship Hall Registered attendees 50 people

Meningie Tuesday 24 March 2009 300pm - 530pm Meningie Bowling Club Registered attendees 47 people

Goolwa Friday 27 March 2009 1000am - 1230pm Centenary Hall Registered attendees 93 people

Clayton Bay Friday 27 March 2009 400pm - 630pm Clayton Community Hall Registered attendees 53 people

Supplementary EIS for the temporary weir near Pomanda Island -86-

A total of 243 people attended the four Community Information Sessions

The agenda for these meetings were as follows

Community Information Sessions Agenda

Facilitator Lindsay Holmes (Meeting Success)

Session Length 25 hours

Timing Task Responsible person

(mins) 5 Welcome and Ground Rules Lindsay Holmes Welcome to Country 5 Explain purpose of Session Peter Croft 5 Introduce specialist panel Lindsay Holmes 20 Explain session agenda and process Hon Dean Brown

Water Presentation 25 EIS introduction presentation Russell Seaman 5 How to respond to the EIS Peter Lumb 5 Explain small group purpose Lindsay Holmes 15 Tea Break 20 Work in small groups Lindsay Holmes

Groups identify and prioritise questions for resourc e peop le

60 Resource people answer questions Chaired L Holmes 5 Meeting thanks and closure Peter Croft

Explanation of the agenda

The purpose of the Community Information Sessions was to provide information about the EIS process and to assist people in preparing their written submission (comment) on the draft EIS It was made clear that the sessions were about gaining information rather than making verbal public comment on the draft EIS

A range of options for lodging submissions was presented

At each Community Information Session there was a panel of five or six specialist resource people

Supplementary EIS for the temporary weir near Pomanda Island -87-

The panel was drawn from the following

Peter Croft DEH Director Coorong Lower Lakes and Murray Mouth Projects

Russell Seaman DEH Manager Environmental

Dr Kerri Muller Contract Ecologist

Ross Carter SA Water Manager Major Projects

Glynn Ricketts DWLBC Environmental Water amp Infrastructure

Judy Goode DWLBC River Murray Environmental Manager

Hon Dean Brown Drought Reference Group

Premier s Spec ia l Advisor on Drought

Paul Harvey Murray Darling Initiative

Program Leader

Jan Whittle SA Murray Darling Basin NRM Board

River Murray Environmental Manager Unit

The panel of specialists was introduced early in each meeting prior to two major presentations

Russell Seaman gave a PowerPoint presentation which overviewed key aspects of the draft EIS for the proposed temporary weir near Pomanda Island

The Hon Dean Brown gave a PowerPoint presentation which provided a Murray-Darling Basin water issues context for the proposed temporary weir

Participants formed groups of eight with a trained DEH facilitator The purpose of the group fac ilita tion was to write questions on la rge post-it notes These questions were to be sorted and answered by the specialist panel

As group facilitators wrote questions the questions were continuously collected and placed on a wall Specialist panel members gathered and discussed who would be the most appropriate panel member to answer each question Like-questions were assembled with like Duplicate or overlapping answers were avoided

The meeting regathered and the specialists answered questions in an open manner

DEH provided a light meal at the end of each Community Information Session Community members were invited to stay on after the meeting to informally discuss issues and ask questions of the specialists Many members of the public accepted the invitation

This meeting format allowed all community members the opportunity to ask questions hear answers from people with specialist knowledge and then to engage with them further This was a successful format for the purpose of sharing information A large number of questions were answered and the community had maximum exposure to specialist panel members Panel members and community members generally responded favourably to this format

The records of these meetings include the wording of each question submitted to the specialist panel (Appendix IV) A summary of broad indicative categories of questions are included in Appendix IV including a graph consolidating answers from the four Community Information Sessions

People who attended the Community Information Sessions were invited to pre-register via email at eisdehsagovau or to register through an EIS 1800 number hotline (Appendix VIII) Registrations were sought to ensure that venues had sufficient capacity there was a sufficient number of group facilitators and so that catering was adequate Registrations were also accepted on entry and all registrants were supplied with a

Draft EIS Executive summary

CD containing a submissions cover sheet the Executive Summary the full text Draft EIS and all Appendices of the Draft EIS and

paper summary of the main PowerPoint Draft EIS presentation

Registration also provided the option for people to provide an email address so that they could receive Coorong Lower Lakes and Murray Mouth project updates

Supplementary EIS for the temporary weir near Pomanda Island -88-

In addition copies of Sim T and Muller K (2004) A Fresh History of the Lakes Wellington to the Murray Mouth 1800 to 1935 SA Murray Darling Basin Natural Resources Management Board Government of South Australia were available to registrants courtesy of the MDB NRM Board

3 Targeted Meetings The Ngarrindjeri People individually and collectively are involved in ongoing consultation about the about the Draft EIS for the proposed temporary weir near Pomanda Island Consultation about the Long Term Plan for the Coorong Lower Lakes and Murray Mouth will be ongoing

Ten targeted meetings were held between 2 February and 2 April 2009 Two meeting were held in Adelaide and eight were in the region (Appendix III)

The targeted meetings were attended by Peter Croft Director Coorong Lower Lakes and Murray Mouth Projects and Russell Seaman Manager Environmental (Department for Environment and Heritage) Peter Croft briefly discussed the developments leading towards the Long Term Plan for the Coorong Lower Lakes and Murray Mouth while Russell Seaman provided the PowerPoint presentation used for the Community Information Sessions but tailored the presentation towards the interests of particular audiences Brief records of these meetings appear in Appendix V

In each case these targeted meetings were scheduled meetings which allocated time on their agenda for the additional presentations about the Draft EIS and the Long Term Plan

4 Overview of media articles (see Appendix VII) This section provides the media context during the time leading up to the opening for public comment on the Draft EIS for the proposed temporary weir near Pomanda Island (12 March) to the close of the comment period (9 April)

In January and February 2009 med ia foc ussed on d isc ussions about flood ing the Lower Lakes Two of the 15 stories provided mention of the proposed temporary weir Through March when the Draft EIS for the proposed temporary weir near Pomanda Island was released 18 of the 20 articles focussed on the proposed weir Some media reporting (as summarised by Media Monitors) did not clearly differentia te between the EIS for the flood ing of the Lower Lakes and the EIS for the Proposed Temporary Weir indicating and exacerbating some public confusion

Main discourse The South Austra lian Government s ma in message was tha t the weir is a last resort tha t will only proceed if absolutely necessary in a worst case scenario situation The South Australian Government is committed to seeking a fresh water solution - they do not want to build the weir

A consistent criticism of pursuing approval for the weir is that it indicates that the South Australian Government has given up on a freshwater solution The media surveyed indicates that a fresh water solution is the preferred and only suitable option If the South Australian Government was serious about providing a solution media discourse suggests they would use the money to purchase water rather than for construction of the proposed temporary weir

Many who are opposed to the weir are of the opinion that the government has already made its decision and the weir will go ahead

Other issues raised There were several other issues raised in the articles including

the proposed temporary weir will cut off the River Murray from the Lower Lakes (one article)

there are alternatives to the weir such as storm water harvesting and more water efficiency (one article)

if the weir is built it is a temporary weir and temporary solution and the final decision on the weir will come six months prior to decision to flood the lakes (one article)

the number of regulators and weirs being planned in addition to the proposed temporary weir Clayton Finniss Latham Point Goose or Goat Island (two articles)

Throughout the majority of articles the weir was referred to as the weir or the Wellington weir and approximately 10 per cent of the time it was called the Pomanda weir

Supplementary EIS for the temporary weir near Pomanda Island -89-

A media release by the Federal Minister for Environment Heritage and the Arts mentioned the need for a long term vision and noted that the Australian Government has committed $200 million from its Water for the Future Plan to assist in the planning process and an additional $10 million towards the development of a long term plan for the Coorong and Lower Lakes

Two media reports expressed concern about the triggers to remove the proposed temporary weir saying that unless increased salinity and acidification levels are addressed and there is freshwater released into the lakes one of the triggers that salinity levels drop below 3000EC - will not be able to happen

Summary

Media analysed

Medium (Total) Channel Number ABC 16 5AA 5Radio (22) Triple M 1 9 Network 2 10 Networks 1Television (4) ABC 1 1 Independent Weekly 1 Adelaide Advertiser 1 Stock Journal (Regional) 3 Times Victor Harbor 1 Murray Valley Standard 1

Print (8)

Lakelander 1

Media release The Hon Peter Garrett Minister for the Environment Heritage and the Arts (one)

Four were regional stations five were Adelaide metropolitan stations and seven were both Adelaide metropolitan and regional stations

Total - 35

5 Receiving submissions and developing the Supplementary EIS The Draft EIS was open for public comment from the 12 March to 9 April 2009

The public were invited to provide written submissions as emails as emails with word attachments or to send hard copy using a free post address

Seventy submissions were received from the public There were 49 individual submissions 18 from community and other organisations and three from local government All submissions are available on DEH website wwwenvironmentsagovaucllmmsubmissions-receivedhtml

Submissions were uploaded twice per week during the public comment period Submissions were listed by author or organisational author as per Appendix I and Appendix II

Supplementary EIS for the temporary weir near Pomanda Island -90-

Timeline of the post-Community Consultation period

9 April Acceptance of submissions closed at 5pm

10 13 April

During the four days over Easter submissions were read summarised and a statement provided in a response column Key words in submissions were identified Summaries and responses were entered into a specially prepared Microsoft access data base Summaries from the data base are provided as appendix ix

14 April

A list of key words was compiled from the access data base The data base was then searc hed by a ll relevant key word s All sub missions jud ged to be in sc ope and a ssoc ia ted with a key word or key word string were then assembled Submissions were then sent to thirteen specialist writers Most writers had attended a meeting at which the requirements for preparing responses were outlined and the constraints of the tight timeline emphasised Other writers had individual briefings Writers could choose to receive hardshycopy of all relevant submissions or access copy on the internet The broad objective provided to writers was to create an over view summary of issues in response to issues associated with the key words for which they were responsible

15 17 April Specialist writers had three days in which to write their over view summaries

17 April Summaries were returned for compilation into the supplementary EIS and an executive writer and assistants then had six days to create an integrated supplementary EIS

24 April A draft of the supplementary EIS was prepared and sent to specialist writers for comment to be returned by 12pm Monday 27 April

27 April

Comments were incorporated into the draft of the supplementary EIS and a new version prepared for a briefing meeting on Tuesday 28 April The objective of this meeting was to facilitate final changes before chief executive and ministerial sign off

30 April The supplementary EIS was prepared and sent to the chief executive and the minister s offic es

Supplementary EIS for the temporary weir near Pomanda Island -91-

Supplementary EIS for the temporary weir near Pomanda Island -92shy

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report ndash Appendices

93

Appendix I Submissions received Individuals

Surname First name Suburb Date Submission

number

Cooke Roger Goolwa 29032009 PTW00001

Galea Michael Clayton Bay 30032009 PTW00002

Fargher Philip Norwood 01042009 PTW00003

Zoerner Andrew Prospect 03042009 PTW00004

Smith Douglas Goolwa 03042009 PTW00005

Rees Melanie Henley Beach 03042009 PTW00006

Brisco Mike Campbelltown 04042009 PTW00008

Moyle Ian Woodcroft 05042009 PTW00009

Harvey Richard North Adelaide 06042009 PTW00011

Richards Sally Finniss 06042009 PTW00012

Giles Trevor Langhorne Creek 06042009 PTW00013

Lower Brenda Goolwa 06042009 PTW00014

Michelmore Frederick Gordon Middleton 07042009 PTW00015

Lucas Ann Goolwa 07042009 PTW00016

Jones Glen Adelaide 07042009 PTW00017

Fenton Derek Finniss 07042009 PTW00019

Tjukonai Vesper Meningie 07042009 PTW00020

McFarlane Keith Tailem Bend 07042009 PTW00021

Read Tony Beaumont 07042009 PTW00023

X Mick Mannum 08042009 PTW00024

Hartnett Anne Milang 08042009 PTW00025

Whitehead Alexander Hindmarsh Island 08042009 PTW00027

Fairweather Peter Adelaide 08042009 PTW00028

Thomas Robert Goolwa 08042009 PTW00029

Carroll Barbara Happy Valley 08042009 PTW00030

Jones Henry Clayton 08042009 PTW00031

Bagley Chris Milang 08042009 PTW00033

Yelland Liz Milang 09042009 PTW00034

Vonow Lynton Lobethal 09042009 PTW00035

Trigg Ruth Normanville 09042009 PTW00036

Yelland John Milang 09042009 PTW00037

Brooks Bruce Finniss 09042009 PTW00038

Walker Keith Yankalilla 09042009 PTW00039

Harden Trevor Finniss 09042009 PTW00041

Allnut Bruce Finniss 09042009 PTW00042

Shillabeer Neil Oakbank 09042009 PTW00043

Heyne Ron Goolwa 09042009 PTW00044

Showell Jacqui Goolwa Beach 09042009 PTW00048

South Cecily Milang 09042009 PTW00049

Moon Silver Finniss 09042009 PTW00051

Supplementary EIS for the temporary weir near Pomanda Island -94-

Surname First name Suburb Date Submission

number

Hunter Rex 09042009 PTW00052

Bradford Karen Milang 09042009 PTW00059

South Mike Milang 09042009 PTW00060

Belford Beryl Mt Barker 09042009 PTW00063

Hobbs Elizabeth Goolwa 09042009 PTW00064

Vizard Talina Victor Harbor 09042009 PTW00065

Carter Carlsa Bridgewater 09042009 PTW00066

Scobie Keith Meningie 09042009 PTW00069

Russell Ruth Magill 16042009 PTW00070

Young amp Jury Mike amp Ken Goolwa 16042009 PTW00071

Submission received under special circumstances Submission sent prior to end of community consultation period

Supplementary EIS for the temporary weir near Pomanda Island -95-

Appendix II Submissions received Organisations

Organisation Date Submission

number

Southern Alexandrina Business Association Inc 04042009 PTW00007

Signal Point Riverine Environment Group Inc 05042009 PTW00010

Alexandrina Council 07042009 PTW00018

The Marina Hindmarsh Island 07042009 PTW00022

SA MDB NRM Board 08042009 PTW00026

Rural City of Murray Bridge 08042009 PTW00032

Australian Institute of Landscape Architects 09042009 PTW00040

Ngarrindjeri People 09042009 PTW00046

DTEI 09042009 PTW00047

Environmental Defenders Office (SA) Inc 09042009 PTW00050

The Coorong District Council 09042009 PTW00053

River Lakes Coorong Action Group Inc 09042009 PTW00054

Nature Conservation Society 09042009 PTW00055

Murray-Darling Basin Authority 09042009 PTW00056

Australian Democrats 09042009 PTW00057

Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

09042009 PTW00058

PIRSA Fisheries 09042009 PTW00061

Natural Heritage Trust 09042009 PTW00062

Conservation Council of South Australia 09042009 PTW00067

Goolwa District Ratepayers and Residents Association Inc 09042009 PTW00068

Supplementary EIS for the temporary weir near Pomanda Island -96-

Appendix III Participants and notes from Targeted Meeting Sessions

Local Knowledge Reference Group

Date Wednesday 4th February 2009 1100am 200pm Location The Monastery

In attendance Dean Brown Bill Paterson Prof Diane Bell Mike Geddes Mike Hammer Neil Shillabeer Paul Davis Rebecca Lester Rob Fitzpatrick Sebastian Lamontagne Mary-Anne Healy

Summary of comments or issues

Draft EIS was presented to the Local Knowledge Reference Group (LKRG) - draft is confidential

Consequences of weir removal and ability for system to recover

Scope of EIS should extend beyond matters of NES

Management strategies for potential flooding should be addressed in the EIS

Approvals process

Concerns regarding high water mark in relation to the causeway and Ramsar boundaries

Apologies were given to the group in regards to the lack of communication around the draft EIS in the past

Discussion

Raised issue re water levels relating to the barrages should say 7000 years

Changed the word ing to levels never rec orded ra ther than not seen sinc e the c onstruc tion of the barrages

No work has been done on how to recover the environment after the removal of the weir

Not going to remove the roads and tracks

Impacts locally not Ramsar site

Weir sinks over time

Remove down to bed level should not be any impediment to what was originally there

Will take time but should result in no impact

Weir will be there for 3 years

SA Water suggests there will be minimum impact

Mud waves will cause impact but will be transported away from sedimentary processes

Increased sedimentation as a result of the structure and disagreement that there will be a significant impact after the removal

The need to conserve the Ramsar wetland and what might be the implications Is it just going to go ahead Worried about the significant damage and if the system will ever recover

Cannot assess what has been done Needs clarity about the purpose of the group

Issues around rates of change and thresholds associated with the weir Also life stages and ecological character

Limited scope about this in the EIS only addresses matters of NES

Will edit the factual errors

Will help edit as well

Worried about experts need for higher level expertise for public comment period

Supplementary EIS for the temporary weir near Pomanda Island -97-

What if there are natural water flows floods Recovery Should be reference in the document to flood event happening and the ability to manage that

Agrees with Bill and need to understand and have something in place if there is a flood and removal of the weir

States that the draft EIS seems to have solid blame on the drought but over-allocation and excessive use are contributing factors as well Look at the language and justification of the EIS Issues about the decision making Commonwealth SA Gov

Understands that it goes to Commonwealth and SA Govt makes the decision Need approval under the EPBC Act

Need approval for MDBA and Minister

Interested to see if the Ramsar site is actually the boundary of where the weir will be built and the implications of that and whether the weir can take place

Drew a diagram of where the cadastral boundary is and where the causeway and proposed temporary weir are Assuming this is where the high water mark is

The whole group are concerned that the high water mark is actually exceeding where the causeway is and if that is the case the causeway and where the weir will be built will actually be in the Ramsar site

Supplementary EIS for the temporary weir near Pomanda Island -98-

Meningie Community

Date Thursday 5th February 2009 700pm 1100pm Location Football Club Rooms Meningie

In attendance Approximately 200 locals Andrew Beal Prof Diane Bell Robyn McLeod Dean Brown Peter Croft AProf David Paton

Summary of comments or issues

Dean Brown Prof Diane Bell Andrew Beal Peter Croft Robyn McLeod and AProf David Paton each gave a short presentation on current issues based around the Coorong and Lower Lakes providing management options

Summary of conditions and long term plans to help secure a future for the Lower Lakes Coorong and Murray Mouth

Following the presentations the community members were given the opportunity to ask questions of the presenters

Neil Shillabeer facilitated the meeting

The meeting was a little heated and closed around 11pm with people staying to speak with the presenters and other expertsofficials

Questions and discussion

What can we do to make other states realise that we are in a dire situation and that we need more water

What is temporary

Groundwater

Over-allocation

Where is the support for the community

Ngarrindjeri hurting no one is speaking with them or the community

What are the government officials going to do to help the community

Yes they are helping the environment but not the economic values and people

Why c an t they have a p ipeline like the other side (referring to the Langhorne Creek irrigation line)

Why haven t they been told about the c osts involved with this p ipeline

Lake Albert s a lloc a tion

What level will the Lakes be once the weir is in place

What are the trigger points for removal

If the weir is built are they going to put in fish ladders or will they be blocked

If Lake Alexandrina gets lower how are they going to continue pumping into Lake Albert

If seawater is let in how are they going to deal with the millions of dead fish and the clean up

How are they going to fix South Austra lia s own wa ter issues and a lloc a tions Need to address what is happening here before we blame upstream

Supplementary EIS for the temporary weir near Pomanda Island -99-

Milang Community

Date Thursday 12th February 2009 130pm 500pm Location Milang Institute Building

In attendance Anne Hartnett Dianne Bell Ken Follett Tim Trevorrow (APOL) Rowena Brown Dr Rob Fitzpatrick Bruce Brooks Graham Gates Lesley Fischer Tony Randall Peter Alexander Wayne Brown Carol Richardson Greg Lundstrom Richard Owen Peter Croft Clare Manning Russell Seaman Karyn Bradford Kathryn Rothe Shirley Smith Liz Barnett Simon Oster

Summary of comments or issues

The Lower Lakes Partnerships for Recovery

Lower Lakes communities are keen to use their knowledge labour and community infrastructure to bring about Lakes and River recovery

The community seeks partnership with government to

- Rescue and remediate degraded environments

- Impede further degradation

- Instigate environmental management and development practices

- Address current and future effects of climate change

Projects have been identified for both immediate and long term implementation

Revegetation Revegetate areas subject to Acid Sulfate Soils with plants having low impact on soil

saturation in

- Priority areas in Finniss River and Currency Creek

- Receding lake shores

- Known ASS hot spots

- Spots at-risk of drying out wind erosion and sun exposure and affected by stock access

Revegetation capacity building Collect seeds for replanting (native plants)

Undertake at-risk plant rescue and propagation

Purchase propagation and planting of annuals

Plant large trees away (upwind) from Lake edge as leaf litter will provide sources of organic matter and iron to Lakes (builds resilience)

Flora and fauna protection Control of increased feral populations arising from revegetation

Establish refuges for endangered flora (and fauna)

Weed control

Protecting fringing vegetation Protect lake revegetation areas from cattle

Protect cattle from poor quality drinking water

Environmental remediation Community Acid Sulfate Soil treatment projects

Source local limestone for application to ASS

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Nurture and capture knowledge

Train communities to identify and map plants useful for land protection and remediation

Create systems for long term monitoring of soils vegetation growth and regrowth

Establish community survey systems to map current and changing status of soils

Collect and contribute data that will enhance GIS data banks and veracity

Create local administrative and data collation processes to manage the above incorporating two-way communication and mutual benefit from data

Monitor water use to aid in the beneficial allocation of water resources

Supplementary EIS for the temporary weir near Pomanda Island -101-

Peter Croft s Murray Futures update for the Lower River Murray Drought Reference Group representatives

Date Thursday 26th February 2009 200pm 500pm Location Murray Bridge

Summary of comments or issues

Status of Environmental Impact Statement for the proposed temporary weir near Pomanda Island

Timelines for the project

Community involvement

Timelines for the Long-Term Plan to secure a future for the Coorong and Lower Lakes Ramsar site

Community Action Planning

Information provided

EIS has not yet been finalised or lodged but is in the critical final stages and is expected to be lodged shortly

We will be holding some Community Information Sessions in the 4th week of March (pending approval from the Commonwealth)

There will be a media release of notices via national state and local press announcing the sessions locations and times to inform the communities (subject to Commonwealth approvals)

These sessions are to summarise the draft EIS allow community members to ask technical questions of some specialists and provide advice to the community on preparing submissions on the draft EIS

A Reference group has been developed (The Long-Term Plan Reference Group) and brings together community leaders scientists and government staff with a view to develop a long-term plan to secure a healthy future for the Coorong and Lower Lakes Ramsar site

This is an important first step to help identify a realistic sustainable future for the region one that will address the environmental community and economic values that are important to the region

Our aim is for a coordinated management response for the future of the Coorong and Lower Lakes And involving the community along the way is critical to the success of our work

We are aiming for a 1st version of the Long-Term Plan ready for public consultation in April We will ensure that a range of different communities get on the list of possible locations (eg Milang and Langhorne Creek)

Notices of such events will be distributed through the national state and local press as well as our website

On 12th February we met with representatives of Landcare Groups and Local Action Planning Groups to discuss proposals for community action around the Lakes

A number of areas of action were identified and a small team with representatives from DEH Regional Conservation Team and LAP Coordinators will flesh out the actions in more detail

A Plan of Action is being developed for trial projects with potential funding of $100000 that may be available to support some preliminary work We plan to finalise the details and get activities rolling ASAP

Supplementary EIS for the temporary weir near Pomanda Island -102-

Ramsar Taskforce Committee

Date Friday 13th March 2009 1100am 1230pm Location Wyndgate

In attendance Ramsar Taskforc e c ommittee members Peter Croft Russell Seaman and Peter Lumb

Summary of comments or issues

Peter Croft briefly introduces EIS processes and distributes draft EIS community development and hard copy Executive Summary

Russell Seaman gave a presentation in the EIS and asks for feedback

Broad range of questions ranging from fish ladders in the weir to alternative options

Questions and discussion

Will the Supplementary EIS be made public

Will the Australian Government then require community consultation on the Supplementary EIS

Why is there such a short time for public comment on the draft EIS

What do you mean by environmental hotspots

Has any thought been given to a natural causeway near Pomanda Island

Is the weir site within the Ramsar site

Where will the water come from to flow over the weir if a weir is built

Comment about the importance of fish ladders

Emphasise that the weir is not a trigger for sea water incursions

Emphasise that the presentation is mostly based on worst case scenarios

The EIS must mention over-allocation

Emphasise actions taken or about to be taken when possible

Emphasise terrestrial vegetation more as well as Lake bioremediation

How much employment will be created in the region

Is it possible to have Councils administer vegetation and bioremediation projects rather than the Attorney-General

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Scientific Advisory Group (SAG)

Date Monday 16 March 2009 930am 1130am Location L5 81 Flinders Street Adelaide

In attendance Rebecca Lester Ingrid Franssen Mardi van Wielan AProf David Paton Adrienne Frears Glynn Ricketts

Summary of comments or issues

Decision trees and timelines

Alternative options

Trigger points

Questionscomments

Needrequest to set aside 5 for science to underpin management

Lake Albert needs early consideration

Need a decision tree as some actions are alternatives or consequent actions

Link decision tree to timeline and water flows

Need to account for measures for Long Term Plan to prevent the need to do reactive work again in ten years

Assumption restore wetland functioning to build resilience

Focus on upper Finniss and Currency dam bypasses upstream modelling water allocation and managing low-flows

Scientific Advisory Group can assist with advice if needed

Pomanda weir s estimated c ost $150m

Need to find out if there is a major ecological downfall if the acidification occurs

Reduce or stop pumping for winter lower evaporation and stop wind erosion

Apply limestone only when triggers are reached

Any ideas for the Long-Term Plan will influence the second version of the Plan

Ephemera l systems a re na tura l Lake Albert is a termina l wetland no outflows

A more complete document will allow a more thorough examination of the situation (possibly in April)

Which trigger will come first

Is a virtual weir still on the table

Does the dam allow for a fishway

Supplementary EIS for the temporary weir near Pomanda Island -104-

South Australian Murray-Darling Basin Natural Resource Management Committee

Date Thursday 19 March 2009 930am 1200pm Location Murray Bridge

In attendance SA MDB NRM Board members Peter Croft Kerri Muller and Lindsay Holmes

Summary of comments or issues

Questions focussed on conditions climate and the environment

Questionscomments

How will the weir be deconstructed

Can we separate the effect of the weir from the effect of the drought

Is the 350GL of wa ter over the weir in c urrent c ond itions

Will water go into the Lake when there are disconnection issues

Will there be a short-term increase in salinity while the pool fills

What is the current river level

Does the EIS consider scouring

Is flooding risk considered (in EIS)

Mud waves are a major issue

Why will construction of the weir be worse during summer

What are other alternatives

When does the EPBC Act review end

Can we make a definitive statement about what happens to the wetlands

Supplementary EIS for the temporary weir near Pomanda Island -105-

Icon Site Community Reference Committee

Date Monday 23rd March 2009 930am 1200pm Location Langhorne Creek Bowling Club

Summary of comments or issues

Questioned the science and experts available

Alternative options were discussed

Questioned engineering aspects of the weir

Russell Seaman presented an overview of the draft EIS

Group showed concern for repercussions of actioninaction

Questions asked

Coorong evaporation 200GL of fresh or seawater

Who will DEH engage as experts to advise on seawater incursion

What will DEH be basing their knowledgeevidence on in regards to the seawater incursion

Has anything like it been done before

Mulching

Limestone locally sourced

Coorong North lagoon monitoring and ASS who is monitoring and what is being done to remediate the hyper-saline conditions

To what extent can we replicate what was in the past southeast freshwater

Salinity in the south lagoon would the level allow Rupia sp to establish itself

Mechanical mouth operation as opposed to dredging has this been considered

What are some other options

Has the department looked at Vortex sand pumping

Will there be culverts between the Lakes through the causeway for water to flow via wind seiching

More research needs to be done has the Department considered engaging the local knowledge Don t dup lic a te researc h

If temporary why are you considering installing fish passages in 5 years time Should that not be done at the time of the weir installation

What levels are you looking at for the lakes

Supplementary EIS for the temporary weir near Pomanda Island -106-

Russell Seaman presentation Overview of the draft EIS for the temporary weir near Pomanda Island

Questions asked Why 01 AHD for the spillway

At what Lake level will it start acidifying

Should we have a lower weir

What is the risk of salt levels increasing when you stop the flows for 3 months

Will ground waters be coming in

What about the banks collapsing

What is the water quality of ground water and will it contaminate the Lakes

What happens if water flow exceeds 15GL per day ie if flood occurs will the structure cope

How quickly will the structure sink is it 1m per year

Will the weir be in place by 1st January 2010 as the graph indicates

When is -15 AHD expected

Has the Premier decided to buy water to see the Lakes through to winter 2010

Have you factored in the local rainfall flows within Currency Creek and Finniss

Is there an indication of seepage of ground water into any region of the Lakes

Have you looked at Biochar for remediation purposes

Lime straight pH neutraliser or feed the bacteria

Why not put a carbon source in there as well

Supplementary EIS for the temporary weir near Pomanda Island -107-

Lower River Murray Drought Reference Group

Date Thursday 2nd April 2009 Location Murray Bridge Council Chambers

Chair Dean Brown In attendance 14 Reference Group members 15 people in the Public Gallery

Summary of comments or issues

EIS Presentation by Peter Croft 30 Minutes including questions

Peter Croft presented overview of the draft EIS

Issues relating to seepage

Costs and issues relating to weir construction

Weir removal

Timelines for weir construction

Questions and comments

All questions asked were from Reference Group members with occasional comments from the public gallery

If the weir is built will more wetlands be closed between the weir and Lock 1

Are estimates being made of loss of water to seepage through the cracked levee banks above the weir And will this seepage appear in the Lake

Will it be the case that water will stop flowing over Lock 1 at some stage to facilitate the construction of the weir

Adrian Pederick MP asked who wrote the draft EIS

Member referred to a rumour that irrigation will cease with weir construction

Can you be clear about the cost of the temporary weir if built

Is the cost of the causeway included

Where will the SA Government get the money to construct the weir (Some anxiety that it would be CLLMM money (Comment wasn t c learly aud ib le)

What is the likelihood of a virtual weir

There was a question (inaudible) about the height of the weir above sea level (Was it about the adequacy of the height to secure water supply if the Lake levels rose)

How much of the weir would be removed when decommissioned

Comment about the complexities of start times and the apparent late start to protect water supply

Update on other matters Peter Croft Closing date for submissions on the draft EIS on proposed temporary weir

Promotion of availability of all documents and information sources

The Goolwa Channel referral lodgement is imminent

Actions Application for projects under $120000 April 10

Approvals process for lime-stoning the first flush coming down the Finniss and Currency Creek

Seeding and bioremediation workshop held Tuesday 31 March

Rural Solutions developing a bioremediation plan around both Lakes

Supplementary EIS for the temporary weir near Pomanda Island -108-

Appendix IV Organisations that participated in Community Information Sessions

The Advertiser

Department for Environment and Heritage

University of South Australia

La Trobe University Centre for Sustainable Regional Communities

Native Food

Investigator College

River Lakes and Coorong Action Group Inc

South Australia Murray Darling Basin Natural Resources Management Board

River Murray Boat Owners Association

River Murray Museum of River History

Department for Sustainability and Environment

Wellington Lodge Pty Ltd

Ranges to River NRM Group

Food and Beverage Australia Ltd

Narrung Wetland Monitoring Group

BMT-WBM (Engineering and environmental consultants)

River Lakes and Coorong Action Group

All Land and Livestock

Clayton Bay Community Association

Finniss Catchment Group

Southern Alexandrina Business Association Inc

Coorong District Council

Narrung Dairy Farmers

Southern Fishermen s Assoc ia tion

Clayton Bay Foreshore Committee

SA Water Corporation

Fleurieu Regional Development

Alexandrina Council

University of Adelaide

Supplementary EIS for the temporary weir near Pomanda Island -109-

Appendix V Participants and notes from Community

Information Sessions

Community Information Sessions Agenda

Proposed Locations Meningie Murray Bridge Goolwa Clayton Bay Facilitator Lindsay Holmes (Meeting Success) Session Length 25 hours

Timing Task Responsible person

5 min Welcome and Ground Rules Lindsay Holmes

Welcome to Country

5 min Explain purpose of Session Peter Croft

5 min Introduce specialist panel Lindsay Holmes Explain session agenda and process

10 min Water Presentation Hon Dean Brown

25 min EIS Introduction presentation Russell Seaman

5 Min How to respond to the EIS Peter Lumb

5 min Explain small group purpose Lindsay Holmes

15 min Tea Break

30 min Work in small groups Lindsay Holmes Groups identify and prioritise questions for resourc e peop le

40 min Resource people answer questions Chaired Lindsay Holmes

5 min Meeting thanks and closure Peter Croft

Supplementary EIS for the temporary weir near Pomanda Island -110-

Meningie Community Information Session

Date Tuesday 24th March 2009 300pm 530pm Location Meningie Bowling Club

Questions asked of the specialist panel listed by category

Lake Albert Is pumping going to stop or continue at Lake Albert

In worst case scenario what will be done about Lake Albert if it runs dry

Assuming a weir will be built what actions will be taken to maintain Lake Albert

What is the future for Lake Albert

Why isn t Lake Albert written up more in the d ra ft EIS

River flows Why are upstream tributaries not included in the flow data considering it is the Murray-Darling Basin system (The information is then misleading for Min Garrett)

Inflow figures Are these figures based on whole basin or just the Murray River catchment

Is there information on how much water is coming in to the basin catchment (not just inflows)

Is 350GL guaranteed to come over the weir per annum Is that happening now

How will the weir pool level be maintained ie Where will the water come from Does this relate to water buy back

Why c an t some of the wa ter held on fa rm dams etc be released and peop le use a little less water to maintain levels (federally)

What measures are being considered to improve sharing and saving water throughout the Basin

How much area is considered Murray-Darling catchment

put in place to use alternative storagemake Adelaide less dependent on the Murray

Ramsar How will the Ramsar convention be respected

Australia signed the Japan-Australia migratory birds agreement (also with China) re wetlands of international significance How will the weir effect this agreement

Is government looking at taking control re Ramsar site

Wildlife What happens if there is a fish kill in Lake Albert

Will the weir affect cod numbers and is there a plan to recover this species

Has the magnitude of a fish kill been considered ifwhen the weir is built Consider Lake Albert amp Lake Alexandrina separately

What will happen to the fish turtles etc if salinity increases

Acid Sulfate Soils (ASS) Why hasn t the government looked a t other op tions for remed ia tion for ASS

What is the long term planmedium term plan for Lake Albert and the ASS issue

What is the gas that comes out of the mud in Lake Alexandrina (Three cases of dizziness when exposed to this)

What can be taken out of Menindee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Alternative catchments Adelaide is now taking 90 water from Murray What is being

Wha t c an be ta ken out of Menind ee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Supplementary EIS for the temporary weir near Pomanda Island -111-

Salinity issues What mitigation strategies are in place to mitigate hyper-salination in the Lakes

Salt water sits beneath fresh water How will the salt water flow over the weir

If the weir is pumped is the pumped-out water saltier

Does the salt water layer

How are they going to flush the salts that accumulate in the weir pool

What is the evaporation rate per annum at the present time considering the Lake levels today Is it still 800GL

Rainfall Was there rainfall measured over Lake Alexandrina in winter last year (No rainfall measured by farmers)

Why doesn t the d ra ft EIS mention Lake ra in

Will decreasing the surface area of water in the Lakes reduce rainfall over the Adelaide catchment increasing the strain of Adelaide Hills reservoirs

Proposed temporary weir impacts How is the weir going to be removed

What is the trigger point for the weir decommissioning

Given the modelling and g iven the government dec ides to build the weir why isn t a lock considered Would allow navigationfish passageflow management

Why is there no facility for navigation through the weir

Why a re there no fishways Why isn t it nec essa ry to have fishways

Is the base of the weir stable enough to stop slippage of the structure

How will they monitor the silt on the downside of the weir and particularly with ASS

Will time to fill the weir pool be more than three months (based on worst-case scenario) Will some leak out under the levee banks

When would construction start

What would it cost to move the intake points above Lock 1

Will the weir help mitigate acid soils in the Lower Lakes

Why does the EIS not address much between Lock 1 and the weir in relation to damage of embankmentshabitat above the weir

How can they guarantee that removal of the weir will allow things to go back to the way they were

Social and economic impacts What consideration has been given to sustaining cultural flows for Indigenous people

Are the social impacts of building the weir and low flows being considered in the decision to build the weir

What provision has been made in the EIS for socio-economic impact factors

Seawater If seawater is let in how far into the groundwater will the seawater penetrate What will be the impact on the level of groundwater

How will the weir affect the decision to allow seawater into the Lakes

How does the weir link with the seawater incursion and will it need another EIS

Politics and Government When is the Murray-Darling Basin Authority going to get up and running (currently only a CEO and Chairman) If it were in place then politics will be in order ()

There have been a lot off government bodies set up over the last few years What has their role been and what is their role now

What is the government doing to educate the public

Supplementary EIS for the temporary weir near Pomanda Island -112-

Miscellaneous Have the trigger points been addressed

Will the weir guarantee water for stock from existing pipelines

Will the weir cause impact on the positive impact that wind seiching plays in the system

Do submissions all go together to the Commonwealth

What will happen when a flood occurs at the Narrung pumping station Will it be removed and the channel opened

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 2 fishways) 14 River flowsallocations 11 Salinity issues 6 Lake Albert 5 Wildlife (Fishturtles) 4 Social and economic impacts (one Indigenous) 3 Ramsar 3 Sea water incursion 3 PoliticsGovernment 3 Acid Sulphate Soils 3 Rainfall (Lake rain) 3 Miscellaneous 4

Supplementary EIS for the temporary weir near Pomanda Island -113-

Murray Bridge Community Information Session

Date Tuesday 24th March 2009 1000am 1230pm Location Uniting Church Worship Hall

Questions asked of the specialist panel listed by category

Acid Sulfate Soils (ASS)

What effect will the weir have on the current situation of Acid Sulfate upstream given that the weir will not be constructed within the next three years

How extensive are the potential Acid Sulfate areas

How deep does the lake need to be to prevent ASS

What is the plan to deal with acidification post weir

What is worse Seawater or lake acidification

Salinity issues How will salt get back into the Lakes

What measures will be taken to address salt building up behind the weir (upstream)

How can you handle the salt (that will come down the river) How will it be managed

Have you considered installing pipesregulators to manage salinity at the base of the weir

Wildlife What evidence do we have that the birds will return after construction

Have we calculated impact of extinctions

River flows allocations Is there a lot of water available for sale

Why hasn t temporary wa ter been purc hased

What about buying water as an alternative to a weir

If a weir is built will there be more water allocations in SA

If the weir goes forward who will receive the water that will be saved from less evaporation Will the allocation be more

18 wa ter a lloc a tion Universa l na tiona l standard set a lloc a tion Why isn t there an agreed allocation standard to all usersirrigated Why not a special rule to override current allocation agreements

Has there been an audit on un-metered bores in the Basin and what action is being taken

How much have extractions increased and what were base extractions

Developed methods to estimate inflows model for calculating extractions How much water is prevented from entering the system Where do extractions go Why is there no graph for extractions for entire systems How is the flow calculated Where is this information available

What is the definition of inflows

Where is the water coming from to maintain the level of the weir pool and the river level

What are the differences in water quality in the channel with or without a weir How serious is the situation What about the use of water upstream Over-allocation

Proposed temporary weir Has consideration been given to the weir at Wellington having a fishway

Will the weir pool inundate the wetlands upstream

How will the water and salt discharge over the weir into Lake Alexandrina Spillway Gate

How will the process prevent the build up of algal blooms and nutrients behind the weir

Supplementary EIS for the temporary weir near Pomanda Island -114-

What will build up behind the weir (eg iron etc)

Water hitting the weir what is going to happen

Why a temporary weir Why remove it and rebuild it

When the weir is deconstructed what happens to debris rocks etc

What will the volume of seepage be What are the implications

Will construction of the weir begin in June

What are the trigger points for removal of the weir

Why is a permanent weir not being considered CSIRO says conditions will get worse

How are they going to remove the weir

How is the level going to be maintained as weir is expected to sink in sediment

Why is the weir being build to 01m above sea level

If and when the weir is removed can it be reassembled quickly

How long will the weir take to build

Were other options considered for construction of the weir and what were they

Have you found a solution to the weir foundation (ie mud and construction of the weir at Pomanda Point)

What is the trigger to open the weir

Are the triggers to demolish the weir strict

Why haven t they got sta rted on build ing the weir

Lock Have investigations been made to have a permanent weir with lock with fishway and means of allowing the bottom salt water to be discharged

Has there been consideration of a lock with the weir (or a bypass channel)

Why have we not considered a lock

Why consider a temporary weir when a permanent weir could be constructed with a lock to maintain a navigable river system

Politics government and planning What about the constitutional right that the river be navigable from top to mouth

When will the Murray-Darling be run federally Not by the states

Why not hand over water management to the Commonwealth

When will the government declare this a disaster

What grantsassistance will be provided (eg tourism) Irrigators get support Why not others Industry assistance

Why is the weir being considered as part of a piecemeal approach What about a long-term plan

Is the weir part of the broader management of the Lakes and Murray Wha t s the b igger picture and where does it fit

Why is there not an integrated plan including Goolwa Channel regulators rather than doing it piece by piece

What is the present status of the Goolwa Channel projects

Is there a trigger for putting in a desalination plant at Tailem Bend

How will the remediation be managed and the long-term effect of the silt build-up be dealt with

Will building of the weir delay the equitable distribution of water in relation to other states

If the weir is built what are the triggers for letting in seawater to the Lakes

Riverbanks What measures have been taken to ensure the levy banks do not collapse with the higher river levels

What proactive approach will be taken to care for river banks

Ifwhen we build the weir what about the raising of the head River bank decline

Supplementary EIS for the temporary weir near Pomanda Island -115-

Has there been any consideration given to realigning the Lake Alexandrina shoreline Reduce evaporation in future

Pumping stations

Cost of moving pump stations above Lock 1

Chapter 4 Relocation of pumping stations above Lock 1 (needs clarification)

If they put in the weir will they continue to pump water to Lake Albert

Society and economy What is the impact on peoplecommunities

Why is economic impact not dealt with in the EIS

Miscellaneous What s the likelihood of worst-case modelling becoming irrelevant Is it likely that worst-case modelling is over predicted

Numbers of questionscomments on each topic indicative

Proposed Temporary Weir (Locks 4) 27

River flowsallocations 13

Politics Government (2 Goolwa channel) 13

Acid Sulphate Soils 5

Riverbanks 4

Lock 4

Pumping stations 3

Society and Economy 2

Wildlife 2

Miscellaneous 1

Supplementary EIS for the temporary weir near Pomanda Island -116-

Goolwa Community Information Session

Date Friday 27th March 2009 10000am 1230pm

Location Centenary Hall

Questions asked by the specialist panel listed by category

Wetlands Milang wetlands identified as number one natural resource by Adelaide University It has now been disconnected for two years Why is it not mentioned in the EIS

Will the wetlands between Lock 1 and the weir be filled How much water is needed to fill these wetlands Will the filling of wetlands result in an increase in acid

Bioremediation Are they considering bioremediation rather than building a weir

Impac t of g rasses tha t a re na tura lly g rowing on beac hes of the Lake

River flowsallocations What s being done about the wa ter supp ly

How much inflow into the River Murray in SA comes from SA compared with inflow across the VicNSW border (see figure 0-2 of the Exec Summary)

What flows would be necessary past Wellington to support a virtual weir at AHDs of -15 shy2 -25m

Will the weir be able to withstand a significant flood

How will water flow over the weir and into the Lower Lakes or will it flow through a gate underneath

How much water bypasses the weir if it is built

What will happen to the temporary weir if there is a flood Will it get washed away

Has the sc enario of three months without flow into the Lakes to fill the weir pool been allowed for in determining the trigger date of Jan 2010

Is it possible to have a shorter period where there is no flow over the weir but take a longer time to fill the weir pool

Has the government considered buying water to maintain the annual 350GL to the Lower Lakes

If the Lower Lakes are without water for three months during construction will the government purchase additional water to factor this in

Why doesn t the environment get a wa ter a lloc a tion like every other user

Why does Adelaide not have underground storage or other measures to alleviate the need for taking water from the River and hence for need of a weir

What difference would it make if we moved down to critical human needs rather than gardens and swimming pools

What is the impact of the various private and public water storages when comparing the Federation Drought and the current drought

What proportion of the Living Murray water agreement will reach the Lower Lakes (of the 500GL from 30 June 2009)

Ramsar What is the potential threat to the Ramsar status of the wetlands

Has the Wellington weir been put to Ramsar

Could building the weir lead to international action and delisting

Wildlife (Four questions on fish passage a re listed under Proposed temporary weir )

How do we consider the impact on species which are not listed under the EPBC Act These species are part of the ecosystem and food chain

Has the EIS looked at all species that will be affected eg snakes kangaroos and others

Supplementary EIS for the temporary weir near Pomanda Island -117-

Will the weir reduce flows significantly downstream and continue to adversely affect wildlife already in distress

There will be a spike in salinity in the Lake after disconnection which may lead to fish kill in certain species eg carp Fish kill will give high ammonia and low dissolved oxygen what is the impact on the other species as a result of this

Acid Sulfate Soils (ASS) What is proposed to address Acid Sulfate Soils

Acidification problem on land There are options to cover sand other than freshwater

Is the lake bed soil at Pomanda sulfuric

What does the Department anticipate will be the result of disturbing and replacing thousands of cubic metres of sulfuric soil above and below the weir

What is the problem with ASS What does it do that is so bad

When acid soils dry out does they still retain their acidity What happens when they turn to dust

What problems have Acid Sulfate Soils caused so far Why do we need to be concerned about this problem

Wha t is the government s stra tegy to c ombat the ac id and heavy metals entering the river as a result of varying levels caused by wind seiching

Salinity issues Why after Lake Alexandrina has been sucked dry should the Lake have to put up with the salt from behind the weir therefore making the Lake worse with a high salt content

What happens to the salt which normally comes down the River and flushes to the sea via the Murray Mouth

Will the weir result in a highly saline weir pool

How will the accumulated salts be flushed at the weir

How quickly can the rocks be removed if it becomes apparent that the weir pool salinity levels have unexpectedly risen to unacceptable levels If not quick enough what is the contingency plan

What is happening to water above the weir Will salinity affect Adelaide water supply

Where are the salt and other contaminants going to go once the weir is constructed

What consideration has been given to the massive mobilisation of salt that would follow heavy inflows

Has the government considered increased salinity building up behind the weir

If the weir has a long life will salinity keep rising

Won t sa lt and toxin c onc entra tion inc rease upstream of the weir

What science is there that demonstrates the mixing of saline waters in the weir pool immediately above Wellington to be kept to acceptable levels while the weir is in operation Is there any precedent of a similar scale for this mixing scale

Proposed temporary weir impacts If the weir is there for a long time what are the groundwater impacts

Why are there far more truckloads of material being put into building the weir as opposed to taking it out

What are the implications of taking the weir down

Impact of increased vehicle access on Lakes beaches on Sulfate soils dust and wildlife

How do you intend to remove the weir given it is a massive structure

How do you intend to remove the weir given it is a temporary structure

What part of the structure and sub-structure will remain after decommissioning

What are the consequences if the weir fails to withstand a flood

If the temporary weir is engaged for three years but is required for longer what would it take to remain operable for as long as it is needed

Wha t will happen a fter the end of the three years of the weir s life

Is twin lakes concept a possibility Has it been sufficiently considered

Supplementary EIS for the temporary weir near Pomanda Island -118-

What is the effect of the weir on the water ecology in the channel (downstream) Eg water rats crustaceans birds beetles etc

Is a fishway being incorporated into the design of the weir

During the period of disconnection can a tunnel be built through the weir to allow fish passage

Will the temporary weir include provision for a fish ladder

What provisions are there in the weir construction for fish ladders and other access for boating

What is the level of the weir spillway and the level of the weir pool behind it

What is the level of the weir itself

Is it possible that the temporary weir will need to be replaced by a barrage if the drought continues

Why not build a permanent weirlock rather than building a temporary weir that may need to be re-built in a number of years

How long do you expect the weir to be in place

Social and economic impacts Where do we take our concerns about economic and social impacts of the situation

Politics and government What are the budget figures of water (both temporary and permanent) How much do they expect to pay per GL

The weir won t a llow boa t tra ffic Is this aga inst the c onstitution

Is it legal to build a weir which will hold the River flow to the detriment of the Riparian rights users downstream

Is it true that Commonwealth or State Laws require the River to remain navigable

How can I use this process to promote a change to the system of governance (States sharingallocations)

How can this consultation process address over-allocation

What is being done about over-allocation

Over-allocation in other states is at the root of the problem When will governments apply sufficient pressure to deal with the shortage of water coming over the border

What is going to happen with the issue of over-allocation and theft of water upstream

Would it be better to spend money on infrastructure instead of buying back water

We need a 50 year plan to remove all man-made infrastructure in the Murray

Why doesn t the federa l government focus on new sources of water being made available For example new engineering securing water from Queensland and delivering it to northern point of Murray-Darling

Is the Murray-Darling Basin Agreement still a legal document Is it still in force

What is the federa l Minister s responsib ility to the c ommunity c onsulta tion p roc ess (Specifically relating to issues submitted to state and if they disagree with the citizen who adjudicates)

What coordination is there between different government departments

Miscellaneous Why was A Fresh Water History g iven out today To influenc e thinking

How long under the worst case scenarios will the water contained by the temporary weir remain suitable for Adelaide use

What would be the cost of shifting the uptakes above Blanchetown

How are they measuring water quality in Lake Alexandrina What about DO and temperature

What role is the rising water temperature having on the aquatic species and water quality as a whole

Will the water beyond the weir cease to be aerated as a result of the weir

How much has wind seiching been considered in the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -119-

Why has there been no consultation with community in Milang Why have they been neglected

Wha t does spend mean in rea l wa ter terms We need a bold idea

If the weir is built will the blocking banks at Clayton Finniss and Currency Creek still be needed

If the blocking banks go ahead with the weir still go ahead

If the drought continues and the weir goes in and barrages are left closed what will happen to the Lakes and Coorong

Trigger Points What will be the indication to dismantle the weir

What is defined as temporary and what are the decommissioning triggers for the weir

Lake Albert What is the future of Lake Albert

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 4 on fish-ways) 21

River flowsallocations 16

PoliticsGovernment 15

Miscellaneous (including 5 on water quality) 12

Salinity issues 12

Acid Sulfate Soils 8

Wild-life (Fishturtles) 4

Ramsar 3

Wetlands 2

Bioremediation 2

Social and economic impacts 1

Lake Albert 1

Supplementary EIS for the temporary weir near Pomanda Island -120-

Clayton Community Information Session

Date Friday 27th March 2009 400pm 630pm Location Clayton Community Hall

Questions asked of the specialist panel listed by category

Regulators Why is a regulator at Clayton for pumping to the Goolwa Channel considered above letting seawater in to it

If the Clayton Regulator is built will it protect the water quality at the pumping stations (without building the weir)

How does the function of the Pomanda Island weir relate to the functions of regulators proposed for Currency and Finniss Creeks and Clayton

Is the weir going ahead as well as regulators If so why are both necessary

With the proposed regulators will the inflows of water to the next section be regulated from the bottom of the weir or from the top ie What will happen to accumulated salt behind the weir

Why is information on the regulators only in the papers and not mentioned in this forum

Lake Albert Should the weir at Pomanda Island proceed what are the ramifications for the future of Lake Albert

River flowsallocations Has blocking off the wetlands between the weir and Lock 1 to allow water when available to run into Lake Alexandrina been considered

If the weir is installed is the initial idea to pump water into the weir pool immediately or to leave it to whatever comes in

If the water extraction cap in other states is applied in 2012 will we get any water flow to SA

What are restrictions in other States on water use

What if anything happens in other states in allocating water as NSW has no meters

How is water removed from the River tracked

How is surface diversion tracked and measured

Has there been an assessment of all water storages available to the MDB

Do we believe SA will actually be able to get more freshwater from the larger eastern states as they are also growing

Would stormwater redirection help the Murray

What is stopping us from buying more water

How can the process of buying water be sped up

Ramsar

of the Murray-Darling Basin and River mouth is of paramount importance

Wildlife Ecology of LakeRiver studies on cod too late They have been in scarce supply for a long time

Given that the Yarra Pygmy perch is in other river systems why is it included

No cod in the Lower Lakes for decades Why are they included in the draft EIS

Is a base line study into Bell Frogs too late

Has anyone looked at the effect of the weir and its repercussion on micro-invertebrates etc on whic h a ll the Lakes residents (human anima l and p lant) depend

The Coorong and La kes site is reg istered a s an interna tiona l Ramsar wetla nd Isn t the Prime Minister responsib le for p rotec ting this a rea Isn t this the b ottom line The ec ology

Supplementary EIS for the temporary weir near Pomanda Island -121-

What effect will the proposed seawater introduction have on the Lower Lakes freshwater species

Why are marine species that were prevalent before the barrages not mentioned in the EIS

What study has been done on non-river marine species threatened by not allowing seawater in as nature would have done under these circumstances

How will species not listed in the EPBC Act be addressed

Acid Sulfate Soils What is the risk of potential ASS becoming actual ASS

The Executive Summary of the draft EIS alerts to the danger of acidification of the weir pool above the weir when wetlands are flooded again Is it intended to close off the entrances to them Has there been any decision yet about exactly what the effect of covering ASS with water (salt or fresh) will be

What will happen to the wetlands above the weir when they are refilled with water Is there a danger of the water being contaminated due to acidic soils

Due to ASS and extraction for urban use it appears that the weir must be in place by mid-January 2010 Is that the case

If the weir is installed is the intention to block off back waters and lagoons below Blanchetown If so are these subject to ASS

Bioremediation Is there something groupsindividuals can do to help with bioremediation projects etc How can we be involved

Will revegetating problem areas with dust fix the problem

Salinity issues What are the impacts of salt water within CurrencyFinniss Rivers

In the introduction it was stated that salt levels in the Goolwa Channel are 20000 ppm (parts per million) I believe they are 30000 ppm Is your information up to date

What will happen to salt accumulation when the proposed temporary weir is removed

Will the water coming over the weir spillway bring the salt with it or will salt build up at deeper levels

How will the salt coming past Pomanda Island be managed with a complete blockage that has a low level spillway in shallow water east of the main River channel

Does the weir prevent salts from being flushed out to sea (ie they will be built up behind the weir)

Rainfall Has consideration been given to constructing a barrage behind the temporary weir given continuing long-term low average rain fall

Proposed temporary weir Given the EIS indicates a 3 year lifespan of the weir what is the situation if the objectives of its installation are not met

Given the criteria for removal why is the design life for 3 years only

How permanent is this weir

If a weir is built upon removal will it all be removed or will it be a narrower channel

Figure 0-4 (lake level and the -15m red line) Is this the trigger for both the start of weir building and the introduction of seawater into the Lower Lakes

In the draft EIS statement there was no mention of effect on commercial social recreational or irrigation impacts Have these been considered

What is the impact of not constructing the weir

If the weir fails to guarantee water supply to Adelaide will it be removed

How long is the temporary weir to be in place

Why is the weir going to be temporary

Supplementary EIS for the temporary weir near Pomanda Island -122-

Has any consideration been given to building a barrage not a weir at Pomanda Point and removal of existing barrages below

Why not build a permanent structure which will service us for the next 100 years

Social and economic impacts Does the EPBC Act consider social and economic issues that the weir will impact on

How is this affecting tourism throughout the Lakes

How are the social and economic impacts being understood

Seawater If we let seawater in would it be flushed out again Would it return to fresh water

Is seawater into the Lakes seriously being considered What are the strong arguments against seawater as a sustainable option for the Lakes

Have we looked at letting seawater in at similar locations in Australia eg Mantra And the effects

Are Professor Gells results for c ore sampling about historic a l seawa ter being c onsidered (in letting seawater in)

Have any studies been conducted to consider the impact of salt water entering this Lake What were the outcomes of it

What prevents the weir height to be increased to say 07AHD to permit ingress of seawater to allow sufficient depth (~05AHD) and the operation of boat ramps jetties sailing clubs and safe navigation within the Lakes

Has a desalination plant option been considered for Beach 19 Lake Albert and Cantara (Replacement of fresh water from evaporation etc)

Politics and government Why has it been left so long for the urgency of this to be recognised and acted on

If the Federal government takes control of the MDB will that make this EIS invalid

Will the d ra ft EIS need to be reviewed due to the Government s rec ent dec isions regarding the blocking banks at Finniss amp Current Creeks

How does the EPBC Act deal with long-term management of the Lower Lakes

As it impacts on matters of NES does a state territory or industry need to get approval under the EPBC Act to get current or future water extractions

Why isn t the Commonwea lth ac ting to restric t a lloc a tions more urgently

Does the construction of the weir contravene Section 100 of the Australian Constitution that gives States or people rights to use water for conservation or irrigation

Due to state environmental assessments being overridden by emergency powers how a re issues suc h as wa ter a ffec ting ac tivities and wetland management p lans add ressed in this process

Miscellaneous Why is the Murray called a river when it is a series of pools

Has the idea of an island in the middle with dredging around it been considered for Lake Alexandrina

Why were 1982 figures used when 2006 was the worst case (until now)

Can we have hope that we will get to a sustainable system and that irrigation can provide Australian food

Has sea level rise been a consideration in the draft EIS and how may this impact on the weir if built

Were there EIS studies on any of the other 4000 barriers across the Murray

Has study of other precedence areas such as Mandura been done

Would it help if we had dry toilets

What level will the Lake be allowed to come up to once the weir is in place How far below the weir will the lake level be

Why have they decided on a pool of 01AHD given that previous pool level of the whole area was at +05 to 06 (Given that top of tide is +06m)

Supplementary EIS for the temporary weir near Pomanda Island -123-

How will water restrictions apply to small farmers on the river

Why wasn t Finniss Angas Bremer etc in MDB c a tc hment a rea

Why hasn t more been done about effic ienc y improvements in wa ter use by loc a ls as well as industry and people in Adelaide and beyond

If we all collected domestic water from properties etc would it negatively impact the Murray

Why isn t Myponga used to supp ly wa ter to the Fleurieu

Why has no impact study on underground water in the Currency Finniss and lower south east region been done

Has there been a comprehensive study of ground water and surface water into the area surrounding Lake Alexandrina

Why is there no navigation pass in the weir or no provision for one in the future

What will happen to Lake Alexandrina if water is pumped out into the Goolwa channel

Once the Lake is dry how will the Clayton channel then be refilled

Trigger Points Where are the trigger points for monitoring salinity and calcium carbonates sites located

Once we reach a certain trigger level at a monitoring site is the weir removed immediately or does it have to sit at a point for a certain amount of time

Will the weir be deconstructed if one trigger point is reached or all trigger points

Wha t is the trigger point for the guaranteed dec ommissioning of the weir

What are the triggers for removing the temporary weir

If the main a im of the weir is p reserva tion of Adela ide s water supp ly why is the level of water in the Lakes the trigger point for construction of the weir rather than the ability to extract water for Adelaide Is the real reason to do with Acid Sulfate in the Lakes

What is being done now to speed up the process of water allocation

Respiratory problems Low water levels are increasing the dust levels How quickly will this be covered to tackle health issues such as respiratory problems

Are health effects of the dust being surveyed What evidence is there of this

Has research been done regarding increases in respiratory problems

Supplementary EIS for the temporary weir near Pomanda Island -124-

Numbers of questionscomments on each topic indicative

Miscellaneous 20

Weir construction impacts 12

River flowsallocations 12

Wildlife 9

PoliticsGovernment 8

Sea water 7

Trigger Points 7

Regulators 6

Salinity 6

Acid Sulfate Soils 5

Social and economic impacts 3

Respiratory problemshealth 3

Lake Albert 1

Ramsar 1

Consolidated list of question topics from all Community Information Sessions

River flowsallocations 50

Weir construction impacts 47

Politics amp Government 39

Miscellaneous 37

Proposed Temporary Weir 27

Salinity issues 24

Acid Sulfate Soils 21

Wildlife 19

Seawater 10

Social and economic impacts 9

Lake Albert 7

Ramsar 7

Regulators 6

Trigger Points 7

Lock 4

Riverbanks 4

Pumping stations 3

Rainfall (Lake rain) 3

Respiratory problemshealth 3

Wetlands 2

Bioremediation 2

Supplementary EIS for the temporary weir near Pomanda Island -125-

Graph of consolidated question topics from all Community Information Sessions

All CIS Questions Summary

0

10

20

30

40

50

60

River flo

wsall

ocat

ions

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Miscel

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us

Prop

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Tem

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locks

)

Salin

ityiss

ues

AcidSu

lfate

Soils

Wild

life

Sea

water

Socia

l and

econ

omic

impa

cts

Lake

Albe

rt

Ramsa

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Regul

ator

s

Trig

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ints

Lo

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Riverb

anks

Pum

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stat

ions

Rainfa

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Respir

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Wet

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Bior

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Supplementary EIS for the temporary weir near Pomanda Island -126-

Appendix VI Advertising copy used in the consultation process

Date Thurs 12th March 2009

The Australian

The Victor Harbor Times

The Advertiser

The Southern Argus

The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -127-

Supplementary EIS for the temporary weir near Pomanda Island -128-

Date Thurs 12th March 2009

The Australian The Victor Harbor Times

The Advertiser The Southern Argus The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -129-

Supplementary EIS for the temporary weir near Pomanda Island -130-

Public Release Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island Email Update Sent 12th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -131-

Public Release Amended Draft Environmental Impact Statement for the

proposed temporary weir near Pomanda Island Email Update Sent 17th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -132-

Public Release Reminder re lodging submissions - Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 1st April 2009

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Public Release Submissions due 9 April 2009 Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 6th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -134-

Public Release Consultation period for draft EIS closes Draft Environment

Impact Statement for the proposed temporary weir near Pomanda Island

Email Update Sent 15th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -135-

CD Pack Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island

Supplementary EIS for the temporary weir near Pomanda Island -136-

Executive Summary

Supplementary EIS for the temporary weir near Pomanda Island -137-

Distribution of draft EIS Executive Summaries and CDs

Organisation Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Alexandrina Council 2 2 5 45 50 Coomandook Community Library

1 0 20 20 1

Coorong District Council 2 2 5 45 50 DEWHA library 2 2 5 5 Goolwa Public Library 1 50 50 1 Meningie Community Library 1 30 30 1 Milang Old Schoolhouse Community Centre

1 50 50

Mount Barker Community Library

1 20 20 1

Mt Barker Natural Resource Centre Mt Compass Library

1 20 20

1 Murray Bridge Library 1 Murray Bridge Natural Resource Centre

1

Rural City of Murray Bridge 2 1 National Library of Australia 2 Port Elliot Library 1 State Library Adelaide 2 1 Strathalbyn Community Library 1 Strathalbyn Council Office 2 Strathalbyn Natural Resource Centre Tailem Bend Community Library Tailem Bend Office of Coorong District Council Tintinara amp Coonalpyn Community Library Tintinara Office of Coorong District Council Victor Harbor Natural Resource Centre

1

5 5

20 20 1 30 30 1

30 30

95 100 5 5 30 30 1 50 50 50 50 1 30 30

30 30

1 30 30 1

1 30 30

1 30 30 1

1 30 30

1 30 30

Victor Harbor Public Library 1 30 30 1 Willunga Environment Centre 1 30 30 CLLMM Project Team 2 2 40 20 Mapland (DEH) 2 2 5 45 50 Meningie Community Information Session

200 100

Murray Bridge Community Information Session

200 100

Clayton Community Information Session

200 100

Goolwa Community Information Session

200 100

Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 SA Government Ministers Hon Mike Rann MP Premier Minister for Economic Development Minister for

1

20 20 20

20 20 20 10

2

10

2

Supplementary EIS for the temporary weir near Pomanda Island -138-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Sustainability and Climate Change Hon Paul Holloway MLC Minister for Urban Development and Planning

1 2 2

Hon Jay Weatherill MP Minister for Environment and Conservation

1 2 2

Hon Paul Caica MP Minister for Agriculture Food and Fisheries Minister for Regional Development

1 2 2

Hon Gail Gago MLC Minister for StateLocal Government Relations Hon M OBrien MP Minister for Employment Training and Further Education Hon T Koutsantonis MP Minister for Correctional Services Hon J Rankine MP Minister for Families and Communities Hon M Atkinson Attorney-General Hon M Wright MP Minister for Police Hon John Hill MP Minister for Health

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

Hon Kevin Foley MP Treasurer Minister for FederalState Relations

1 2 2

Hon Jane Lomax-Smith MP Minister for Tourism

1 2 2

Hon Patrick Conlon MP Minister for Transport Energy and Infrastructure

1 2 2

Hon Karlene Maywald MP Minister for the River Murray Minister for Water Security

1 2 2

Shadow Ministers Martin Hamilton-Smith MP 1 2 2 Adrian Pederick MP 1 2 2 Mitch Williams MP 1 2 2 Aust Govt Ministers Minister Penny Wong 1 2 2 Minister Peter Garret 1 2 2 SA Parliamentarians Parliamentary Leader SA Greens - Mark Parnell

1 2 2

Parliamentary Leader SA Democrats - Hon Sandra Kanck MLC

1 2 2

SA Parliamentary Library 1 1 Chief Exec DEH - Allan Holmes 1 Chief Exec EPA - Helen Fulcher 1

5 2 2

5 2 2

2Chief Exec DWLBC - Scott Ashby Chief Exec DTED - Brian

1 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -139-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Cunningham Chief Exec DTEI - Jim Hallion Chief Exec SA Water - Anne Howe Chief Exec DPC - Chris Eccles 1 2 2 Chief Exec DPLG - Ian Nightingale

1 2 2

Chief Exec PIRSA - Geoff Knight

1 2 2

Chief Exec DTF Rob Freeman 1 2 2 Dr Tony Sherbon 1 2 2 Mr Dean Brown 1 1 Mr Simon Stretton 1 2 2 Mr Sean Berg 1 2 2 CLLMM Steering Cttee 8 8 8 CLLMM Project board 4 4 4 Conservation Council of SA -Julie Pettett

1 2 5

Spares 2 2 500 500 92 15 25 2410 2012 11

Hard Copy Append CD Exec Sum CD Ordered 140 20 0 2500 2000

1 2 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -140-

Web content

Supplementary EIS for the temporary weir near Pomanda Island -141-

Supplementary EIS for the temporary weir near Pomanda Island -142-

Supplementary EIS for the temporary weir near Pomanda Island -143-

Fact Sheet

Supplementary EIS for the temporary weir near Pomanda Island -144-

Supplementary EIS for the temporary weir near Pomanda Island -145-

Appendix VII Media generated by the consultation process

Radio 12012009 410 PM ABC North amp West SA (Port Pirie) Late Afternoons - Kieran Weir Interviewees Michael Pengilly Liberal Member for Finniss Duration 10

18 01 2009 850 AM 5AA (Adela ide) Mic hael Keelan s Weekend - Michael Keelan Neil Humphrys amp June Taylor Interviewees Simon Birmingham South Australian Liberal Senator Duration 710

8012009 954 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 025

Newsreader News Director Ms Monique Crichton Duration 014

8012009 603 AM Triple M (Adelaide) 0600 News

8012009 1212 PM 5AA (Adelaide) Mornings - Mike Smithson Interviewees caller Jeff Mike Rann SA Premier Duration 1133

8012009 731 PM 5AA (Adelaide) Matthew Pantelis - Jeff Burzacott Interviewees Caller Robyn Duration 1605

8012009 1127 AM ABC 891 Adelaide (Adelaide) The Soapbox - Sonya Feldhoff Interviewees Michael Pengilly Member for Finniss Duration 328

8012009 1212 PM ABC North amp West SA ABC North amp West SA (Port Pirie) SA Country Hour -Annabelle Homer Interviewees Senator Sarah Hanson-Young Australian Greens SA Duration 415

8012009 100 PM ABC 891 Adelaide (Adelaide) 1300 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Martin Hamilton-Smith SA Opposition leader Mike Rann SA Premier Duration 119

8012009 600 PM ABC 891 Adelaide (Adelaide) 1800 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Duration 033

9012009 632 AM ABC 891 Adelaide (Adelaide) 0630 News - Newsreader Interviewees Arlene Buchan Australian Conservation Foundation (ACF) Duration 036

9012009 704 AM ABC 891 Adelaide (Adelaide) 0700 News - Newsreader Interviewees Arlene Buchan ACF Duration 050

3022009 1003 AM ABC 891 Adelaide (Adelaide) 1000 News - Newsreader Interviewees Karlene Maywald SA Minister for the River Murray Duration 046

12032009 830 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 017

12032009 521 PM ABC North amp West SA (Port Pirie) Late Afternoons - Annette Marner Interviewees Caller Tom Karlene Maywald Minister for Water Security

Supplementary EIS for the temporary weir near Pomanda Island -146-

Duration 847

13032009 809 AM 5AA (Adelaide) Pilkington amp Conlon - Tony Pilkington amp Keith Conlon Interviewees Karlene Maywald SA Minister for the River Murray and Water Security Duration 628

13032009 840 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan - live from Goolwa Interviewees Prof Diane Bell Resident and former Federal independent candidate for the Seat of Mayo Duration 239

13032009 910 AM 5AA (Adelaide) Mornings - Mike Smithson Interviewees Senator Sarah Hanson-Young Australian Greens Party Duration 612

13032009 1024 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan Interviewees Clem Mason Lower Lakes and Coorong Infrastructure Committee Lesley Fisher Lower Lakes and Coorong Infrastructure Committee Duration 923

13032009 1105 AM ABC 891 Adelaide (Adelaide) The Soapbox - Matthew Abraham and David Bevan live at the Goolwa Sailing Club Interviewees Dean Brown Premiers Special Drought Advisor Robyn McLeod SA Independent Water Commissioner Duration 603

31032009 835 AM ABC North amp West SA (Port Pirie) Morning Show - Kieran Weir Interviewees Dr Jochen Kaempf Oceanographer Senior Lecturer Flinders Uni Duration 1136

Television 8012009 600 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Martin Hamilton-Smith SA Opposition leader Peter Garrett Federal Minister for the Environment Rory McEwen Acting Water Minister Senator Sarah Hanson-Young Australian Greens Party Simon Birmingham Liberal Senator for SA Duration 135

8012009 601 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Henry Jones fisher Jock Veenstra tourism operator Kym McHugh Mayor Alexandrina Michael Smyth Channel 9 reporter Duration 200

12032009 516 PM Channel 10 (Adelaide) TEN News - George Donikian and Rebecca Morse Interviewees Karlene Maywald Water Security Minister Mark Parnell Australian Greens Martin Hamilton-Smith SA Opposition leader Duration 147

Print media PG227 13 March 2009 The Hon Peter Garrett MP Minister for the Environment Heritage and the Arts Final terms of reference for Barrage EIS httpwwwenvironmentgovauepbcnoticesassessmentslower-lakeshtml Stock Journal 19032009 p 8 General News Adelaide Advertiser 14032009 p 27 General News Lakelander 27032009 p 9 General News Stock Journal 19032009 p 12 General News Stock Journal 19032009 p 16 Letters Times Victor Harbour 19032009 p 1 General News Murray Valley Standard 19032009 p 4 General News

Supplementary EIS for the temporary weir near Pomanda Island -147-

Appendix VIII Summary information of enquiries and

submissions for provision of the proposed temporary weir

Summary information

Number of phone calls to EIS hotline 52 Number of emails to eisdehsagovau from unique individuals 82 Number of feedback comments on the CLLMM website 14 Number of subscriptions to e-newsletter via the CLLMM website 48 Number of Community Information Session registrations on the CLLMM website 47

Number of submissions received by email 61 Number of submissions received by letter 9 Total number of submissions received 70

Number of unique visitors to the CLLMM website 1588 Number of visits to the CLLMM website 2834 Number of page views on the CLLMM website 9343

Supplementary EIS for the temporary weir near Pomanda Island -148-

Submission Summary

Mr Roger Cooke The writer proposes a major scheme which aims to simultaneously drought-proof the Murray-Darling Basin and to meet 2020 emissions targets Features of the scheme include - Laying concurrently gas and water pipelines from the NW Shelf to major centres including SA mining towns and Adelaide - Laying irrigation pipes to replace open channels a financial stimulus package - Piping LNG to replace coal-fired energy production assisting Australia to meet 2020 emissions targets The submission outlines a national water distribution scheme as well as a proposal for creating a river channel in order to prevent evaporation across the Lakes while maintaining a freshwater channel The writer proposes a scheme for a long-term solution to the Lower Lakes The writer suggests a permanent weir is necessary as drought will increase in severity and frequency The proposed scheme would aim to reduce evaporation occurring over the Lakes by creating a channel from a proposed permanent weir to the barrages The writer suggests benefits to the Coorong mitigation of Acid Sulfate Soils a freshwater environment for boating while p rotec ting Ad ela id e s wa ter supp ly

Mr Michael Galea Argues there are too many unquantifiable risks associated with the proposed weir and freshwater is needed now The writer bases the submission on local knowledge and common sense He reports the awesome impact of low water on many plants and animals in recent years in the vicinity of Clayton Bay He expresses concern that a weir will pool polluted water upstream and the saline spike will kill tens of thousands of carp and pollute Lake Alexandrina

Mr Philip Fargher The writer is keen to see base environmental River flows established through the use of Commonwealth Government powers The writer outlines established processes of River flooding which periodically flushed out saline water from the Lower Lakes and Coorong Changes to the system due to locks allocations irrigation and the barrage are noted Seawater flooding of the Lakes is thought to lead to negative and unpredictable results as tidal exchanges are insufficient Acid Sulfate Soils require freshwater flows or peripheral lime sand

Mr Andrew Zoerner The writer is concerned that a freshwater environment in the Lower Lakes will not survive unless a Lock is built east of Clayton as well as a water pipeline from Wellington The aim is to maintain freshwater around Goolwa Hindmarsh Island and Clayton for environmental cultural historical industrial recreational and tourism reasons while preserving local flora and fauna

Mr Douglas Smith The submission has nine points The author seeks clarification identifies gaps and expresses points of view The author asks that the definition of sea level and salinity measures are clarified He notes that ferry operations are

Appendix IX Table of submissions

The table below provides a summary of submissions received during the public consultation period An electronic copy of the submission can be located on the DEH website httpwwwenvironmentsagovaucllmmtemporary-weirhtml

Submission no

PTW00001

PTW00002

PTW00003

PTW00004

Submission from

PTW00005

Supplementary EIS for the temporary weir near Pomanda Island -149--

Submission no

Submission from Submission Summary

not discussed under the do nothing option and notes that the difficulties of decommissioning a weir are understated He notices that there is no discussion of management of blue green algal blooms above the temporary weir

PTW00006 Ms Melanie Rees The author argues that efforts to mitigate negative impacts of a proposed temporary weir are grossly inadequate and any amendments envisaged to the draft EIS will not make the weir development acceptable Threats to species and communities are not adequately addressed or are downplayed or discountedThe author indicates concern about the lack of genuine community consultation and argues that the weir development should be considered with other developments because there are cumulative impacts She expresses points of view on public understanding of pertinent issues drought the importance of cost benefit analysis and suggests changed wordings The author suggests investigating filling reservoirs and drawing from them while relocating pumping stations She suggests that stormwater statistics are inaccurate and recommends increasing stormwater harvesting to alleviate reliance on the River Murray The author provides detailed information about the Southern Emu-wren noting Draft EIS information is out of date Gaps are identified in that phytophthora impacts are not considered at the weir building site and the impact of a weir on Callop fish is not discussed

PTW00007 Mr John Clark President Southern Alexandrina Business Association Inc

This submission puts a case for an alternative to the proposed temporary weir near Pomanda Island SABA argues for a permanent lock (Lock 0) in the vicinity of Tailem Bend SABA refers to Gell et al and notes the estuarine but predominantly freshwater environment of the Lower Lakes A navigable lock with a fishway would support the ecology and recreational fishing and boating (boating valued at $200m pa) and meet water security objectives SABA argues that climate change increases the logic of a permanent Lock 0 Supports remediation and revegetation where appropriate and seawaterif needed to check Acid Sulfate Soils

PTW00008 Mr Mike Brisco This submission draws on authoritative literature on climate change The author argues that the weir is proposed in an inadequate context that is the context of severe drought in south eastern Australia The proposed weir should be located in other scenarios - especially for example that of rapid climate change In the event that the weir needs to remain in place projected sea level rises need to be considered in its design The main point is that the impacts of the proposed weir cannot be understood in an inadequate context An additional chapter is suggested Other detailed suggestions are made for changes to the draft These changes show more dramatic water security issues than currently documented in the draft EIS (for example diminished run off over time into Adelaide water storages)

PTW00009 Mr Ian Moyle The writer has lived and worked at Narrung and has lasting educational and environmental interests in the Lakes and Coorong He is c onc erned b y governments lac k of acknowledgement of climate change and previous poor water management He urges the state government to get serious about collecting and using rainwater and grey

Supplementary EIS for the temporary weir near Pomanda Island -150shy

Submission no

Submission from Submission Summary

water re-use PTW00010 Ms Jan Meek

Secretary Signal Point Riverine Environment Group Inc

The group believes a weir willl become permanent and that a revised draft EIS should be prepared based on this premise There are seven issues of concern listed Gaps and lack of clarity in the draft EIS are identified The group indicates - that species rescue outside the Ramsar boundary is unacceptable and that the EIS needs to include species impact statements on a range of species - that an impact of a weir will be increased salt discharge salt interception schemes or mitigation measures need consideration - weir removal triggers are unrealistic and imprecise and out of the control of the SA Government

PTW00011 Mr Richard Harvey

PTW00012 Ms Sally Richards

The writer has a long association with the Coorong and Lower Lakes He indicates his opposition to any seawater incursion In relation to the weir he understands that in the order of 500 tonnes of salt a day would build up This would impair water piped to Narrung The writer urges strong action by Federal Government to reverse over-allocation The writers submission is informed by her residence in the Finniss Catchment and membership of the Finniss Catchment Group Points made by the writer include - more freshwater in the river system - over-allocation and poor management of water continues today - for example in the Finniss catchment where there is no Water Allocation Plan - system wide over-allocation must be addressed - more species than those listed in the draft EIS should be considered - the weir will have impacts beyond the weir site The writer advocates working with community and nature and and disallowing XXXXXXX water supply control (company not named for legal reasons)

PTW00013 Mr Trevor Giles

PTW00014 Ms Brenda Lower

The writer has very extensive experience living and working as a primary producer in the Langhorne Creek District and has a strong attachment to the Lower Murray Region He notes the lack of freshwater will lead to habitat loss and that all water supply proposals are interconnected All projects together are an overall threat to the environment Other concerns include - the bund at Narrung Narrows and proposed regulators prevent wind seiche - lack of consideration of groundwater - no fishway inclusion - the unsuitability of the weir site Freshwater is the only viable solution to retaining habitat The writer is concerned about the river and the people of the district and she asserts that water is needed now The author notes negative impacts of increasingly saline water on turtles birds and fish and is concerned about sulfidic soils and human health The author favours a permanent weir and seawater incursions to cover soils

PTW00015 Mr Frederick Gordon Michelmore Farmer

The author is concerned by the increasing salinity in the Lakes He suggests spending 10 of the cost of the weir on increasing rainwater capture from roofs Other sources of water must be found because the river can not keep up with demand

Supplementary EIS for the temporary weir near Pomanda Island -151shy

Submission Summary

Ms Ann Lucas The writer is concerned about previously estuarine areas between the Murray Mouth and Beacon 19Goolwa Barrage which are an important habitat for migratory birds It is suggested freshwater is accessed for the area in order to return it to estuarine conditions - possibly through the use of an inexpensive Desal plant

Mr Glen Jones General Manager Boating Industry Association of SA Inc (BIASA)

Points on matters of national environmental significance relating to the EIS no comment Concerns - BIASA would have liked to see provision for boating

ac c ess (a vessel loc k ) through the weir - the greatest concerns of BIASA are for both the natural environment and the declining economic viability of many businesses and communities along the River Murray downstream from Lock 1 and in the CLLMM region - concerns are for both the immediate situation and the longer term The submission documents the broad membership of BIASA the operation of BIASA and the organizations with which it liaises and for which it provides advice The submission documents financial losses being incurred (economic losses $ figures) as a result of low water levels and low water flows The cost of repairing river bank slumping and impact on ferry services and nearby communities are mentioned The impact of low water levels and low water flows in the CLLMM on social and health wellbeing of communities and jobs in boating and tourism businesses is documented in some detail and discussed The submission supports the immediate construction of a weir

Mr John Coombe Chief Executive Alexandrina Council

Points on matters of national environmental significance relating to the EIS - concern about the future health of the Ramsar protected areas - concern about the lack of fish passage between Lake Alexandrina and the River Murray and vice versa Concerns - most concerns are based on the premise that the weir will reduce water flows into the CLLMM region however this will be temporary only (90 days) - potential for unknown andor unforeseen impacts of building a weir on biodiversity and water quality both upstream and below the proposed weir - the biodiversity of the CLLMM region is dependent on freshwater for survival and is getting insufficient freshwater - infestations of tubeworms and other pests have the capacity to impact on biodiversity including turtles (not currently listed under EPBC Act) - health problems caused by excess dust from dry lake bed areas - increased impact of environmental condition on social and economic wellbeing of the region Suggestions building of a lock upstream is preferred because it will allow fish passage and boating access up and downstream

Mr Derek Fenton Points on matters of national environmental significance relating to the EIS No specific points were raised but a concern was expressed about impact on other species which are not listed under the EPBC Act

Submission no

PTW00016

PTW00017

PTW00018

Submission from

PTW00019

Supplementary EIS for the temporary weir near Pomanda Island -152shy

Submission Summary

Concerns the main concern is for lack of water for environmental flows in the River Murray in the CLLMM area

PTW00020 Ms Vesper Tjukonai Points on matters of national significance relating to the EIS not addressed except to say that in Ngarrindjeri traditional thinking animal bird and fish species (part of Ruwe) are not separated as in Chapter 13 but considered in an integrated way Concerns - questions the thoroughness of consultation with Ngarrindjeri Traditional Owners - impact of declining quality of river systems on humans (especially Ngarrindjeri in this case) - construction of weir would reduce water flows available for the Ngarrindjeri - continuing noise nuisance from pumps at Narrung Narrows pumping especially low frequency noise (health problem) - lack of clarity of the relationship between the Narrung Narrows bund the proposed weir and the future need for pumping at Narrung Narrows - potential health impacts of dust from the exposed edges of drying lakes - there could be increased pumping in summer and autumn at Narrung Narrows if the weir is built - current restriction of activities including collection of traditional foods basket making and others - soc ia l imp a c ts of the d rought a nd inappropriate water

hoard ing and fa rming method s Suggestions - Include the Ngarrindjeri Nation as Traditional Owners of the CLLMM region in the Draft EIS Executive Summary and Draft EIS Fact Sheet - Refer to Ngarrind jeri as Nation and Trad itiona l Owners - Go beyond consultation to partnership with traditional owners in planning and management - Consideration of impact of the drought and water quality situation on humans (Ngarrindjeri Nation and the wider community)

PTW00021 Mr Keith McFarlane

Background local landowner along Lake Alexandrina (family since 1845) cattle production irrigation Points relating to matters of national environmental significance EIS - Mr McFarlane says that the CLLMM is the most important part of the MBD and that river flows must be allowed for environmental maintenance as the highest priority - He is concerned that increased salinity below lock 1 caused by building the weir will be disastrous for the Ramsar-listed wetlands - He is also concerned that mud disturbance around the weir site during construction would turn the water saline and impact on all fish species Mr McFarlane does not support the building of the temporary weir at Pomanda Island The closure of wetlands along the River Murray is supported as long as there is periodic re-wetting Additional concerns Mr McFarlane is concerned that the seasonality of wind direction and speed across Lake Alexandrina may not have been taken into account when the modelling was done and that SW winds in winter and spring will counteract river flow such that river salinity will

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -153shy

Submission no

Submission from Submission Summary

build up more quickly than has been suggested in the draft EIS Suggestions - that Acid Sulfate Soils have not been a problem to date and could be counteracted in future by seeding into exposed areas - it is not necessary to keep the Lakes up to pool level in drought because the Lakes will present a smaller surface area for evaporation reducing amount of water lost - establishment of more rainfall recording stations around the Lower Lakes region to improve the accuracy of data used in modelling

PTW00022 Mr Tom Chapman Director The Marina Hindmarsh Island

Points relating to matters of national environmental significance EIS - the weir would reduce (economic and) environmental activities of the LLMM region - suggests that a fishway should be included in the weir Support the submission supports the proposed weir as a last resort but argues that a permanent lock between Tailem Bend is a better solution He views the weir as a high cost item to build and maintain as well as not allowing boating access between the Lakes and the River Concerns Mr Chapman is very concerned about the impact of lack of boating access through the proposed weir and the consequent negative impact on economic activity in the LLMM region especially on the recovery of boating but not necessarily limited to boating Perspective a worst case scenario and the weir might not be removed for a considerable time (many years) Alongside this he also supports the introduction of seawater into the LLMM and makes points about historic and current salinity levels in the LLMM

PTW00023 Mr Tony Read The author argues that there is no compelling evidence to build a weir He indicates that long-term investments are required for long-term solutions A short and a long-term solution exist The author refers to research into aquifers beneath the Adelaide Plains and provides a reference He indicates that groundwater bores can be increased quickly if necessary and argues that brackish bore water can be desalinated more cheaply than seawater He makes a case for a long-term solution that is the Twin Lakes concept He notes that the partial weir options do not support any argument to build a weir

PTW00024 Mr Mick The writer supports building a weir He notes that people upstream are suffering He is concerned about evaporation losses

PTW00025 Ms Anne Hartnett Points on matters of national environmental significance relating to the EIS - this EIS is only a partia l doc ument bec ause there a re many interrelated interventions occurring in the CLLMM region a single holistic EIS should be put together covering all of the interventions - the site of the proposed temporary weir is at or near a biodiversity hotspot as pointed out in Appendix 15 and was this considered when the site was chosen - potential for release of metals (including heavy metals) from sediments by acidification and associated ecological impacts are unknown

Supplementary EIS for the temporary weir near Pomanda Island -154shy

Submission no

Submission from Submission Summary

- the potential threat of blue-green algal outbreaks and the associated impact are not addressed sufficiently - concern that the honouring of international biodiversity agreements is not a high priority (migratory birds Ramsar wetlands) - an apparent inconsistency in that -15 m AHD is proposed as the trigger level for building a weir and is also the point at which Acid Sulfate Soil risk increases substantially yet the water level after building a weir

will drop below this to -167 m AHD concern that the scenario from here might need to include seawater introduction into the lakes and there is no EIS relating to this possible intervention Concerns - the size and therefore the impact of mud waves generated during the construction of the proposed weir are unknown - the lack of information on rates of acidification and lack of chemical analysis of the sediments and the potential for release of heavy metals upon acidification - cutting off the river from the Lake by building the weir leading to loss of the aerating wind seiche effect - if there are low water flows over the weir in future what will be the impact on water salinity levels upstream - has sought clarification on the cost of engineering solutions but not received information Expresses supports for 10 other submissions Suggestion - proposes that the money that would be spent on all interventions and engineering solutions be used instead to buy water for environmental benefit as well as human consumption

PTW00026 Ms Judy Goode River Murray Environment Manager SAMDB NRM Board

The SA MDB NRM Board agrees the weir should only be built when all other solutions have been exhausted The submission argues in detail and with reference to EPBC-listed species and numerous other species that a fish passage is required to support migration of species upstream and downstream and to support upstream movement as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river Upstream wetlands The submission asks for consideration of the environmental impacts of re-filling wetlands and potential impacts of Acid Sulfate Soil mobilising into the river The submission indicates inadequate measurement of water savings from wetland closures in Section 434 There is an unquantified assumption about the prevalence of the Southern bell frog in Section 1310 which requires consideration Water qualitywater quantity impacts A significant omission is identified in that salinity impacts are not modelled over three years The weir pool above the weir will be relatively small and the impact of wind seiche in the pool is not understood Additional modelling is sought for acid release from acid

Supplementary EIS for the temporary weir near Pomanda Island -155shy

Submission no

Submission from Submission Summary

soils metals release increased nutrient loads blue-green algal outbreaks increased sedimentation and turbidity increased temperatures fish and other biota kills odour dissolved dust fuel and oil spills Further modelling on a range of scenarios Impacts of construction The weir site is at a junction of the Lake and River and is a biodiversity hot spot A more comprehensive explanation of the choice of this weir site is required Technical issuesmore details which require more consideration What are the environmental impacts of sourcing the weir building materials SA Planning justification in writing for exemption under the Development Act Environment and Construction Management Plans How do all the costs which would be included in a properly constituted business plan compare to the potential purchase of water (for a freshwater solution)

PTW00027

PTW00028

Mr Alexander Whitehead Hindmarsh Island resident

Supports the building of a weir at Pomanda Island Also suggests that regulators not be built in the lower reaches of the river and that seawater be allowed into the Lakes

Prof Peter Fairweather Professor of Marine Biology School of Biological Sciences

Background Research Associate and Prof of Marine Biology Flinders University Points on matters of national significance relating to the EIS - the submission raises a number of concerns about the adequacy of the geographic scope of the EIS the treatment of different types of aquatic habitat the use of averages in modelling and several other points listed below Concerns - there is a concern about gaps in the EIS relating to factors that drive ecosystem change the submission questions whether maxima minima and seasonality rates of change have been considered in addition

to average values as these are important - argues that the Coorong and Lake Albert will be affected and should therefore be included in the EIS - questions whether the impact of a weir really is insignificant relative to the effects of drought - questions the reliability of modelling for years 2 and 3 and suggests that more caution should be used in interpretation towards the end of the period - that there is a gap in the EIS in the treatment of aquatic habitat types such as the benthos and the water column - that the different models appear to use different weather sequences to predict outcomes for the same sets of years and that more attention should be given to variation as a result of different weather sequences The authors are not opposed to the need for or construction of a weir but argue that the accuracy of the EIS needs to be improved in relation to several matters of national environmental significance Other points raised The legibility of many Figures in the EIS was not adequate A comment about bird species discussed in 142 and 143 and whether these are the correct or appropriate species

Mr Robert Thomas Points on matters of national environmental significance relating to the EIS none

PTW00029

Supplementary EIS for the temporary weir near Pomanda Island -156shy

Submission no

Submission from Submission Summary

Concerns - concerned about health problems relating to lowered Lake water levels (dust) Supports the construction of a weir at Pomanda Island Suggestions - not to build the regulators around the lower reaches of the River and allow seawater into the Lakes - as a longer term solution suggests the building of a barrage with a lock at Wellington

PTW00030

PTW00031

PTW00032

PTW00033

Ms Barbara Carroll Native Foods amp Plants

Confidential submission

Mr Henry Jones Commercial Fisherman Boating Industry Association

The writer is a commercial fisherman He and his family have been in the Coorong Lower Lakes and Murray Mouth commercial fishing industry for six generations The industry in the area has achieved a number of significant firsts in sustainable fishery management The author now feels ashamed for the following reasons - the extinction of species - the dredging of the Murray Mouth - the death of two thirds of the Coorong - the changing from estuarine to marine of the remaining third of the Coorong - the change from once busy bustling wetlands to a sandy wind-blown desert - the exposure of Acid Sulfate Soils - the pain inflicted on our native animals especially the pain and death of turtles - the slow death of native water rats deprived of habitat - the death of small Lake birds who no longer have their sustaining habitat - the tonnes of dead mussels invertebrates and macro invertebrates - the Government blaming drought rather than providing environmental flows The writer submits that a weir will cause major fish kills and further environmental decay

Ms Gloria Booker Manager Development amp Environmental Services Rural City of Murray Bridge

The submission points out that there was insufficient time for Elected Members and the Council to provide formal comment The Murray Bridge community may receive aesthetic and environmental benefits from raising the River level but this should not be to the detriment of native wild life and migratory birds Points made include - the weir is a last resort in ensuring water for critical human needs - ecological damage is not irreversible - the proposed weir is of sufficient height to prevent salinity moving upstream from Wellington - professional fishermen are provided with access to Lake Alexandrina - the location of pumps does not allow salt water to be washed back into the river - consideration be given to allowing river craft and fish to move from the River to the Lake

Mr Chris Bagley Dryland Farmer

Points on matters of national environmental significance relating to the EIS - the Draft EIS carries no mention of the highly regarded and important Milang Snipe Sanctuary Concerns

Supplementary EIS for the temporary weir near Pomanda Island -157shy

Submission no

Submission from Submission Summary

- that SA water planning focuses too much on consumption - that the Draft EIS indicates that only 50 of the weir material is to be removed a the end of its life and that this is not acceptable - that there may be a weir collapse with associated impacts due to the nature of the base material Suggestions - the a uthor strong ly suggests tha t Dilution Flow be

rep lac ed by the c onc ep t of Maintena nc e Flow with a rationale and that MDB management should focus on this - that the Draft EIS focuses on a base flow of 350GLyear past Pomanda Island he suggests that other scenarios and their impacts also need to be considered including zero flow 700GLyr and 2000GLyr - the author supplies a water resource report for the MDB (Mar 09) and proceeds to argue that SA can buy environmental water to save the Lower Lakes without building the weir and for 25 less cost than weir

construction and removal a set of Tables outlining water purchases over the next 3 years is presented

PTW00034 Ms Liz Yelland General concerns are expressed about the draft EIS It fails to concentrate on all species and acknowledge interdependency It fails to persuade that sufficient water will overspill the weir into the Lake No or insufficient water could result in Carp dying and then all Lake life dying Suggests that the proposed temporary weir EIS should be considered with a seawater incursion EIS In relation to chapter 10 the author is concerned that Weir construction will signal to upstream river management that there is no need to provide water to replenish the Lakes as it evaporates Ch 10 is not predicated on the view that there is already an environmental emergency further endangering international treaty sites - Political will addressing over-allocation can save these wetlands - The author expresses concerns about Goolwa Channel and Finniss and Currency Creek regulators - Questions why so little attention is given to the Coorong Comments on Ch 5 - The writer provides an image of childrens Lego sinking in porridge - Local knowledge and draft EIS Appendix 6 are referred to as the author makes the case for the difficulty of establishing the weir at the designated site Comments on Ch 11 - Asks the question what is the possible effect of cutting off the seiche surges of water from Lake Alexandrina into the lower reaches of the River Murray - Local knowledge of seiching is provided which indicates that the River beyond Murray Bridge during times of very low flows has been oxygenated and saved - Also during low flow periods the seiche and wind variations allows salinity and pollution burden to be transported to the Murray Mouth Should seiching be interrupted increasing salt build up causes flocculation of clay particles suspended in the River Conditions then support the possibility of blue-green algae blooms

Supplementary EIS for the temporary weir near Pomanda Island -158shy

Submission no

Submission from Submission Summary

- The author is sceptical that temperature inversion will mix salt to an extent which allows low flow to transport it away - Negative effects of seiching - Salinity build up since 2002 is described (reference provided) - Acid A graph is provided with detailed interpretation of wind salinity water levels and pH The author concludes that generally wind seiching has positive outcomes and that acid is not showing signs of being a problem and salinity could be managed by intermittently ceasing pumping - Concerns about mobilising acid upstream from the weir in wetlands which have been cut from the River Comments on Chap 16 - It is the author s view tha t the EIS implies a n ac c ep tanc e of an unacceptable environmental collapse which shames country and governmentThe weir is an enormous gamble due to the possibility of the weir sinking that construction methods will be ineffective and there are probable unexpected consequences

PTW00035 Mr Lynton Vonow Points on matters of national environmental significance relating to the EIS - the EIS is deficient in that it is not presented as part of an integrated plan for the region and its water and environmental problems - potential impact of building a weircompared to only

having the sill a t the entra nc e to Lake Alexa nd rina a t Pomanda on fish eg Murray Cod Concerns - that the environmental impacts of permanent weirs along the River Murray are severe and the temporary weir poses a similar risk - that the weir would increase the likelihood of blue-green algal blooms in the river upstream of the weir (and associated risk to drinking water supply) - that the salinity spike that would occur in the water near Pomanda Island after construction of the weir would be very detrimental to long-necked tortoises through the negative direct impact of tubeworms which are salt-tolerant Suggestions - that better alternatives to building a weir are (a) purchasing water (b) increasing water harvesting in the metropolitan area of Adelaide (c) relocation of pumping stations to upstream of Lock 1 and that increasing the storage at Mt Bold reservoir has significant problems including negative environmental impacts - that as the Lake levels drop the problem of wind seiching of saline water into the river will decrease - that acid Sulfate Soils are not as serious a problem as was predicted - that allowing seawater into the Lower Lakes would be very destructive The author supports the submissions of 17 other people and groups

PTW00036 Ms Ruth Trigg Concerns - the author is concerned about the basic premise(s) for construction of a weir at Pomanda Island and offers a critique of the process which has led to this point She analyses Chapter 3 of the Draft EIS using an

Supplementary EIS for the temporary weir near Pomanda Island -159shy

Submission

no Submission from Submission Summary

ana lytic a l framework and a toolkit of d ifferent method s (such as Critical Discourse Analysis and a number of others) - from the list of 73 reports agreements and Acts of Parliament relevant to the River Murray system in the CLLMM region (cited in the submission and in Chapter 3) it is argued that the existence of these documents has not helped to retain the long-term health

of the river system - the lack of accountability with regard to the health of the MDB river system in the present system of government and interactions between governments - the unavailability of water audit figures for the whole MDB system for more than one month of data at a time (data seen as withheld) - tha t the voic e of multina tiona l c omp anies and sha rehold ers overrid es the environment s need s illustra ted

with recent quotes from the media about continued expansion of irrigation in upstream states - that the decision to build the proposed weir is connected

with the a im of g rowing South Austra lia s popula tion (to 2 million by 2050) and that keeping this expansion target in the face of present difficulties with the

sta te s wa ter sup p ly is unreasona b le - that the collective voices of knowledgeable people who live near and care about the River system in the CLLMM region will not be listened to Suggestions - the author suggests that new models of economic growth and development need to be urgently considered (eg further development and use of the Genuine Progress Indicator Dr P Lawn Flinders University) The author supports the submissions of 16 other individuals and groups

Supplementary EIS for the temporary weir near Pomanda Island -160shy

PTW00037 Mr John Yelland Points on matters of national environmental significance relating to the EIS - concern that the EIS guidelines have not been followed Concerns - the author seriously questions whether the weir structure can be built considering the nature of the foundation material especially the apparent unsuitability of the foundation at the western end and quotes material presented in Appendix 5 - the mud waves formed by the dumping of rock have not been studied adequately - the wetlands upstream of the proposed weir which are currently dry will be re-wet at some stage with potential for acid formation and release of heavy metals these acids and metals might not be adequately

flushed with the weir in place and the risks need to be studied - the Draft EIS is deficient in that it does not refer to other proposals such as the regulators at Clayton and at Finniss and Currency Creeks modelling of salinity and Lake water levels should take these other

developments into account The author supports the submissions of 13 other individuals and groups

PTW00038 Mr Bruce Brooks Points on matters of national environmental significance relating to the EIS no direct comment but questions are asked about some assumptions and the accuracy of

Submission

no Submission from Submission Summary

modelling presented in the EIS which lead to decision points (water levels wind speed and salinity) Concerns - argues that the problems of the CLLMM are not primarily a result of drought by comparing Figures 0-2 and a graph showing Murray-Darling Catchment annual rainfall trends 1950 2008 (both graphs with trendlines the latter graph possibly not in the draft EIS but presented at community consultation meetings) - argues that the data and modelling that have been used that point to -15 mAHD (trigger point) being reached in Lake Alexandrina in early 2010 may be incorrect and predicts that the levels reached will not be as low as this in the worst case scenario Further he presents data from Kotwicki 1993 (a factor relating evaporation from the lake to pan evaporation measured in situ at the lake) which differs from the factor used b y MDBC a nd uses Kotwic ki s factor to arrive at a higher Lake water level than predicted in the EIS - concern that the salinity levels in the Lakes in the modelling output presented in the EIS are underestimates and that the data need to be looked at again

PTW00039 Dr Keith Walker This is a detailed submission which provides important knowledge and information on a range of relevant issues including ecology and threatened species of the lower Murray and CLLMM The submission raises many pertinent questions Points on matters of national environmental significance relating to the EIS - a weir pool is not the same habitat for plants and animals as a river or a lake conditions in the pool will favour species such as common carp and discourage riverine species in particular - there should be a fish passage in plans for the weir - the author is concerned that diadromous fish (ie requiring access to the sea) are prevalent in the lower Murray but these would be unable to move beyond the weir - more consideration should have been given to the wetlands between Blanchetown and Wellington - contends that statements on page 13-17 (Interaction of salinity with EPBC-listed fish species) about salinity tolerance of early stages of freshwater fish are misleading - the author says that the discussion of EPBC-listed species is incomplete and superficial - states that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the MDB including the CLLMM region are currently being evaluated for EPBC listing

- the author disagrees with statements in the Draft EIS that suggest tha t the weir would not a ffec t c ond itions a fter d isc onnec tion a rguing instead tha t rec overy will b e delayed - suggests that Chowilla should be listed among the Ramsar wetlands because birds may need to move that far if food becomes scarce in the CLLMM region Concerns - the proposal should be considered alongside other current and planned interventions in the CLLMM regions for

Supplementary EIS for the temporary weir near Pomanda Island -161shy

Submission no

Submission from Submission Summary

the purpose of the EPBC Act - that over-allocation of water is likely to be a major contributor to the crisis in the CLLMM - that the alternatives to a weir have not been adequately considered in terms of feasibility costs and benefits in economic and environmental terms ideas such as shandying water are put forward - that there is a significant risk of development of algal blooms including toxic blooms in the weir pool and that there is scientific literature on this local situation - that the weir will be in place for at least 10 years (with reasoning for this conclusion) - the construction of access roads to Pomanda Island should have been subject to an EIS as it iswas a (dynamic) sand spit - that there is little reference in the EIS to work on Acid Sulfate Soils in other places - that the salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences that the tolerable salinity limits for freshwater species need to take into account peak levels not

average levels - that flooding of the Lakes region with seawater will cause a total ecosystem collapse of a Ramsar-listed wetland - that the weir will have an impact on pest species (common Carp and tubeworm) but this is not addressed in the Draft EIS - tha t the term keystone spec ies is misused in Chapter 6 Suggestions - more attention should be paid to mixing processes in the weir pool and Lake Alexandrina with respect to the perceived increased risk of algal bloom formation - tha t we should ma ke more use of others c onsid erab le experience on dealing with Acid Sulfate Soils

PTW00040 Ms Alison Radford SA President Australian Institute of Landscape Architects

The AILA notes that the following points appear to be missing from the Executive Summary under the terms of reference of the EIS and should be included there as they have been addressed in the body of the Draft EIS - what is the potential for deterioration of the quality of water in the weir pool - is there a soil acidification risk upstream as a result of the construction works - how will the weir pool be filled without increased water flows to the River - there d oes not a p p ear to b e any worst c ase sc ena rio discussion of the effects of further disrupting flows within the main River channel Also AILA notes that while there has been a lot of discussion of impacts downstream from the proposed weir in the Draft EIS there is not a corresponding examination of effects upstream AILA requests that future consultation processes include information sessions in the Adelaide metropolitan area

PTW00041 Mr Trevor Harden This submission argues that dust from exposed dry lake beds in the CLLMM region is a major problem and concern and that the best way to control this problem is to fill the Lower Lakes region with seawater a step which requires that the weir at Pomanda Island be built as soon as possible The author is opposed to community groups who advocate a freshwater solution only and argues that historically the

Supplementary EIS for the temporary weir near Pomanda Island -162shy

Submission no

Submission from Submission Summary

CLLMM area is very likely to have been saline especially at times of low river flow He takes issue with the d oc ument A Fresh History of the La kes by Sim and Muller a nd a rg ues with the support of quotes from journals and personal observations that the CLLMM has a history of being a saline estuary at certain times

PTW00042 Mr Bruce Angus Allnutt Committee Member River Lakes amp Coorong Action Group

The submission mainly addresses Chapters 8 and 10 of the Draft EIS Points on matters of national environmental significance relating to the EIS - queries why there is no fishway in the proposed weir - contends that many statements in the Draft EIS use

language tha t suggest there may be impac ts but the authors believe that many of these impacts will definitely eventuate - the authors suggest that impacts on non-listed EPBC-listed species can affect EPBC-listed species because they are part of the same food chain Errors - Page 10-2 of the Draft EIS the authors state that

Tookayerta Creek is a tributary of the Finniss River not of Lake Alexandrina also the Finniss River and Currency Creek flow into the Lower Murray not Lake Alexandrina Concerns - the lack of consideration of ground water resources in the

Draft EIS - that the site for the weir is unsuitable - the loss of habitat due to lack of freshwater flows - that the social issues and impacts are not addressed - that the effects of drought on low water levels are overstated and that the impacts of water over-allocation are likely to be substantial - Table 10-4 states that water levels in Lake Alexandrina will be maintained at +08 mAHD the authors argue that levels of no greater than +07 mAHD should be maintained otherwise there can be serious

erosion damage - the authors are concerned that the systems modelling uses incorrect assumptions or is not reliable (Table 10-8 and Section 1042) - that Section 107 may not be taking into account the extraction of water from pipelines being constructed that take off water upstream of the proposed weir Questions and suggestions - that the EIS should be part of a combined EIS for the larger set of interventions occurring in the CLLMM region - Section 823 that hazardous substances be stored well away from the weir site during construction - query whether the site of the spillway is optimal and suggest that in the present eastern location this will lead to worse silting problems than if it were placed further west - on page 10-3 there are additional reasons for increase in salinity in the Lower Lakes - in Table 10-3 the word sp illway should be inserted a fter weir in the sec ond aspec t point - query why the dilution flow would be disrupted apart from during the weir pool filling period (Table 10-3) - in Table 10-4 there should be a LAC for the Angas River - the modelling has used worst case scenarios was any modelling done with other scenarios

Supplementary EIS for the temporary weir near Pomanda Island -163shy

Submission no

Submission from Submission Summary

- the authors would like clarification of the last paragraph on page 10-30 - top of page 10-31 The authors endorse the majority of the key points of 15 other submissions

PTW00043 Mr Neil Shillabeer Chairperson Lower Lakes and Coorong Infrastructure Committee

Points on matters of national environmental significance relating to the EIS - potential effects of significant mud displacement during building of the weir on aquatic life - states that the Draft EIS Chapter 12 (page 12-2) is incorrect and that the Ramsar boundary does extend above the proposed weir site and quotes section 1248 (page 12-12) Some wetland s up stream of the

weir [that are] still within the Ramsar boundary are expec ted to experienc e eleva ted wa ter levels Concerns - that the time required to fill the weir pool will be greater that stated in the EIS because swamps between Wellington and Mypolonga have subsided and the soils under the swamps have dried out these will take time to be re-wet

- that the weir will be difficult to complete (close) satisfactorily given the design and construction method and that it may be unstable as a result - that the scale of the proposed weir is much larger than the example quoted in the EIS of the blocking bank at Narrung Narrows which has already had problems that required attention including recent problems not included in the Draft EIS

PTW00044 Mr Ron Heyne The author supports a weir or a permanent lock at Pomanda Island and seawater incursion into the Lakes The author is concerned about other weirs at Finniss River Currency Creek and Clayton and pumping water from Lake Alexandrina into the Goolwa channel He understands this will deplete the Lake and expose more Acid Sulfate SoilsHe proposes a channel into Lake Albert from the Coorong

PTW00046 Mr Shaun Berg Lawyer Ngarrindjeri People

This is a lengthy detailed submission which addresses a variety of issues and makes 57 points about the Draft EIS The submission suggests that the Draft EIS for Pomanda Island be rejected and that the building of the proposed weir should be rejected on a number of grounds It is argued that the EIS has failed to take into account Ngarrindjeri views and that Ngarrindjeri Native Title Rights are affected Finally the submission appends the disclaimers in the Draft EIS and the Appendices to the Draft EIS and thereby points to a number of uncertainties in systems modelling (eg salinity wind) and efforts made by Government and consultants to reduce these uncertainties This submission supports those made by two other individuals Early in the submission the following points are made about the wishes of the Ngarrindjeri

1 natural solutions should be used rather than engineering solutions

2 solutions should consider the CLLMM region as an integrated whole

3 the CLLMM region needs to be maintained as a freshwater area

4 environmental flows to the system are needed to

Supplementary EIS for the temporary weir near Pomanda Island -164shy

Submission no

Submission from Submission Summary

maintain freshwater ecology 5 exposed lake beds should be remediated by

plantings or sand 6 cattle and other animals should be excluded from

these areas to minimize acid soil problems 7 hot spots of acid soils should be treated with lime or

sand Omission Table 4-3 is referred to in the text of the Draft EIS but is not supplied Points on matters of national environmental significance relating to the EIS At least 5 points relate to the EPBC Act - the Australian Painted Snipe should be considered in the EIS (with reasoning) - the EPBC protec ted matters searc h tool wa s used to generate the list of EPBC-listed species likely to be found in the region This result is indicative only has consultation with experts also occurred - the draft EIS does not include the Coorong or Lake Albert in relation to impact on Ramsar listed wetlands yet the Coorong and Lakes Alexandrina and Albert were listed together as a wetland of international

importance under the Ramsar Convention the three are related especially given that water is being pumped from Lake Alexandrina to Lake Albert - the potential impacts of weir operation and removal on

EPBC-related matters has not been not addressed Concerns - EIS process at least 6 points deal with EIS process for

example there is concern that the Draft EIS is not a stand-alone document as required (eg accompanying documents referred to in the Draft are not all available)

- Integration is needed at least 5 points deal with the need to consider this Draft EIS together with the environmental impacts of other current or planned interventions in the region (such as the introduction of seawater into the Lower Lakes)

- Over-allocation it is suggested that over-allocation of water is a major reason for the current crisis

- Technical concern is expressed that too little detail is provided about the construction of the weir

- Removal of the weir no consideration has been given to the removal of the weir if the Lower Lakes have been flooded with seawater This needs to be considered

- Alternative solutions 14 points deal with alternative solutions to the building of a weir it is argued that alternative solutions have not been described or considered in sufficient detail particularly the possibility that

combinations of alternatives may be an effective way to gain sufficient freshwater supplies

- Systems modelling concern is expressed that (a) the impacts are assessed only with an inflow of 896 GLyear to SA other scenarios with lower inflows need to be considered (b) salinity is only modelled for one year (c) impacts of the weir on water temperature

and turbidity are not addressed sufficiently - Soil chemistry risks associated with Acid Sulfate Soils

upstream of the weir and potential impact on the potability of water around pumping stations should be given greater attention there are several questions

Supplementary EIS for the temporary weir near Pomanda Island -165shy

Submission no

Submission from Submission Summary

about Acid Sulfate Soils for example what is the likelihood that the building of the weir itself will lead to a pH crash

- Management and mitigation a number of concerns are raised about what monitoring enforcement mitigation and review procedures will be applied

Suggestions - that the Draft EIS for Pomanda Island be rejected on the grounds that it does not comply with the Guidelines - that the SA Government take into account the changed use of the weir (from a means of securing water supply only to also acting as a barrier to ingress of saline or polluted water into the river) and then resubmit an EIS which covers this broader scope - that the Draft EIS fails to support the construction of a weir at Pomanda Island on the following grounds

1 The proposal does not consider alternatives sufficiently particularly combinations of alternatives

2 That the draft fails to distinguish adequately between impacts of the scenarios with and without the weir

3 There is a risk that the water quality in the weir pool may be poor because of algal blooms

4 There is insufficient attention given to the problem of Acid Sulfate Soils and measures taken elsewhere to solve this problem

5 The proposal should be integrated with other proposals eg the proposal to allow seawater into the Lower Lakes

6 The treatment of EPBC-listed species is superficial and lack plans for mitigation of negative impacts

- that the Draft EIS fails because it does not take into account views of the Ngarrindjeri - that Ngarrindjeri Native Title Rights are affected by the proposal and a number of points are made in relation to this claim

PTW00047

PTW00048

PTW00049

Mr Andrew Milazzo Executive Director TSD DTEI

This submission details the requirements for technical aspects of commissioning the weir according to DTEI regulations Examples are the inclusion and positioning of warning lights on the structure and signage The submission notes that there was no mention in the Draft EIS of the operation of the Narrung Ferry

Ms Jacqui Showell Suggests Adela id e s wa ter supp ly is the main d river for the weir Questions if enough alternatives are being investigated Concerned that decommissioning criteria will never be met Suggests ecological effects downstream will also occur upstream affecting the whole country Believes the system should be treated as a whole Suggests acid and heavy metals will affect regions and Ad ela id e s d rinking wa ter Concern for flora fauna (particularly southern bell frog Murray cod and migratory birds) and Ramsar obligations

Ms Cecily South Over-allocation and human activities need to be addressed The Eastern Mount Lofty Ranges flows into Lake Alexandrina mitigate ASS and heavy metals Further water savings are possible if households have allocations rather than timing restrictions There is water upstream get it Crops that cannot be sustained with irrigation should be

Supplementary EIS for the temporary weir near Pomanda Island -166shy

Submission

no Submission from Submission Summary

abandoned - change to sheep and cereals Reference to technical paper written by Brooks and South The barrages all lead but must be kept closed The SA Government and SA Water should stop pumping from Lake Alexandrina into Adelaide storages Landowners are losing 2-3 metres of lakefront pa The author is opposed to seawater incursions

PTW00050

PTW00051

PTW00052

PTW00053

Ms Ruth Beach Solicitor Environmental Defenders Office (SA) Inc

Points on matters of national environmental significance relating to the EIS

- this submission argues that the proposed weir will be permanent rather than temporary because the conditions for its removal are not likely to be met and that it will be physically very difficult to remove the weir as such the proposed weir should be assessed under the Development Act and the Draft EIS should take into account permanent effects on the environment in the CLLMM region including the Ramsar-listed wetlands and associated fauna and flora

- proposes that the construction of the weir is in contravention of legislation (State and Federal) and international conventions (Federal EPBC Act Water Act Murray-Darling Basin Act State Development Act River Murray Act Natural Resource Management Act Environment Protection Act)

- it is argued that the Draft EIS and proposed weir should be considered alongside other current and planned interventions in the CLLMM region

Concerns - that the EIS has not given sufficient consideration to

alternative sources of water - that other relevant Government reports are still in

preparation Ms Silver Moon Suggests EIS should and fails to be about the impact of an

action Suggests there is deficient understanding of the environmental processes and interactions in the Coorong and Lower Lakes Suggests climate change needs to be addressed Contributes considerable researchedreferenced information on various fauna and suggests they should be included as matters of NES Indicates the significant impact weir construction will have on wildlife and the system Suggests Australia has agreements it must abide by Suggests Chapter 15 is vague and lacking substance Suggests the weir does not meet principles of environmentally sustainable development and calls for action in addressing water allocation in the Eastern Mount Lofty Ranges including Finniss catchment

Mr Rex Hunter Confidential submission

Mr Tim Drew CEO The Coorong District Council

The Council points out - Tha t muc h of the CLLMM area is within the Counc il s boundary and details the population and main land uses - That the area is of particular significance to the Ngarrindjeri - That the Coorong and Lower Lakes were listed in 1985

as a wetland under the Ramsar Convention and that

Supplementary EIS for the temporary weir near Pomanda Island -167shy

Submission no

Submission from Submission Summary

a req uirement is to manage the a rea in a way tha t mainta ins [its] ec olog ic a l c harac ter

- That the Coorong and Lower Lakes are icon sites under the Living Murray Initiative - That as a response to the situation it has established the Lower Lakes and Coorong Infrastructure Committee (2007) - That it is opposed to the construction of the weir at Pomanda Island and any other new man-made structures in the River Murray

Points on matters of national environmental significance relating to the EIS

- the submission points out that there is a Ramsar wetland just upstream of the expected weir site at Pomanda Island and that this needs to be corrected in the Draft EIS - there is concern that there will be significant algal blooms after weir construction and that this will have a negative impact on native fish stocks

Concerns - that the present situation has been brought about by over-allocation of water resources across the MDB rather than by drought - the economic and social impacts of the situation (low water levels and flows) are very serious - that the weir will intervene in the natural river system and have a negative impact as a result - that the Draft EIS Chapter 26 includes the topic of maintenance of water levels for pumping purposes and that this was not included in the original referral to the Federal Government - that the modelling in Chapter 2 is in error because the forecast figures used for levels of L Alexandrina considerably understate the winter rainfalls of 2008 - that the modelling in Chapter 2 may be unreliable because it relies on estimates - that the triggers for removal of the proposed weir need to be more clearly defined and more realistic (the current conditions for removal are not likely to occur for another decade) - that there is a significant risk of blue-green algal blooms in the weir pool - that there is a risk of heavy metal release and acidic soils if the weir is built and potential impact on wildlife - that the weir will lead to the build-up of water with low oxygen concentration with risk to fish populations - that the significance of wind movement (wind seiche) is underestimated in the Draft EIS

PTW00054 Prof Diane Bell Committee Member River Lakes amp Coorong Action Group Inc

The Draft EIS should be rejected because it is inconsistent with the Guid elines for the Content of a Draft Environmental Impact Statement on the Proposed Temp ora ry Weir a t Pomand a Isla nd The p roposa l

- is not a stand-alone document - should properly be considered as part of a larger plan - lacks detail to support plans for construction operation and removal - has no staged and costed short mid and long-term plans for mitigation of NES - fails to investigate alternatives

The proposal will not achieve its stated goals because the

Supplementary EIS for the temporary weir near Pomanda Island -168shy

Submission no

Submission from Submission Summary

- triggers for removal are unrealistic - construction is problematic - water quality above the weir will be poor

The proposed action is likely to have significant impacts on internationally protected wetlands and species that the Federal and South Australian governments are obliged to protect The proposed weir is not the solution to the crisis in the Lower River Murray and Lakes The SA Government should be required to submit a Referral which takes all proposed actions into account and explores all options Part 1 the status of the EIS procedural points Summary It is their contention that the Draft EIS is significantly flawed and should be rejected by the Minister under Section 133 EPBC or alternatively the Minister should require that new Draft Guidelines ones that accurately reflect the situation and the needs of Adelaide for a secure water supply be prepared by the SA Government A number of points require further consideration

1 There is no longer a crisis of water security Minister Maywald has announced she has bought water for next year Acidification and increased salinity are now significant issues but were not when the Guidelines were published Given that both quantity and quality issues have changed the Guidelines should be varied or a new Referral written

2 Since the proposed temporary weir referral there have been a number of other proposals which impact on the quality of water (a weir rationale) The EIS is (therefore) flawed because it is not a stand-alone action and is in violation of the Guidelines

3 The author asserts that the triggers for removal cannot be achieved and there is no long-term plan that explains how they might be achieved

In other points the writer expresses a desire for access to related documents greater clarity and certainty less repetition in the draft EIS and for supplementary reports to be ava ilab le In a d d ition the EIS outlines c onsulta tion whic h has been inadequate ineffective and non-responsive to pub lic questions Part Two Chapter commentaries substantive questions The a uthor s summary sta tesThe EIS is tentative incomplete lacks detail and refers important matters to further supplementary reports and EIS The author states that the SA Government should be req uired to make d eta ils of the freshwa ter solution available as part of the EIS process She asks for a stronger d efenc e of the weir as the only feasib le op tion Referring to Richards she indicates that over-allocation and poor management continue on the Finniss and other tributaries today and asks who makes decisions about critical human needs and under what conditions On wetlands she states that the EIS cannot be considered competent and on seepage and run off the EIS does not give due consideration and states that the criteria for removal are unrealistic and unlikely to be met The Draft EIS displays little or no understanding of the imp ortanc e of c ultura l flows to the Nga rrind jeri

Supplementary EIS for the temporary weir near Pomanda Island -169shy

Submission no

Submission from Submission Summary

Chapter 2 comments as for submission by K McFarlane Chapter 3 comments this consists of pages 7 and 8 of the EDO submission which sets out reasons for non-approval of the Draft EIS under various legislative and regulatory processes Chapter 4 comments this is a combination of K Mc Farla ne s sub mission with a few c ha nges with the addition of the suggested Government freshwater purchase options (staged over three years) from C Ba g ley s submission Chapter 5 Proposed works to be undertaken The author contributes local knowledge about aspects of the Causeway which indicate that it is a dynamic area and that the development of the Causeway will create new flow patterns during floods Comments included

- there is no staged plan for the period of the weir pool filling to manage water issues and consequences below and above the weir - there is insufficient detail describing weir construction methods - insufficient is known about embankment materials and potential to pollute

Concern is expressed about - the amount of weir material which will sink or be washed downstream - the lack of an Environmental Management Plan - the lack of a fish passage - unrealistic weir decommissioning triggers and lack of detail in decommissioning planning

Relevant aspects of the submission by Liz Yelland are then included Chapter 6 comments replicate those submitted by Silver Moon in her submission Chapter 7 comments replicate those submitted by Silver Moon in her submission Also included is a portion of Anne Hartnetts submission (80409 page 5) The first section asserts Australias seemingly low honouring of Jamba Camba Kowamba and the Ramsar agreement and refers to the effect of the weir on migratory birds and the significance of weir placement at a meeting of waters Further Hartnett references (page 5) are made in relation to water levels and the need for spelling out of the effects of MAJOR interventions to remedy the result of these that

would be felt by all other biota Chapter 8 comments this is essentially taken from the submission by B Allnutt and T Giles with an additional comment expressing concern about the risk of habitat loss which in turn leads to species extinction Chapter 10 comments this section contains almost all of B Allnutt a nd T Giles submission (exc ep t for the summa ry of c omment for EIS p lus a paragrap h referring to C Bag ley s submission (questions about salt mobilization when sufficient ra in fa lls) two c omments from K Walker s sub mission (concerns about algal blooms upstream of the weir and acidification of wetlands upstream of the weir) and pages 3 to 5 of L Yella nd s sub mission a b out wind seic hing Chapter 11 comments this includ es N Shillabeer s submission one page (pa ge 4) of A Ha rtnett s submission (the effect of the weir on upstream water quality) and two

Supplementary EIS for the temporary weir near Pomanda Island -170shy

Submission no

Submission from Submission Summary

paragra p hs from S Ric ha rd s sub mission (wa ter qua lity) Chapter 13 The criteria for removal are unrealistic and unlikely to be met This underlines the lack of a long-term rec overy p lan and c asts d oub t on the tempora ry na ture of the weir Chapter 14 comments raise the absence of the Milang Snipe Sanctuary from the draft EIS Page 67 contains the list of birds also contributed by Silver Moons submission (Moon S un-numbered page re section 77 Summary) Commentary on Chapter 15 Environmental safeguards and mitigation measures raises

- Lack of fish passage - Diminution of freshwa ter hab ita t for two mentioned fish spec ies - c omment tha t a rg uements tha t the impac t of the weir c onstruc tion a nd opera tion a re minima l a re misguid ed and fa ils to rec ognise the p rob lem

Further Chapter 15 inclusion replicates in full questions raised by Liz Yelland (submission PTW 34 pages 1-2)

PTW00055 Mr Tim Milne Scientific Officer Nature Conservation Society of SA

Issue 1 Suggests the weir will exacerbate water level reduction and potential problems increasing need for remedial action Also suggests EIS does not address remedial action required Solution 1 examine the impacts of actions to increase water levels in the Lake as these are a direct consequence of weir construction and operation Issue 2 Risks to species associated with increased salinity and acidity Solution 2 EIS should examine impacts of accelarated incareases in salinity and acidity of the water Issue 3 Shortcomings in the environmenetal assessment of construction in Ramsar wetlands Solution 3 Full range of florafauna species need to be examined Issue 4 Lacking accurate information on period of operation and predictions of removal triggers Solution 4 EIS should assume the weir to be permanent to mitigate matters of NES in case this occurs

PTW00056 Ms Gillian Whiting Project Coordinator Murray-Darling Basin Authority

This submission is in the form of the letter addressed to the Director CLLMM Projects under the signature of the Chief Executive Rob Freeman Murray-Darling Basin Authority The letter notes that the proposed temporary weir must be assessed and approved under the Water Act 2007 (Cth) The MBDA requires more details than already provided in the EPBC Act referrals The MBDA asks for clarification and expansion of a range of issues - flow use control and quality of water The MBDA requires information and data relating to hydrology design flow assumptions water balance (inflows storage outflows) assumed water volumes design flood assumptions Hydraulics design details relating to flood surcharge and Water Quality flow cessation into Lake Alexandrina and seawater introduction and acidification thresholds The authority seeks additional information in order to make an Environmental Assessment on fish passage and disconnected wetlands below Lock 1 Weir plans must be submitted to the Authority for

Supplementary EIS for the temporary weir near Pomanda Island -171shy

Submission no

Submission from Submission Summary

consideration and approval Information is required about the capacity of the weir crest to resist erosion More detail is required in relation to weir removal in relation to definitions of normal time required to remove method of removal if a flood Other issues in relation to increased salinity in Lakes Alexandrina and Albert the effect of potentional increase in heavy metals and salinity and increased acid production It is anticipated that the Authority will require at least six weeks to undertake its approval processes

PTW00057 Mr David Winderlich Member of the Legislative Council Leader of the Australian Democrats

The author suggests that the cost of the weir be put into buying water bioremediation and assisting communities experiencing hardship due to low flows In his opinion the Lakes ecosystem and relevant matters of NES will not tolerate the impacts of the construction of the proposed weir The author advocates a natural freshwater system

PTW00058 Ms Kathryn Rothe Project Manager Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

Background this submission is on behalf of the Mannum to Wellington Local Action Committee and the Mypolonga Highland Land and Water Management Committee This submission relates in some aspects to the submission by Ruth Trigg Points on matters of national environmental significance relating to the EIS - lack of a fish passage across the weir is pointed out - concern about loss of important habitat Concerns - that the weir is only a bandage solution and that a strong integrated plan is needed that encompasses the environmental as well as social and economic survival of the Lower Murray and the CLLMM region - the submission does not support the construction of a weir and argues that alternative measures must be used especially the purchase of freshwater upstream for the CLLMM and Lower Murray region - that over-allocation of water is an important cause of current problems - that alternative water supplies have not been given sufficient consideration - that there have been and are many plans and reports about the situation but there does not seem to be a holistic or integrated plan - tha t g rowth in the Sta te s pop ula tion will put even more pressure on water and other resources - the allocation of water to different users needs to be reassessed by the MDBA in a holistic way and with food production as a priority - that the weir will be unstable Suggestions - that freshwater be brought downstream to SA where evaporation rates are much less than at the Menindee Lakes - that bioremediation of Acid Sulfate Soils is already occurring - that the new MDBA should start emergency actions in the region as soon as possible - that alternative sources of water and water conservation and re-use measures be put in place The author points out that the task of preparing this

Supplementary EIS for the temporary weir near Pomanda Island -172shy

Submission no

Submission from Submission Summary

submission was daunting and that it took a lot of time effort and community spirit to prepare This submission endorses the submissions of approx 18 other individuals and groups

PTW00059 Ms Karyn Bradford The writer highlights long connection with the CLLMM extensive knowledge and a long list of achievements in the region The submission contains additional references The writer is concerned that there has been a lack of effective public consultation and that government ministers and their employees chose to dismiss the knowledge skills and expertise freely offered by members of the community many of whom have intimate and generational knowledge of the Lakes and Coorong environment EIS coverage The writer believes that the EIS should be rewritten to include all proposed action for the CLLMM region Language used EIS la nguage is c ritic ised a s [c asting] d oub t on the qua lity and veracity of the informa tion p rovid ed and a s having very few d efinitive sta tements

Seiching A very strong possibility that un-potable water could travel down the river and be trapped behind the weir is identified as a flow on effect of interruption of wind seiching Fish passage The lac k of a llowa nc e for a fish passage is sta ted as not meet(ing) one of the three key ecological objectives of the Murray-Daring Basin Commission Environmental Management Plan 2007-2007 for the CLLMM Icon Site River and Lakes system complexity not understood The writer states that the EIS shows that the proponent does not understand the complexity of the interactions between the River Murray Lakes Alexandrina and Albert its tributaries and the Coorong Ramsar principles breached The author submits that the Ramsar wise use tenet and the precautionary principle are breached by the weir at a time when over-allocation and drought have already done c onsid erab le ha rm to the environment The writer endorses submissions of other named persons A table is used to identify and address issues applicable to specific sections of the EIS including - Executive Summary Purpose

Questions whether full information is available No discussion of bad water coming down Murray Seawater option outside this EIS Alternatives to EIS proposal named

- Executive Summary Introduction Possibility that weir will contribute to algal growth if mixing is impeded

- The original referral Lack of fish passage contradicts Murray-Darling 2007shy2007 Management Plan objectives

- Draft EIS section 737 References to Angus and Bremer Rivers are omitted d esp ite signific a nt b iod iversity va lues partic ula rly a t their c onfluenc e with La ke Alexa nd rina

- Draft EIS section 7-5 Why were only 9 of the 68 listed threatened species discussed in detail

Supplementary EIS for the temporary weir near Pomanda Island -173shy

Submission no

Submission from Submission Summary

Short and Long necked turtles and the Japanese Snipe are of particular interest to local people

- Appendix 15 Raises concern with levels of confidence in 64Confidence in impact assessment Suggests that further information is required

- Selections from the EIS The uncertainty expressed by the use of qualifiers in the EIS language is raised as a concern Question Is there enough evidenc e for this p rop osa l to proceed without further study of all aspects of the p roposa l

- Section 121 A sta tement is mad e tha t the weir will not may interact with the ecological values of the Lower River and Lakes

- Section 141 An attachment provides a record of migratory birds sighted in the area The definition of regularly sighted birds in the EPBC Act is questioned and a Web address supplied at which a local record of birds sighted is kept httpwwwmilangorgauMilanghtm

PTW00060 Mr Mike South Attachment Brooks B amp South M Discussion Paper 19 August 2008 Applying a localised water balance approach to estimate losses from Lake Alexandrina and Lake Albert for the years 1970 to 2006 The author suggests that the models used for the virtual weir should be used with caution and a range of further scenarios need to be modelled A clarification is offered in relation to weir pool levels and pumping SA Water pumps can access water at minus 30m therefore there is no need to maintain levels at +1m AHD The a uthor d isc usses in d eta il sec tion 452 Red uc ing Evapora tive losses of the d ra ft EIS and d isputes the statement that 70 of evaporative losses occur in the Lower Lakes He concludes that long-term evaporation for the Lower Lakes is an over estimate and that the apportionment of losses inappropriately biases the Lakes

PTW00061 Mr Jonathan McPhail Inland Fisheries Management Officer PIRSA Fisheries

The proposed weir will increase pressure on fish stocks and fish habitats which will have significant environmental impact on commercial and recreational fishing Habitat above the weir water will be more stable than currently The changed flow regime will better support European carp and negatively impact on spawning recruitment and migration of Murray cod Murray hardyhead and Yarrra pygmy perch This will work contrary to the MDBC Native Fish Strategy Water quality Removing saline water above the weir will d iminish na tive fishes c omp etitive a d vantage Potentia l decreases in salinity and increases in nutrients and sedimentation will also favour European carp and Mosquito fish and potentially increase the threat of blue-green algae blooms A fish passage is required to support migration of species upstream and downstream and to support upstream fish movements as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline

Supplementary EIS for the temporary weir near Pomanda Island -174shy

Submission no

Submission from Submission Summary

In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river The proposed temporary weir will have severe negative impacts on the available fish habitat and water quality and affect the environmental sustainability of commercial fishing

PTW00062 Mr Glenn Williams Natural Heritage Manager Natural Heritage Trust

The writer has 4 areas of key concern with the EIS 1 Failure to take an ecosystem approach

- The imp a c t of adding a further 5200 hectares to the tens of thousands of hectares of fringing reed-bed habitat that have already dried out and degraded along with their micro and macro invertebrate populations has been stated but not properly assessed in the EIS

- The EIS tends to b e qua lita tive ra ther tha n quantitative both of the proposed weir construction and the altered water regimes across ecosystems A clearer quantitative estimate of potential impacts upon na tive vegeta tion is need ed An example is given relating to impact of rock acquisition on native vegetation

- The writer states that the impact on wetland vegetation and (specifically) samphire plant communities should be quantified more accurately

- The writer is concerned that the EIS does not address over-allocation of water and states that no water allocation has been made for the Ramsar site Irrigation and upstream allocations are referred to

- It is asserted that the weir will withhold even more flow including 350MLday to flush out salt emanating from upstream water-using activities

- EIS is considered to give insufficient attention to the potential implications for the Coorong and the hydrological links between the Lower Lakes the Goolwa Channel and the Coorong particulalry during the period of filling the weir

- The writer believes that the Draft EIS lacks context and overview of the range of other feasible actions that might have been taken as well as those needed with the construction of the temporary weir

2 Failure to seriously examine pursue and commit to fund ing other rea sona b le a nd p rud ent a lterna tives

- The writer argues that human needs have been given priority with minimising of environmental impact being a secondary objective

- The writer asserts perceived lack of action by the state government to decrease reliance on Murray giving examples of water allocation from the Murray to the Clare Valley the BILL scheme Port Lincoln and a Port Hughes golf course

- The writer sta tes tha t the p roponent s EIS ob liga tion to exa mine p rud ent a nd fea sib le a lterna tives has

not been fulfilled by the failure to seriously address - Harvesting of stormwater and more substantial flows

from the short west-flowing creeks of the Mt Lofty Ranges

- Promoting water tanks - Increasing Adelaides water restrictions - Pricing water more competitively particularly for

Supplementary EIS for the temporary weir near Pomanda Island -175shy

Submission

no Submission from Submission Summary

industry and irrigation - The writer considers that the movement of the

pumping stations to above Lock One is a better alternative to the weir

3 Failure to adequately address impacts on EPBC Act-listed fish and frog species

- The writer sta tes tha t the EIS ignores c ond itions below the weir and only concentrates on higher water levels above the weir

- The writer notes that there is no commitment to building a fishway to address the impact on Murray hardyhead and Murray cod caused by disconnectivity between the Lake and River and further sta tes tha t the EIS seems to g loss over the very serious impacts that the iconic Murray cod will suffer from reduced water levels and wa ter qua lity

4 Failure to address geotechnical structural problems with the weir

- Refer section 55 and Executive Summary and Appendix 6

Specific issues raised refer to - poor foundation conditions except for the eastern

half of Getochnical model 1 - low sheer strength indicating slope instability - continuing movement and settling of clays - seepage and possible development of piping - impact of earthquakes on foundation sands

Other concerns addressed in short are - The temporary weir being left in place for a longer

period - writer s rec ommend a tion tha t a c tive-adaptive

processses be adopted for bio remediation of Acid Sulfate Soils and a need to clearly identify the indigenous plants to be used

- lack of information on impacts of temperature changes in the Lakes water column

- failure to address the oxygenation of the River water through wind seiching

PTW00063

PTW00064

Ms Beryl Belford Writer supports a one river and whole of basin approach to ecological management of the River and Lower Lakes The writer believes that - water is available in the basin to save the River system - the federal government must take responsibility for equitable distribution of water - state government should regulate water held in stock and domestic dams in Eastern Mt Lofty ranges to ensure environmental flows to the Lower Lakes

Ms Elizabeth Hobbs Points on matters of national environmental significance relating to the EIS - the author is alarmed that the potential impacts of the weir on the Coorong are referred to so little - states that the list of endangered species in the EIS is too narrow and argues that as both species and habitats are interconnected they should not be split up for the purpose of the EIS - emphasizes the need to have healthy waterways in the region due to its ecological importance Concerns - the author is concerned at the cost of the weir and other interventions in the CLLMM region and quotes from other

Supplementary EIS for the temporary weir near Pomanda Island -176shy

Submission no

Submission from Submission Summary

submissions on this point - from first hand experience at seeing sediment build up due to low water flows the author is concerned that this will occur at the weir site and there will be an impact of this silting up - that the weir is a technical solution for problems that should be solved by other means - that the proposed weir needs to be considered as part of the larger set of interventions occurring and being planned in the CLLMM region - that over-allocation of water rather than drought is the reason for major problems occurring Suggestions - the author proposes that there are alternative measures that should be put in place and expanded to reduce Ad ela id e s relia nc e on wa ter form the River Murray - an interconnected systems solution needs to be developed to protect the area listed under the Ramsar agreement

PTW00065 Dr Talina Vizard The writer questions Can local springs be channelled into the river (eg from Victor Harbor) Would redirecting storm water into the system help Have views of Ngarrindjeri been considered Can the use of bore water be policed and how can farmers be educated to the effect of taking water from the c ommon store

Writer Comments Time for comment too short Writer supports the submissions of Liz Yelland (PTW00034)

PTW00066 Ms Carlsa Carter The author states that the South Australian Government ignores the serious environmental condition of the Coorong and Lower Lakes and withholds minimum environmental flows The author states that there is a lack of thorough information about EPBC-listed species and species of the freshwater ecosystem and states that the loss of reed beds and habitat during the period of weir construction is trivialised Attention is drawn to a bird survey by Dr Kingsford of Newcastle University (2009) which shows greatly reduced numbers of water and wading birds over a short period

PTW00067 Ms Julie Pettett CEO Conservation Council of South Australia

The CCSA opposes the construction of a weir near Pomanda Island while accepting that the provision of drinking water is critical CCSA states that the impact of the weir will have unacceptable impacts on several matters of NES and the idea that the weir will be temporary is strongly contested CCSA argues that the EIS is seriously deficient and that the EIS for the proposed temporary weir should be reshyconsidered in conjunction with a referral EIS and public consultation about the introduction of seawater into the Coorong and Lower Lakes The CCSA is concerned about the impacts of a weir on Southern bell frogs Murray cod Murray hardyhead and Yarra pygmy perch and may be able to provide a supplement to the submission about these concerns at a later date CCSA states that the construction of a weir will destroy and degrade more than a hectare of Ramsar wetlands flora

Supplementary EIS for the temporary weir near Pomanda Island -177shy

Submission no

Submission from Submission Summary

and reed beds and have consequent impacts on listed threatened species and migratory fauna Construction of a weir is likely to contaminate the Lake and impact on Ramsar wetlands threatened species ecological communities and migratory species Triggers for removal are discussed CCSA states that the weir will exacerbate acidification of the Lower Lakes and thus the weir will need to be permanent In addition CCSA states the Hume and the Dartmouth storages have not been at normal operating levels for ten years and achieving the prescribed salinity level is unrealistic These factors suggest a permanent weir CCSA believes more consideration needs to be given to the Federal government purchasing water and structural adjustments under the Water for the Future Program Stormwater harvesting aquifer storage and recharge and wastewater re-use would be less environmentally harmful options than a weir

PTW00068 Ms Paula Horbelt Secretary Goolwa District Ratepayers amp Residents Association Inc

This submission urges the State Government to consider water alternatives as Salisbury Council has done It is suggested that Cheltenham could be similarly used as a water capture site The Association encourages rainwater tank policy but questions the energy intensity costs of desalination The Association is concerned that a weir will increase salinity levels in Lake Alexandrina and that Ramsar sites of significance will not be protected The Association understands that water quality between Lock One and a weir at Pomanda island would inevitably deteriorate due to inadequate wind seiching In conclusion the submission states We support the purchase of water rather than weirs temporary or otherwise

PTW00069 Mr Keith Scobe The writer is a member of the Ramsar Taskforce His submission expresses a preference for securing water from upstream He refers to submergable floating booms as a method managing water (instead of a weir) He expresses uncertainty about the no flow period over the weir and expects weir construction costs will escalate He expresses hope that the MDBA will manage the Murray Darling Basin well in future

PTW00070 Ms Ruth Russell The writer is opposed to the construction of a weir and argues for a sustainable freshwater long-term management plan for the Murray-Darling Basin overall The author contributes to Adelaide University Frog Census work and has engaged with CLLMM issues in the region She urges a well researched long-term freshwater solution so that there is a postive outcome for future generations The writer urges - better use of a range of water alternatives - accessing water from the temporary water market through the Water for the Future Program - adoption of the precautionary principle - rejection of this EIS in favour of a more holistic and systematic EIS acknowledging complexity and interdependency The writer understands that the weir will be destructive of nationally listed species and suggests a fish passage should be included She fears algal blooms due to ineffective wind seiching as well as acid soils impacts on water qulaity The

Supplementary EIS for the temporary weir near Pomanda Island -178shy

Submission Summary

writer also fears that the weir will not be temporary PTW00071 Mr Ken Jury and

Mr Mike Young The authors are critical of the unrealistic timeline for consultation They propose a permanent weir which prevents loss of freshwater above and allows an esturine environment in the Lakes below This environment would support wader birds and improve tidal access to the north CoorongThe River Lower Lakes and Coorong must now be regarded as a human-altered environment and managed to suitThe authors argue that it is important not to allow the mobilisation of acid from soils into water as this will corrode the barrages They believe the only option is to inundate the Lakes with seawater and query the freshwater science presented A diversion pipeline is suggested from Morgan and questions are raised about loss of River water into aquifers

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -179shy

Government of South Australia

  • Table of Contents
  • Part Two - Community Consultation Report ndash Appendices
Page 4: Supplementary Environmental Impact Statement

Proponent s details

South Australian Government represented by

Name Peter Croft

Title Director Coorong Lower Lakes and Murray Mouth Projects

Department Department for Environment and Heritage

Address GPO Box 1047 ADELAIDE SA 5001

Proponent s environmental record

The South Australian Department for Environment and Heritage (DEH) is responsible for South Australias nature conservation heritage conservation and animal welfare

DEH collects and provides information and knowledge about the states environment

DEH manages the states public land including national parks marine parks botanic gardens and the coastline

DEH also advises on environmental policy

DEH is part of the Environment and Conservation Portfolio and reports to the South Australian Minister for Environment and Conservation DEH delivers the Governments environment policies d irectly and through partnerships These are with other government agencies including the Department of Water Land and Biodiversity Conservation (DWLBC) the Environment Protection Authority (EPA) Zero Waste SA Natural Resources Management Boards and Primary Industries and Resources SA as well as a wide range of non-government environment organisations industry bodies and the community

DEH s work is determined by its ob liga tion to ac hieve rela ted ta rgets in South Austra lia s Strategic Plan to administer legislation dedicated to the Minister for Environment and Conservation and to respond to the needs of South Australians

Table of Contents

PART ONE SUPPLEMENT TO THE DRAFT EIS 1

1 Introduction to the Supplementary Environmental Impact Statement (EIS) 2

Overview of Supplementary EIS structure 2 Purpose 2 DEWHA issues 2

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region 3

Submissions received and responses 3

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir 5

Submissions received and responses 5 Murray-Darling Basin Authority submission 5 The time required to remove the temporary weir 5 Floods 5 Phytophthora at the temporary weir construction site 6 Weir Causeway 7 Weir Site 7 Weir Construction and Environmental Management Plans 7 Weir Materials 8 Weir Crest 8 Pumping 8 Permanent Weir 8 Triggers for Removal 9 Salinity measuring locations 10 Decommissioning 11 Modelling 11 Virtual Weir 13

4 Supplementary comment on expected impacts of the temporary weir on soils and water 14

Introduction 14 Submissions received and responses 14 Acid Sulfate Soils (ASS) 14 Water quality 16 Wind seiche 16 Impacts upon Coorong and Lake Albert 17 Dredging of Murray Mouth 18 Water quality impacts near Narrung Narrows 18 Algal blooms 20 Summary of water quality impacts 21 Connectivity of Surface and Ground Waters 22 Surface Waters 22 Groundwater 23

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels 24

Introduction 24 Upstream impacts 24 Impacts of altered water regime in weir pool 24 Impacts to Pelican Lagoon and Nalpa Station 25

Weir Footp rint Impac ts 25 Impacts of Habitat LossDegradation 25 Impacts upon fish migration 26 Impacts of noise upon wetland birds 27 Monitoring during constructiondecommissioning 27 Timing of construction and presence of migratory species 28 Downstream impacts 28 Impacts of water level changes upon aquatic vegetation 28 Impacts of temporary increase in salinity upon aquatic biota 28 Impacts upon tributary wetlands 31 Impacts upon the Milang Snipe sanctuary 31 Impacts upon primary determinants of ecological character 32 Impact upon keystone species 32 Impact upon habitat availability 32 Impact upon salinity 33 Impact upon turbidity and sedimentation patterns 33 Impact upon water levels 33 Impact upon water regime 33 Impacts upon migratory shorebirds 34 Impacts upon Australian Painted Snipe 34 Impacts upon Orange-bellied Parrot 34 Impacts upon Great Egret Cattle Egret and Caspian Tern 35 Impacts upon pelagic birds 35 Impacts upon bush birds 35 Impacts upon Mt Lofty Ranges Southern Emu Wren 36 Impacts upon White-bellied Sea Eagle 36 Issues of scope adequacy and definition 36 Adequacy of species and communities examined 36 Current status of waterbirds 37 Adequacy of EPBC Act threatened species and communities lists 37 Adequacy of discussion of EPBC Act-listed species 37 Omitted flora and fauna records 37 Definition of keystone spec ies 38 Spec ies c onsidered of partic ula r signific anc e 38 Adequacy of description of different wetland types 38 Regional importance of the Coorong Lower Lakes and Murray Mouth 38

6 Notes on significant issues outside the scope of the draft EIS For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities 39

Ngarrindjeri People 39 Social and economic issues 39 Climate change 40 Dust and health 40 Other themes 40

7 Suggested text changes errata additions clarifications and references 41

References 53

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA) 54

General comments 54 Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth 54 More specific comments 61 Water supply 68 Removal triggers (pg 1-6) 70 Wetlands 72 Re-wetting of upstream wetlands 75 Threatened and migratory species 77 Fishway 81

PART TWO COMMUNITY CONSULTATION REPORT 85

1 Introduction 86

2 Community Information Sessions 86

3 Targeted Meetings 89

4 Overview of media articles (see Appendix VII) 89

5 Receiving submissions and developing the Supplementary EIS 90

PART TWO COMMUNITY CONSULTATION REPORT - APPENDICES 93

Appendix I - Submissions received Individuals 94

Appendix II - Submissions received Organisations 96

Appendix III - Participants and notes from Targeted Meeting Sessions 97

Appendix IV - Organisations that participated in Community Information Sessions 109

Appendix V - Participants and notes from Community Information Sessions 110

Appendix VI - Advertising copy used in the consultation process 127

Appendix VII - Media generated by the consultation process 146

Appendix VIII -Summary information of enquiries and submissions for provision of the proposed temporary weir 148

Appendix IX - Table of submissions 149

Executive Summary

The purpose of this Supplementary Environmental Impact Statement (EIS) for the temporary weir near Pomanda Island is to address Issues of National Environmental Significance (NES) (as defined in the Environmental Protection and Biodiversity Conservation Act 1999) arising from written public submissions and government comment during the period of public consultation for the Draft EIS

Part One is the Supplement to the Draft EIS provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report provides an overview and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Part One of the Supplementary EIS is divided into 6 key sections

Section 1 contains an overview of the document

Section 2 considers the role of the temporary weir within the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth Region These comments are made in response to a number of submissions that suggested that the temporary weir was being considered in isolation

The sec tion outlines the Government s multi-faceted strategy to combat the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region

This strategy includes both long and short-term plans including worst-case scenario measures that would only be implemented as an option of last resort should a fresh-water solution not be found

Section 3 considers submissions relating principally to Chapter 5 of the Draft EIS Proposed Works to be Undertaken

The Murray-Darling Basin Authority (MDBA) submission outlined the approvals necessary under the Commonwealth Water Act 2007 and in particular under clause 49 50 and 63 of the Murray-Darling Basin Agreement

The South Australian Government submitted a detailed application to the MDBA on 15 May 2009

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process however the Authority sought details on the method of removal of the temporary weir in the event of a flood coming down the River

As the flood scenario was not discussed in the draft EIS it is addressed in the section 3 of the supplementary EIS

Any flood moving down the River is most likely to have originated in the upper reaches of the river system and can take up to six weeks to reach the temporary weir location During this time an assessment will be possible as to the appropriate method of management of the temporary weir structure

A significant cluster of submissions were made regarding triggers for removal or decommissioning of the temporary weir

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria stated in the Draft EIS remain appropriate

Other submissions considered in Section 3 relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the proposed temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir A number of submissions also raised concerns about modelling

By way of response section 3 outlines the environmental management framework for the temporary weir including an Environmental Management Plan which ensures management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Section 4 provides an overview of submissions relating to expected impacts of the temporary weir on soils and water

A number of submissions raised concerns regarding acid acidity and Acid Sulfate Soils (ASS) These submissions support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible

ASS field investigations and modelling will enable key information gaps to be addressed and be fed back into the ongoing planning and measures undertaken

Wind seiche and its impact on water quality also formed the basis of several submissions as did possible increases in algal blooms within the weir pool itself

While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes

Some submissions sought clarification regarding the interaction between surface and ground waters

Section 5 Submissions discussed in Section 5 relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

A process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Another issue of concern raised in many submissions is the potential impact of increased salinity within the Lower Lakes upon aquatic biota By way of response Section 5 adds considerable detail regarding predicted salinity changes and the likely biotic response

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Section 6 briefly overviews issues raised in submissions which lie outside the scope of the Supplementary EIS In some cases ideas were contributed which are worthy of note

There is a suggestion about the importance of consulting with and recognising the Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

Another submission argues for having more than one scenario when drafting the EIS (not only d rought but a lso c limate c hange) and another c ontextua lised the c urrent p red ic ament of

the Coorong Lower Lakes and Murray Mouth in ideologies about unsustainable growth

A number of submissions outlined the current social and economic conditions of the Coorong Lower Lakes and Murray Mouth region indicating that there is considerable social and economic suffering attributable to drought and over-allocation of River water

Many submissions expressed discontent with over allocation of water resources and a significant majority expressed opposition to the temporary weir A minority supported the temporary weir and some indicated a preference for seawater flooding of the Lower Lakes (rather than a limited incursion)

There was almost no comment about water security issues for Adelaide and the majority of South Australian country towns

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part OnE Supplement to the Draft EIS

1

1 Introduction to the Supplementary Environmental Impact Statement (EIS)

Overview of Supplementary EIS structure

Rather than replacing the Draft Environmental Impact Statement (EIS) this Supplementary EIS d iscusses those issues raised in submissions Thus most of the tables and figures from the Draft EIS are not repeated Section 7 of the Supplementary EIS lists a range of text changes (corrections deletions additions and minor clarifications)

Note This Supplementary EIS needs to be read in conjunction with the Draft EIS for the proposed temporary weir near Pomanda Island There is no re-written version of the Draft EIS

Purpose

The purpose of this Supplementary EIS for the temporary weir near Pomanda Island is to address issues relating to Matters of National Environmental Significance (NES) that are within the scope of the guidelines arising from written submissions lodged during the period of public consultation for the Draft EIS

DEWHA issues

The Commonwealth Department of the Environment Water Heritage and the Arts (DEWHA) raised a number of issues with the South Australian Department for Environment and Heritage (DEH) Many of these issues are pertinent to the Supplementary EIS and a copy of the response to these issues is provided in Appendix 1

Supplementary EIS for the temporary weir near Pomanda Island -2shy

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region

Submissions received and responses

A number of submissions suggested that the temporary weir was being considered in isolation and several suggested that there should be one encompassing environmental impact statement for actions being considered in the Coorong Lower Lakes and Murray Mouth (CLLMM)

The scale and complexity of the problems associated with lack of inflows to South Australia suggests that there must be a well coordinated set of solutions The South Australian Government has developed a multi-faceted strategy in response to the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region This involves development of a short-term strategy to protect the quality and access of major public water supplies to protect the local and regional environment from irreversible damage and to minimise adverse impacts on infrastructure and the regional community It also involves the development of a long-term management p lan Refer to tab le Summary of SA Government Projec ts in the Lower Lakes Coorong and Murray Mouth in Append ix 1 Question 3

Water security involves water quantity and quality to ensure a potable water supply to Adelaide and Regional South Australia The drought and anthropogenic1 uses have drastically reduced inflows to South Australia and water levels have dropped below Lock 1 (near Blanchetown) increasing salinity and exposing Acid Sulfate Soils (ASS) in the Lower Lakes The oxidation of ASS upon drying can result in acidic water and mobilised metals some of which are toxic to humans above certain concentrations The temporary weir aims to ensure adequate weir pool level for operation of the pumps supplying water to Adelaide and regional South Australia in addition to presenting a physical barrier to acidic andor saline water migrating upstream towards the pump stations from the Lower Lakes

The temporary weir is not considered the only solution to issues in this region The South Australian Government is writing a long-term p lan the initia l version entitled The Coorong Lower Lakes and Murray Mouth Directions for a healthy future This was released for pub lic comment during May 2009 Following a period of public consultation community feedback and with scientific input the final version of the long-term plan will be completed in October 2009 and submitted to the Australian Minister for the Environment Heritage and the Arts (MEHA) as required under the Murray Futures Funding Deed

In addition to the long-term plan the South Australian Government has had to take a number of emergency measures which while separate in their own right form part of a strategy of inter-connected short-term actions

The South Australian Government has referred five proposals to the MEHA for consideration under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) These are

A referral to establish a temporary weir near Pomanda Island (EPBC 20073484) which was determined to be a controlled action in July 2007 (the subject of this EIS process) The South Australian Government has stated that this temporary weir would only be constructed as a last resort and that the Government is continuing to pursue options for a freshwater solution The weir if approved and constructed would be a temporary weir aiming to protect the water supply of Adelaide and many country towns The draft EIS was released for public comment on 12 March 2009 This Supplementary EIS is prepared in response to public submissions that closed on 9 April 2009

A referral to upgrade the Pomanda Peninsula causeway to allow access to the temporary weir embankment site on Pomanda Island (EPBC 20084674) was referred to the MEHA on 23 December 2008 The Minister decided on 23 January 2009 that this p roposa l was not a c ontrolled ac tion

1 of relating to or resulting from the influence of human beings on nature

Supplementary EIS for the temporary weir near Pomanda Island -3shy

A referral to open the barrages that separate the Lower Lakes from the Coorong (EPBC 20084618) as a last resort should this prove necessary The aim of this proposal is to allow the controlled entry of a limited amount of seawater to maintain the water level in the Lower Lakes above the critical trigger level of acidification The proposal has been deemed a controlled action The final guidelines for the Content of a Draft Environmental Impact Statement were released on Friday 13 March 2009 (Note that The Murray-Darling Basin Ministerial Council approved a Real time management strategy to avoid acidification in the Lower Lakes (November 2008) involving the introduction of seawater through the Barrages when certain trigger points are reached The Council recognised the threat of acidification and approved this strategy essentially as a last resort)

A referral to construct a below ground pipeline that is capable of delivering 30 GL annually from the River Murray (at Jervois) to the Langhorne Creek and Currency Creek landowners was submitted on 18 February 2009 (EPBC 20094743) The pipeline will deliver irrigation water to communities and industries in the region that are currently reliant on the Lower Lakes for their water supplies This was assessed as not being a controlled action if undertaken in a particular manner and completion is scheduled for late 2009

An emergency first response referral to mitigate the multiple adverse impacts of Acid Sulfate Soil exposure in the Goolwa channel and its tributaries (Finniss River and Currency Creek) was submitted on 6 April 2009 (EPBC Reference No 20094833) This involves the construction (1) a temporary environmental flow regulator within the Goolwa Channel near Clayton (2) a temporary low-level regulator in the mouth of the Finniss River (3) a temporary low-level regulator in the mouth of Currency Creek The referral also involves pumping water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel This was assessed as not being a controlled action if undertaken in a particular manner

If more fresh water could be secured to flow into South Australia and Acid Sulfate Soil managed to mitigate impacts on water quality then the temporary weir would not be needed

Supplementary EIS for the temporary weir near Pomanda Island -4shy

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir

Submissions received and responses

Submissions discussed in this section generally relate to the content contained in the Draft EIS Chapter 5 titled Proposed Works to be Undertaken The major sections of that Chapter include weir location design parameters and time constraints construction environmental constraints and site selection alternative design options operation decommissioning and removal

Written comment received on Chapter 5 from the public and government agency respondents raised a wide range of issues A gap relating to the temporary weir and the effect of flood was identified and there was a significant cluster of submissions related to triggers for removal or decommissioning the temporary weir

Other submissions relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir

Murray-Darling Basin Authority submission

A submission from the Murray-Darling Basin Authority (MDBA) stated that approval for the construction of the temporary weir was required under clause 49 50 and 63 of the Murray-Darling Basin Agreement and detailed exactly what was required as part of the approval process The South Australian Government subsequently wrote to MDBA (15 May 2009) seeking approval for the construction of the temporary weir

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process However many of the details requested are relevant to the temporary weir

The MDBA sought details on

Quantifiable triggers for removal

The time required to remove the temporary weir

The method of removal if a flood is travelling down the river when the level of Lake Alexandrina is low

The effect of increased salinity levels

The effect of the potential increase in heavy metals and

The effect of an increased sediment rate of acid production around Pomanda Island

On 30 June 2009 the MDBA approved plans for the proposed weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

The time required to remove the temporary weir

Refer to discussion on floods below

Floods

The MDBA submission has requested information about the removal of a temporary weir during a flood

Response

Given the exceptionally low storage levels in the Murray-Darling Basin system it would take considerable rain over a prolonged period of time and throughout a significant proportion of the Basin to generate a flood of sufficient flow resulting in all the decommissioning triggers

Supplementary EIS for the temporary weir near Pomanda Island -5shy

specified in section 58 the draft EIS being met Should a flood event signal the achievement of the weir decommissioning triggers the decommissioning and removal would only proceed after the flood has passed

Nevertheless advice has been sought from relevant authorities regarding both the specific level of rainfall necessary to create flood conditions in the Murray-Darling Basin catchments and the lead time available to remove the temporary weir in the unlikely event of a flood

Any significant flood moving down the river is most likely to have originated in the upper reaches of the river system and therefore can be expected to take up to six weeks to reach the location of the temporary weir During this time an assessment will be possible as to the appropriate method of management of the structure of the temporary weir

The temporary weir contains a spillway which is designed to pass 15 GL a day with a minimal rise in the upper weir pool level This flow rate was given by the MDBA as a nominal upper flow limit for normal river management and represents a 15 fold increase from the current flow past Wellington of approximate 1 GL per day A design for higher flood events was not included in the draft EIS due to the expected very low probability of occurrence plus the expectation that if flood event were occurring then the river system would have recovered and the temporary weir would not be required

The impact of flood flows over the temporary weir are being reviewed and initial indications are that flows much greater than 50GL per day could be passed without the upper weir pool level rising above the normal full supply level (FSL) of 075m AHD

In the unlikely event of a significant flood two reactions are available Firstly the flood could be allowed to pass over the temporary weir or secondly a breach in the temporary weir could be made to assist passage of the additional flow

The choice of the best option depends on the flood flow size the water level in Lake Alexander and the degree to which it could be flushed by the flood and the likelihood that the temporary weir will still be required after the flood (ie whether the conditions for weir removal have been met)

If the temporary weir is required after the flood then breaching the weir is unlikely to be a preferred option If the flood is allowed to pass over the temporary weir the likelihood of significant damage will depend on both the size of the flood flow and the downstream water level It is expected that flood damage should be low due to the width of the spillway (This is still to be confirmed by additional design analysis)

In a worst case situation a sufficiently large breach in the temporary weir could be done in the available time The method of removal remains the same however the work method will need to control all risks associated with different upstream and downstream water levels that may exist

The South Australian Government will work with the MDBA to develop a weir flood management plan Given the current exceptionally low water levels throughout the Murray-Darling Basin system it would take considerable rain over a prolonged period and over a significant proportion of the Basin to generate a flood of sufficient flow to require removal of the temporary weir The low water levels in storages and the River system also provide the opportunity to regulate a large percentage of high flows

Phytophthora at the temporary weir construction site

One submission claimed that impacts of weeds and pests such as Phytophthora cinnamomi were omitted and that therefore the weir construction could potentially have a significant environmental impact

Response

The Draft EIS (chapter 15) provides details on the environmental management framework for the temporary weir including Environmental Management Plan (EMP) to ensure management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Supplementary EIS for the temporary weir near Pomanda Island -6shy

Once a contractor has been selected the contractor is expected to manage the temporary weir project in accordance with best practice mitigation measures to effectively reduce the environmental risks and avoid adverse impacts associated with site level impacts during the construction operation and decommissioning of the temporary weir

It is recognised that weeds and pests if not managed appropriately can present a long-term threat and impact on the native plant communities in the area

Consequently weed and pest management in general and the specific management of Phytophthora a re a c ritic a l element of the c ontrac tor s Environmenta l Management Plan (EMP) Selection criteria for contractors also include specific environmental compliance and best practice evidence

As part of this project detailed weed assessments will be conducted as part of the risk assessment in the Construction Environmental Management Plan (CEMP) via desktop studies (especially for Phytophthora) weed surveys and expert advice Project-specific mitigation measures are then included in the EMP and a specific (during and post-construction) weed management plan Specific measures may include but are not limited to

Avoidance of weed-infested areas for land-based construction activities (for example by relocating stockpile areas etc)

Construction activities restricted to approve construction corridors only

Weed management plan endorsed by the South Australian Murray-Darling Basin Natural Resource Management Board (SA MDB NRMB)

Wash-bay areas established according to weed management plan

Record kept of hygiene measures conducted prior to entering the site (for example plant trucks materials working clothes shoes boots etc)

Phytophthora cinnamomi distribution is contained to the wetter areas of the state It is highly unlikely that this fungus would be spread at the temporary weir site

For more information see httpwwwenvironmentsagovaubiodiversityplantsshyanimalsdiebackhtml

Weir Causeway

A submission claimed that as the level of the causeway would be higher than the temporary weir this would form a barrier and create new flow patterns

Response

There is no evidence that a flow path across the causeway exists with normal water level conditions The existing causeway and beach area on the western side contain no wash ways On the contrary there is evidence that only minor amounts of water in storm-driven waves have moved over the causeway

Weir Site

A submission from the SA MDB NRMB requests a better explanation of why this site is the preferred site

Response

This is explained through extensive studies summarised in Section 56 of the Draft EIS which concluded that no other feasible site exists down stream from Murray Bridge

Weir Construction and Environmental Management Plans

Some submissions criticised the lack of an EMP

Response

Specific mitigation measures will be developed in consultation with State environmental agencies to ensure that they are consistent with the relevant Acts and regulations (for example the Environment Protection Act 1993 (SA) the Natural Resources Management Act 2004 (SA))

Supplementary EIS for the temporary weir near Pomanda Island -7shy

The EMP is reviewed and endorsed by a number of agencies before any works can be carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) for the overarching EMP SA Water Corporation and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Weir Materials

One submission states that information about sourcing of material is not complete and raises doubts as to whether materials can be transported Will pollutants be introduced to the water

Response

The draft EIS (section 542) addressed the first two issues raised

The issue of pollutants to the Lake from the embankment material is covered in the requirements for an EMP and CEMP in the Draft EIS

One submission claims that mud waving will create a structure fault where the weir embankment fingers join It also claims that the structure will slip

The possible impact of mud waves on the structure is recognised and is one of the key elements in the c ontrac tor s c onstruc tion method The stab ility of the struc ture is a norma l design issue that is mitigated by using a design review process

The EIS provides all the available knowledge on material sources As the contracting method leaves the material source decisions to the contractor no further information will be available until a contract is awarded

Weir Crest

The MDBA requires confirmation that the temporary weir crest can resist erosion from flow

Response

Specific details for the temporary weir crest design were incorporated in an application sent to MDBA on 15 May 2009 This is not related to the draft EIS or the Supplementary EIS

Pumping

One submission claimed that the option of relocating the pump stations would involve a short timeframe and thus avoid the environmental impacts of constructing a temporary weir

Response

The option of re-locating pump stations is stated in the Draft EIS to involve a risk of continuity of supply The submission has also not recognised that the timeframe for moving a pump station individually upstream of Lock 1 (near Blanchetown) is similar to building a larger pump station upstream of Lock 1 and laying the required connecting pipeline Both options would require feasibility studies and engineering designs as well as the necessary State and Commonwealth approvals and assessments Should an EIS be required for these options it is envisaged that the projects would not be in place to ensure a potable water supply to Adelaide and Regional South Australia within the next two years

Permanent Weir

One submission claimed that impacts of permanent weirs are severe and therefore another weir should not be built on the River Murray

Supplementary EIS for the temporary weir near Pomanda Island -8shy

Response

The impacts have been examined and reported (See for example Draft EIS Section 831) taking into account the temporary nature of the proposed weir The Draft EIS concludes that the impacts of not building the temporary weir when critical trigger points are reached are more signific ant as muc h of South Austra lia s wa ter sec urity is threa tened

Triggers for Removal

A number of submissions claim that triggers are inappropriate because they specify conditions that have not prevailed for more than a decade and that they lack detail and are unlikely to occur within the next decade References are made to water levels in Murray-Darling Basin storages salinity in Lake Alexandrina and general water quality risks in Lake Alexandrina

Response

Triggers

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria as agreed by the Water Security Council and accepted by the MDBA and stated in section 58 of the Draft EIS remain appropriate

Removal of the temporary weir is highly dependant on the seasonal conditions as well as decisions by Murray-Darling Basin Ministerial Council on water sharing water recovery and water allocation policies The South Australian Government has selected a nominal 3 year life for the temporary weir as indicative

Stages

The graph below is available on the MDBA website and shows that storage levels dropped below the long-term average in 2002 and have not exceeded this since that time The time to recover storages to these levels is primarily dependent on inflows and while based on historical data it might take a series of years to recover to average inflows equally it could be much quicker in a single year with high inflow For this reason the life of the temporary weir has been referred to as nominally 3 years

Supplementary EIS for the temporary weir near Pomanda Island -9shy

Salinity in Lake Alexandrina

Similarly the graph below shows historical salinity levels in Lake Alexandrina where the salinity did not increase above 3000 EC (Electrical Conductivity) until 200708 This graph shows salinity averaged at four sites - A4261157 (Milang) A4261158 (West Pomanda Point) A4261133 (Beacon 90) and A4261156 (West Point McLeay)

Water quality in the Lakes is unlikely to improve until additional freshwater flows down the river to either dilute the Lake water or flush it to the sea The third trigger has been purposely expressed as water quality rather than salinity to allow for possible acidification impacts and associated mitigation measures

As fresh water flows eventually increase the salinity level in Lake Alexandrina will initially fall due to dilution and the Lake will fill with freshwater Salinity levels will then fall further as lake water is flushed to the Coorong and the ocean The extent of flushing required to reach the trigger level is dependent on how long the higher flows persist

Salinity measuring locations

One submission suggests that the target of 3000 EC lacks detail on where it is to be measured Another submission suggests that the target on storages should be replaced with a target on-flow to South Australia

Response

The 3000 EC trigger is intended to be a general salinity measurement in Lake Alexandrina Specifying a single measurement location is not appropriate because there can be areas of localised higher salinity and some of the sites where salinity has been measured over many years are now out of the water The intent is to take a rolling 7 day average over the four representative existing sites (Milang Mulgundawa Poltallock and Raukkan) Data from these sites have been collected for many years and existing protocols will be continued As part of these protocols the sampling sites have moved to accommodate the shift in shoreline

The flow to South Australia comprises a combination of ordered water (and South Australias entitlement flow of 1850 GL is in this category) and unregulated flow which is water that cannot be captured in Murray-Darling Basin (MDB) storages normally due to rainfall in the

Supplementary EIS for the temporary weir near Pomanda Island -10shy

lower parts of the catchment It is therefore possible to get high flows in any single year but the MDB storages could still be empty at the end of the year

It is only when the Hume and Dartmouth reservoirs have returned to normal operating levels (and other decommissioning triggers specified in section 58 the draft EIS have been met) that the South Australian Government can have confidence that the temporary weir would no longer be required The MDBA state that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

Decommissioning

A respondent questions how a structure designed for 3 years can be reconciled with a possible continuing drought and the removal triggers

Response

The temporary weir is designed to a nominal three year structural life and is expected to be removed when current drought conditions abate sufficiently with confidence that the improved River Murray flows are sustainable Detailed information on the triggers for decommissioning are specified in section 58 the draft EIS

As indicated in chapter 4 of the draft EIS the Murray-Darling Basin is six years into the worst drought on record It has led to low water River Murray flows over the border No-one knows when the drought is expected to end or how much water is expected to become available so it is necessary to plan for the worst scenario

Modelling

A number of submissions raised concerns about modelling

Water level forecasts may be incorrect due to assumptions about net evaporation There were questions about whether drought is the fundamental cause of the problem considering recent rainfall history in the Murray-Darling Basin

Modelling is only carried out for a period of 3 years despite the unknown length of the proposed operation

That modelling is only reported for an allocation to South Australia of 896 GL

That there is a lack of modelling results for temperature turbidity and acidification

That the temporary weir will cut off low water inflows

That water level modelling is flawed and underestimates local winter inflows

That the temporary weir will stop salts moving into Lake Alexandrina and these salts will be forced back into the River channel and

Further modelling particularly related to a virtual weir was sought

Response

The following graph (Department of Water Land and Biodiversity Conservation 020709) shows the drop in water levels in Lake Alexandrina over recent years The falls are quite uniform and the projections are consistent with recent history The models used have been accurate in projecting water levels to date

Supplementary EIS for the temporary weir near Pomanda Island -11shy

_

Lake Alexandrina Level

-26

-24

-22

-2

-18

-16

-14

-12

-1

-08

-06

-04

-02

0

02

04

06

08

1

0100 0600 1100 0401 0901 0202 0702 1202 0503 1003 0304 0804 0105 0605 1105 0406 0906 0207 0707 1207 0508 1008 0309 0809 0110 0610

Date (monthyear)

Lake

Ale

xand

rina

Wat

er L

evel

(m A

HD

)

Modelling projections have only been made for a period of 3 years because of the low probability of a continued period of extended drought and increasing uncertainty about future management responses Modelling using 896 GL flow over the South Australian border was used as it reflected the water sharing agreement for South Australia This figure is considered the worst case flow into South Australia

Flows to the Lower Lakes are currently determined by the minimum River flow needed to ensure that the maximum salinity at Murray Bridge remains within potable limits The temporary weir will not cut off flows to the Lower Lakes and once the pool behind the temporary weir is filled water will flow over the temporary weir into Lake Alexandrina at the rate of at least 350GL per annum

Modelling does not support the contention that the temporary weir will not prevent saline water from moving upstream into the River channel This is fully described in the Draft EIS

The Draft EIS acknowledged limitations with the model used to predict the movement of saline water in the Lakes but also notes that it provides the best information available and was based on numerous model runs (Refer also to section 443 of the Draft EIS) It is considered that running the models for a broader range of scenarios would not substantially alter the advice on impacts of the temporary weir The salinity model cannot be calibrated to a high level of certainty simply because there is no historic reference The current conditions are outside the bounds of normal lake operation

An adaptive approach will be required for managing the filling process for the pool upstream of the temporary weir to ensure that there is an appropriate balance between the various competing interests This will need to take into account issues such as technical constraints related to the construction program potential environmental impacts on Lake Alexandrina during the period of no flow or low flow to the lake flow requirements for the proposed fishway through the temporary weir and possible impacts on wetlands reclaimed swamp areas levee banks and the river bank as the water level rises upstream of the temporary weir Some of these issues will only become clear as the water level rises and the filling process will need to be adjusted in response to these impacts

It is apparent from the early contractor engagement process that the initial construction method adopted for the modelling described in the draft EIS will be slightly modified due to

Supplementary EIS for the temporary weir near Pomanda Island -12shy

technical constraints In addition a fishway will be provided through the temporary structure As a result of these factors the basic refilling process has been modified from that proposed at the time the draft EIS was published

The current proposal (assuming the inclusion of a fishway through the temporary weir) is to have a minimum dilution attraction flow of 200 MLday past the structure at all times during refilling An initial period of refill of some 2 to 3 weeks is proposed when level will be raised from -15m AHD to -12m AHD and the flow past the temporary weir would be limited to the 200 MLday This will be followed by a period of approximately 25 to 3 months when the level is held at -12m AHD and the passing flow will be approximately 1500 MLday Finally there will be a period of approximately 2 to 25 months as the temporary weir is refilled from -12m AHD to the nominal pool level of +01m AHD and the passing flow will be limited to approximately 200 MLday

However it is proposed that this refill strategy will be modified in response to any impacts arising from the refilling process as identified above

Virtual Weir

A submission suggests models need to be used with caution and asks whether models have been run at lower levels and with salinities less than seawater and what flow past Wellington would be needed to make a virtual weir work

Response

It is agreed that the model used to predict the movement of saline water from Lake Alexandrina to the River channel needs to be used with caution There is limited data with which to calibrate the model

The value of the model is to better understand the mechanisms of how saline water moves upstream and how it is dissipated This information is included in section 443 of the Draft EIS

The model indicates that current flow rates are too low to ensure mixing of fresh and saline water and prevent a saline layer making its way up the River Murray The modelling indicates that flows would need to increase by a factor of 5-10 times before this issue could be resolved As indicated in the draft EIS if this volume of water was available then no saline water would enter the river channel

Since the release of the Draft EIS the MDBA engaged WBM-BMT to undertake further hydrodynamic modelling to investigate the potential for and risks associated with a virtual weir Modelling will incorporate several months of new data and involves a number of new scenarios in respect of water levels lake salinities and wind strength direction and duration

It is anticipated that the outcome of this work will be available progressively during July and August 2009 and will further inform the technical feasibility of implementing a virtual weir

Supplementary EIS for the temporary weir near Pomanda Island -13shy

4 Supplementary comment on expected impacts of the temporary weir on soils and water

Introduction

The draft EIS involved discussion of soil and water quality impacts within many sections of most chapters The chapters specifically detailing soil and water quality impacts were

Chapter 8 Potential impacts of the proposed temporary weir

Chapter 10 Changes in water levels and salinity

Chapter 11 Soil and Water quality impacts

A significant number of submissions and government responses to the draft EIS included comments related to soil and water quality Government agencies such as the Environment Protection Authority (EPA) the Department of Water Land and Biodiversity Conservation (DWLBC) MDBA and the SA MDB NRMB have suggested changes in the light of new data or further information DEWHA has requested further clarification

Submissions received and responses

The major points raised by the submissions are detailed below along with responses involving a discussion and conclusion in regard to the points raised

Acid Sulfate Soils (ASS)

Submissions raised the following questions and concerns

Who is completing monitoring for alkalinity in Lake Alexandrina and where is monitoring data being stored Can the public or other agencies access this data

The lack of information about rates of acidification and potential release of metals (and metalloids) the mobilisation and flushing of acidity and associated contaminants (for example metals nutrients) to the water and the impacts of ASS and acidification on the ecology and ecological processes for example risks to species

The need to make more use of the considerable experience from elsewhere when dealing with ASS

The need to study acidity risks and environmental impacts associated with rewetting of wetlands upstream of the temporary weir

The need for information and data on hydraulics relating to flow cessation into Lake Alexandrina and sea water introduction and acidification thresholds

Not enough information on immediate and long-term implications of building the temporary weir (for example medium to low confidence in modelling of tipping point for acidification)

The need for additional modelling of acid and metal release

The need to address remedial actions necessary in the Lakes because of the accelerated decline in water level

Quantification of the risk of acid mobilisation upon re-wetting of River channel wetlands upstream of the weir site in general more consideration is needed to be given to these water bodies and

What are the mitigation measures planned if alkalinity levels reach 25mgL CaCO3

Response

As indicated below independent advice from leading international and Australian ASS scientists has been sought in order to increase knowledge on sulfide oxidation rates generation of contaminants (for example metals and nutrients) transport mechanisms and neutralisation dynamics

In 2008 the South Australian Government commissioned several reports into acidity metal mobilisation and water quality risks for the River Murray and Lower Lakes and it is further

Supplementary EIS for the temporary weir near Pomanda Island -14shy

prioritising investigations to assist with ASS mitigation and management options such as bioremediation

Such investigations can take from several months to years but once more information is available the models underpinning acidity and metal mobilisation impacts for this region can be better refined

Since August 2008 the SA MDB NRMB has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (for example sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (Report 1 March 2009 Available May 2009 wwwepasagovau) The EPA also compiles the raw data in a spreadsheet available to South Australian Government agencies

Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on the potential impact refilling wetlands will have on water quality of the Main River channel and the ecological impact of further acidification of wetlands

The

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes

Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the Murray-Darling Basin Authority Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from a DEH project identifying acidification remediation options for the Lower Lakes

Construction of regulating structures and other on-ground works for remediation at priority wetlands

Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRMB is managing the Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t with a steering c ommittee of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRMB DEH DWLBC MDBA SA Water Corporation EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of +01m AHD An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of the wetlands will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island for example wetlands providing important aquatic refuges

Conclusion

In conclusion it is agreed that the impact to River channel wetlands is an important issue that needs to be managed This is true irrespective of whether a temporary weir is constructed or

Supplementary EIS for the temporary weir near Pomanda Island -15shy

not Measures are already in place to minimise the risk to water quality in the River channel Refilling these wetlands will provide important aquatic refuges

The submissions on acid acidity and ASS support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible and be fed back into the ongoing planning and measures undertaken

In the meantime it is noted that there is extensive experience in dealing with ASS elsewhere Leading international and Australian ASS scientists with industry specialists have been contacted to provide independent advice and an ASS risk workshop involving many of Austra lia s soil and hyd rology sc ientists was rec ently held for the Lower Lakes If a lka linity levels reach 25mgL CaCO3L immediate mitigation measures such as limestone slurry dosing of the water in affected areas are expected to be undertaken

Recent information on ASS bioremediation and dust issues for the Coorong Lower Lakes and Murray Mouth reg ion is ava ilab le from the South Austra lian Government s Environment web page httpwwwenvironmentsagovaucllmmfaqs-acid-sulfate-soilshtml

Water quality

Wind seiche

There were a number of submissions in regard to wind seiche impacting on water quality at the pump intakes Concerns included

Some suggested that the remaining area of the Lake above the temporary weir (weir pool) would still be large enough to allow significant wind seiching to occur Due to low inflows and a large weir pool surface area salinity would increase in the weir pool and these seiching events would still have the capacity to drive the saline water within the weir pool upstream to the pump intakes

It was suggested that the temporary weir will effectively impede if not completely stop the wind seiche effect across Lake Alexandrina and into the River thus stopping the mixing of the water in the River and substantially increasing the risk of algal blooms

It was suggested that the impact of wind seiche in the weir pool is not fully understood and

Concern was expressed about cutting off seiche events into the lower Murray providing nutrients and oxygenated water from Lake Alexandrina Seiching events also allow transport of pollutants to the Murray Mouth and may build up in the weir pool when there are inadequate seiche effects

Response

Wind seiche is believed to be an important part of the ecosystem within the lower reaches of the River Murray It is a transport mechanism for both up and downstream transporting oxygenated nutrient rich water from Lake Alexandrina into the lower reaches of the River and allowing flushing from the channel of excess nutrients and salt Additionally it provides variability in water levels important for the life cycles and habitat of some native species

If the River system and Lower Lakes were experiencing normal flows and water levels then the temporary weir would reduce the effects of seiche events At the proposed trigger level to install the temporary weir (-15 m AHD) the connection of Lake Alexandrina to the River channel will be minimal reducing the effects of wind seiche As indicated in section 443 of the draft EIS this is partly due to the natural bathymetry of the river channel where it connects to Lake Alexandrina

Modellers have incorporated the effects of winds seiche including those modelling scenarios with a temporary weir in place There are also real world examples The draft EIS made a comparison between seiche effects above and below Lock 1 and noted that the effects were less pronounced above the lock Additionally BMT-WBM modelling indicates that by December 2010 under ongoing low flow conditions both scenarios with and without a temporary weir show a marked drop in the effects of wind seiche and there is little difference between the two scenarios

The draft EIS also stated that the effects of wind seiching are expected to be reduced by approximately 50 with the temporary weir This is because the temporary weir will decrease

Supplementary EIS for the temporary weir near Pomanda Island -16shy

the effects of wind seiche within the River channel by disconnecting it from Lake Alexandrina which supplies a large amount of momentum for water seiching up the lower River Murray

Any water from Lake Alexandrina that did manage to travel up channel will also be highly saline acidic and have high concentrations of metals Currently water does not flow over the barrages and out the Murray Mouth and would not at the trigger level of -15m AHD The shoreline of much of Lake Alexandrina would in fact be kilometres north of the barrages by this stage

With a temporary weir in place flows over Lock 1 will continue supplying a constant source of freshwater in the weir pool helping to keep salinity low within that pool Additionally the temporary weir will prevent the transport of saline acidic water from Lake Alexandrina into the River channel These effects along with the reduction in wind seiche will ensure salinity and contaminants at the pump intakes are minimised However the reduction is unlikely to remove all wind seiche effects creating enough movement to reduce the risk of algal blooms and oxygenate the water

Conclusion

The effects of the temporary weir need to be considered in the context of what the situation will be when it is proposed that the temporary weir will be installed that is at a water level of -15 m AHD in Lake Alexandrina While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes Some effects such as blue-green algae formation and potential reduction in oxygen levels upstream of the weir pool (due to reduced flow velocities over the temporary weir itself) whilst undesirable can be managed by the treatment plant whereas other poor water quality (such as metal releases due to acid sulphate soil effects potentially created in the Lakes) would be more difficult to treat Oxygen levels may fall within the weir pool due to the reduction in seiche events and a lack of oxygenated water from Lake Alexandrina however some seiching and wind action will still occur within the wide weir pool reducing the likelihood of anoxic conditions from occurring

Impacts upon Coorong and Lake Albert

A number of submissions raised questions about the impacts on the Coorong and Lake Albert from the temporary weir

Response

These submissions are noted however the proponent contends that the Draft EIS contains sufficient evidence that conditions in Lake Albert and the Coorong will be unaffected by construction of the temporary weir The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170 mm only occurs during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD (including Lake Albert and the Coorong) is not a direct impact of the temporary weir It is therefore beyond the scope of the draft EIS

The draft EIS considered that impacts of the temporary weir on the Coorong and Lake Albert were not considered significant This is because at the time of the weir closure the surface water elevation of Lake Alexandrina will be below sea level preventing any movement of water to Lake Albert and through the barrages to the Coorong The introduction of a temporary weir will not change this situation

Since May 2008 water levels in Lake Albert have been maintained artificially at an approximate height of - 05 m AHD by pumping from Lake Alexandrina Continued low River Murray flows have made this practice unsustainable and funding for pumping ceased on 30 June 2009 as noted by the MDB Ministerial Council on 12 June 2009 The cessation of pumping in June 2009 will lead to a gradual lowering of the level of Lake Albert The introduction of a temporary weir will not change this situation

Supplementary EIS for the temporary weir near Pomanda Island -17shy

Conclusion

At the trigger level for the construction of the temporary weir the Coorong and Lake Albert waters will be disconnected from Lake Alexandrina so changes to soil and water quality are not significantly impacted on by the temporary weir

Dredging of Murray Mouth

The issue of whether the dredge at the mouth of the Murray will remain there if the temporary weir is put in was raised

Response

The Murray Mouth is the only site where water contaminants such as silt salt and nutrients can exit the Murray-Darling Basin There has been no significant release of water from the Lower Lakes via the barrages since November 2005 and connection at the Murray Mouth has been dependent on dredging

The dredging program should only be regarded as a temporary measure Increased environmenta l flows a re the Murray s only solution in the long term if we are to keep the mouth open and maintain the health of the Coorong

Water quality impacts near Narrung Narrows

Submissions suggested that conclusions on water quality impacts from the construction of a blocking bank at the Narrung Narrows need revising in the light of additional monitoring data

Response

The construction of the blocking bank took 16 days to closure after commencing on 16 April 2008 Water quality parameters were monitored before during and after construction but revealed little impact with fluctuating turbidity levels likely due to the effects of wind as shown historically in figure 11-5 of the draft EIS There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid once water levels rose Alkalinity concentrations showed little change during and after the construction

Turbidity

The EPA has undertaken monitoring at locations around Lakes Alexandrina and Albert since the commencement of the construction of the Narrung Narrows blocking bank EPA water quality monitoring reports p repared for the b loc king bank p rojec t s steering c ommittee noted tha t some localised turbidity impacts were observed but this did not translate into widespread impacts in Lake Albert Figure 11-7 (below) shows turbidity readings for five locations and demonstrates that there is little correlation between the installation of the blocking bank the subsequent pumping and turbidity in both Lakes The variability in turbidity is principally related to climatic conditions at the Lakes For example the Lakes are shallow and the area experiences wind events which regularly create turbulence which is able to mobilise sediments thus increasing turbidity The spike at Meningie in December 2008 is not likely to be related to the blocking bank as it is nearly six months after construction

Supplementary EIS for the temporary weir near Pomanda Island -18shy

Turbidity at Monitoring Stations near the Narrung Narrows

0

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120408 70508 10608 260608 210708 150808 90908 41008 291008 231108 181208 120109 60209 30309 280309

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Lake Albert - 1km offshore Meningie jetty Lake Albert - Near narrows 3km NE of Reedy point

Lake Albert - Near water level gauge 11km N of Meningie Lake Alexandrina Poltalloch

Lake Alexandrina - Beacon 90

Figure 11-7 Turbidity (NTU) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Acidity

Water column pH has remained relatively constant with readings predominantly between 86 and 89 (Figure 11-8 of the Draft EIS) There was a pH drop in Lake Albert at the time of completion of the blocking bank with the closest monitoring point recording a pH of 79 These lows were recovered to normal levels within the month after pumping commenced

These results show there may be some localised effects to pH through the exposure of sulfidic sediment However the buffering capacity of the water and the quantity of exposed sulfidic sediment reduce the risk to the effects of pH to the Lake as a whole

pH at Monitoring Stations near the Narrung Narrows

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120408 10608 210708 90908 291008 181208 60209 280309 170509

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-8 pH at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Supplementary EIS for the temporary weir near Pomanda Island -19shy

Alkalinity

All stations with the exception of the Lake Albert station closest to the blocking bank have had relatively constant alkalinity concentrations The largest decrease in pH did not correlate with a reduction in alkalinity however later reductions in pH in August and November 2008 and January 2009 did Due to the continued exposure of sulfidic sediments over this time it is unlikely the effects are due to the blocking bank construction

Alkalinity at Monitoring Stations Near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-9 Alkalinity (mgL) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Conclusion

Water quality parameters were monitored before during and after the construction of the Narrung Narrows blocking bank and monitoring revealed little impact with fluctuating turbidity levels likely due to the effects of wind There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid Alkalinity concentrations showed little change during and after the construction

Algal blooms

There were many concerns about possible increases in algal blooms within the weir pool through reduction in flows and nutrient fluxes impacting on water quality

Response

The risk of algal blooms in the River is influenced by a number of interacting factors including weather conditions flow and turbulence and nutrient supply It is therefore not possible to precisely predict the extent and intensity of blooms However it is generally accepted that blue-green algae are favoured by waters with reduced turbulence reduced turbidity and increased nutrients A change to turbulence only increases the risk if sufficient nutrients are present to support the bloom The reduced flow in the River as a result of the drought will increase the likelihood of algal blooms The temporary weir will also reduce the flow and turbulence during the weir pool filling period and may therefore also tend to increase the risk of algal blooms Precise prediction of the frequency and intensity of algal blooms is not possible but it could be expected to be similar to the permanent structures upstream

Supplementary EIS for the temporary weir near Pomanda Island -20shy

There is a range of information mainly from studies overseas that lakes and rivers that experience frequent andor prolonged algal blooms display an array of ecosystem properties that may have impacts on water quality biological communities and ecosystem services

Some impacts of algal blooms may be direct including possible effects of toxins on fish invertebrates and other aquatic fauna or indirect including a reduction of submerged plants when plankton biomass becomes very high and changes in fish community structure due to hypolimnetic anoxia In lakes with dense blooms of blue-green algae accumulation of organic material in lake sediments and increased bacterial activity also may lead to anoxic conditions that alter the structure of benthic macro invertebrates Despite numerous case studies and a vast literature on species specific responses community level effects of blue-green algal blooms are not well understood

It must be noted however that these potential changes are associated with highly eutrophic environments that have frequent and persistent and often massive algal blooms These conditions are relatively extreme and unlikely to be encountered for extended periods in the River provided projected flows are maintained

The lower River Murray and other surface water storages within the Murray-Darling Basin regularly experience minor algal blooms due to seasonal stratification and periods of low flow These blooms have not been associated with the types of potential environmental effects that occur in the degraded systems with persistent blooms A case in point is the recent short-lived but highly visible bloom in the River Murray in NSWVictoria downstream of Hume Dam

It is not possible to make a precise prediction of the impact of the temporary weir on the risk of blue-green algal blooms However it is expected that the impacts will not be significant and will be similar to those in the permanent structures up stream

The water treatment plants in South Australia all have the capacity to remove algal cells and the toxins taste and odours that they produce and are able to mitigate any detrimental effects of algal blooms on water supplies

Summary of water quality impacts

One submission highlighted that the summary of water quality impacts in Chapter 11 of the draft EIS did not include all of the impacts to water quality particularly salinity

Response

The construction of the blocking bank at the Narrung Narrows was examined to determine what impacts on water quality if any were identified during and after construction of the blocking bank Using the blocking bank as an example it is expected that the construction of a temporary weir near Pomanda Island may have impacts on water quality both up and down stream

Water quality issues which may result within the weir pool include a reduction in flow velocity an increase in temperature and evaporation and a decrease in dissolved oxygen levels and in the effectiveness of wind seiche events to provide mixing and transport of salt nutrient and contaminants This may lead to temperature and salinity stratification and an increase in blue-green algal blooms in the weir pool It is expected that these impacts will be similar to those relating to the permanent structures that already exist in the River Murray up stream from Lock 1 and that the potential environmental risks will therefore not be significant

The construction of the temporary weir itself will create localised sediment waves as material placed in the River channel displaces sediment This sediment wave is likely to contain sulfidic materials that will oxidise and form acid Based on the experience of the Narrung Narrows blocking bank the provision of mitigation and management measures as outlined in the CEMP is adequate It can be expected that there will be localised impacts to turbidity pH and alkalinity but minimal effect at a distance

Once the weir construction is complete there will be a reduction in inflows to Lake Alexandrina while the weir pool is filled (see page 13 -14) Modelling indicates that during this time there will be a temporary increase in salinity in the waters of Lake Alexandrina However it has indicated that in the long-term the d ifferenc es in sa linity between the weir and no weir op tion under continued low inflows become insignificant

Supplementary EIS for the temporary weir near Pomanda Island -21shy

The reduction of flow during the filling of the weir pool (see page 13-14) predicts the volume of water in the Lake such that a further 5200 ha of sulfidic soils are exposed in Lake Alexandrina under the worst case scenario This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage ASS will need to be implemented across the Lake in this case

When these impacts are compared to the conditions likely to be present when water levels reach triggers for the temporary weir to be installed at viz 15 m AHD it is likely that the impacts of the temporary weir on water quality in Lake Alexandrina will be an increase in salinity for up to 3 months and bringing forward a potentially rapid pH reduction in Lake Alexandrina by 2 to 3 months For a detailed discussion of likelihood of Lake Alexandrina acidifying during the no flow period refer to Appendix 1 Question 7

For a detailed discussion of reasons underlying the 25 to 3 month disconnect of Lake Alexandrina refer to Appendix 1 Question 9

Connectivity of Surface and Ground Waters

Surface Waters

A few submissions questioned what the tributaries of Lake Alexandrina were and when they would disconnect

One submission was received stating that the drop in water level predicted to occur as a result of building the temporary weir should not have been expressed as an average but as a range

Response

There are four tributaries from the Eastern Mount Lofty Ranges (EMLR) to Lake Alexandrina namely

Angas River

Bremer River

Currency Creek

Finniss River

The surface waters of these tributaries will be disconnected at -15m AHD from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into the Lake and were the first to disconnect at a water level between +01 m and + 03 m AHD The Angas and Bremer have been disconnected since 2007

At times of medium to high outflow from these tributaries there is likely to be some reconnection of surface water with or without the temporary weir

The South Australian Government commenced construction of a temporary environmental flow regulator at Clayton in June 2009 The Goolwa Channel (and Currency Creek and the Finniss River tributaries) will be disconnected from Lake Alexandrina during construction of this regulator (EPBC Reference No 20094833)

The figures in Chapter 10 of the draft EIS show a selection of graphs of predicted water level impacts of the temporary weir From these the greatest reduction in water level during the weir pool filling phase in the first year is shown to be approximately 210 mm near the tributaries (points 63 and 64 Figures 10-13 and 10-14)

Conclusion

All tributaries except the Goolwa Channel are now disconnected from Lake Alexandrina and will remain so with or without a temporary weir

The construction of an environmental low flow regulator at Clayton will disconnect Currency Creek and Finniss River from Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -22shy

Reconnection of surface water in Angas and Bremer Rivers with Lake Alexandrina is likely at times of medium to high outflow from these tributaries This situation is unlikely to change with the construction of the temporary weir

Groundwater

A few submissions questioned the detail on surface waters and groundwater interactions

Response

In terms of groundwater connection it is assumed that the sediments in the tributaries and Lake Alexandrina will have some hydration from groundwater even at water levels of less than -28 m AHD

During development of the EIS DWLBC hydrogeologists were consulted on whether the p red ic ted dec rease in Lake Alexandrina s water level of 210 mm near the tributa ries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the drought induced water level drop which has already occurred

Conclusion

Tributaries are likely to remain connected to Lake Alexandrina through groundwater at levels less than -28 m AHD and the 210 mm difference in water level induced by the construction of a temporary weir is unlikely to have a significant impact on groundwater flux

Supplementary EIS for the temporary weir near Pomanda Island -23shy

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels

Introduction

Submissions discussed in this Section relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir as outlined below The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

Another issue of concern raised by many submissions and respondents is the potential impact of increased salinity within the Lower Lakes upon aquatic biota The following discussion adds considerable detail relating to predicted salinity changes and the likely biotic response endeavouring to provide greater breadth and clarity around this issue

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Upstream impacts

Impacts of altered water regime in weir pool

Several submissions argued that conditions in the weir pool created upstream of the temporary weir would favour exotic species such as Common Carp and disadvantage native species including EPBC Act-listed species such as Murray Cod Such an impact would be contrary to the goa ls of the MDBA s Native Fish Stra tegy

There was also a concern that flora species such as the common reed cumbungi and willows (an introduced species) in the riparianlittoral zones might respond in a way that could impact on matters of NES

Response

aspec ts of the p roposed temporary weir tha t interac t with ray-finned fishes of NES (page 15-13) should be expanded to include The list of

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

The list of potential impacts of the temporary weir upon aquatic fauna (Section 15415 pages 15-24) should be expanded to include

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

Advice from the South Australian Research and Development Institute (SARDI) Aquatic Sciences is that mitigation of improved spawning conditions for Common Carp in the Pomanda Island weir pool is not practical due to the scale of the issue Similarly measures to promote spawning of Murray Cod in the weir pool are not practical The potential impacts of the temporary weir upon EPBC Act-listed fishes in the River Murray channel upstream of the

Supplementary EIS for the temporary weir near Pomanda Island -24shy

temporary weir due to altered hydrology and increased exotic fish abundance appear to be unavoidable

The following aspec ts of the temporary weir tha t interac t with ripa rian flora such as Phragmites (common reed) Typha (cumbungi) and willow (introduced species) in the upstream wetlands and consequent effects on matters of NES (fauna) should be taken into consideration

The vegetation type and distribution in the upstream wetlands is expected to change due to the change in water level from (historic) +05m AHD - +08m AHD to a new level of +01m AHD and reduced wind seiche noting that current water levels are substantially lower than this

The change to a shallower wetland regime is expected to favour Phragmites and Typha which are invasive

The impact of changed vegetation pattern on matters of NES (EPBC-listed fish and birds) is expected to be negligible considering their preferred habitat

The impact of changed vegetation pattern on the EPBC-listed Southern Bell Frog is expected to be either to maintain or improve the preferred habitat for breeding

Impacts to Pelican Lagoon and Nalpa Station

Several submissions raised concerns regarding Pelican Lagoon and wetland habitats on Nalpa Station Pelican Lagoon is a large fringing wetland located directly upstream from the temporary weir site Previous surveys at the wetland and the Nalpa property have determined the area to be a biodiversity hot-spot hosting significant species such as the southern bell frog southern pygmy perch white-bellied sea eagle golden-headed c istic ola Lewin s ra il Australasian shoveler and various aquatic plant species As the wetland has been dry since early 2007 there is an inherent assumption that these species are lost therefore the impact of the temporary weir can be negated However further impacts upon these species are possible

Response

It would be desirable to resurvey the area particularly the small inundated area from which stock and domestic water are accessed to determine which species of significance remain and what measures can be taken to protect them

The local landholders have also shown an interest in undertaking management actions for the betterment of the wetland environment Support could be provided in the form of a wetland management plan for the site to determine the most effective way to manage the wetland

Weir Footprint Impacts

Impacts of Habitat LossDegradation

Several submissions argued that potential impacts to flora and fauna due to the clearance or disturbance of vegetation at the weir construction site were understated or unclear These flora and fauna included EPBC Act-listed species Among the fauna of concern were the Southern Bell Frog Orange-bellied Parrot La tham s Snipe (Gallinago hardwickii) White Bellied Sea Eagle and Great Egret Flora of concern included Phragmites australis Typha domingensis Senecio longicollaris Shrubby Groundsel (Senecio cunninghamii var cunninghamii) purple Loosestrife (Lythrum salicaria) and a range of samphire species

Response

A native fauna and flora survey of the approach works footprint and the subaqueous weir footprint was conducted by ecological consultants in SeptemberOctober 2008 (Ecological Associates 2008) Habitat impacts in the immediate weir footprint area were identified to be minimal

It is highly likely that the temporary weir will cause the loss of some of the reed beds at or near the construction site through physical disturbance

Supplementary EIS for the temporary weir near Pomanda Island -25shy

Impacts of mud disturbance upon salinity

One submission claimed that mud disturbance around the temporary weir site during construction would turn the water saline and impact on all fish species

Response

There is no available data which suggest that disturbance of submerged sediments can lead to an increase in the salinity of surface water

Impacts upon fish migration

A significant number of submissions argued that the temporary weir may impede upstream and downstream movement of juvenile and adult fish including EPBC Act - listed species and that this is an unacceptable impact upon upstream and downstream ecosystems and commercial fishing activities

Response

Due to concerns raised in submissions about the lack of a fishway (fish passage) a process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species

SARDI has indicated that it has sufficient knowledge to be able to design a fishway without the need for further site survey work SA Water Corporation is working with SARDI to design a suitable fishway into the temporary weir

SA Water Corporation is progressing a concept design for a fishway in the temporary weir with URS Australia

The concept design for the fishway is expected to be completed in July 2009 and a draft Concept Design Report should be available before the end July 2009 The report will include sketches of the concept and will also show the impact on the temporary weir design

The concept (although still to be finalised and confirmed) is for a rock ramp fishway in the centre of the temporary weir at the western end of the spillway This position places the fishway as close as possible to the deep channel to the west near Pomanda Island The rock ramp would be around 50 metres wide and slope downstream on a 130 gradient The deep centre section would be a metre deep (at full pool level) and the sides of the ramp would slope upwards to provide shallower and slower paths for smaller fish Stop logs at the top of the ramp will allow dewatering of the fish passage

Although the impacts on the temporary weir design will not be certain until the concept design is finalised the indicative impacts of such a concept include the following

The fishway hydraulic design will maintain an upper weir pool water level of 00m AHD with a flow of 600 MLday

A small auxiliary spillway is needed adjacent to the fishway to provide an attraction flow and this will pass 360 MLday the remainder of the average daily flow of 960 MLday (350 GLyear)

At a flow of 960 MLday the upper weir pool will be +01 m AHD with the fishway open (ie identical to the no fish passage design)

At a flow of 1200 MLday the upper weir pool will be +017 m AHD with the fishway open

For automatic operation the bottom of the auxiliary spillway will be inclined from +01 m AHD to +02 m AHD between the fishway and the main spillway

The main spillway crest will be raised to +02 m AHD to ensure that average daily flows remain confined to the fishway and auxiliary spillway Initially a spillway level of +01 m AHD had been established as the upper pool level to be retained by the weir

Supplementary EIS for the temporary weir near Pomanda Island -26shy

However the desire to have a ll flow pass through the fishway during norma l river flow that is 960 Mlday with the upper pool level maintained at +01 m AHD necessitates a reconfiguration of the main spillway of the temporary weir

The main spillway will be slightly shorter (around 1150m wide instead of 1200m wide) so that the fishway can be constructed on the western edge of the better foundation material

To ensure that water entering the downstream pool from either the fishway auxiliary spillway or main spillway remains continuous and provides an attraction path to the fishway the centreline of the auxiliary spillway and main spillway will be moved slightly downstream between the fishway and the eastern abutment

The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Impacts of noise upon wetland birds

One respondent sought clarification on the level of noise the weir construction is anticipated to create given that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB as stated in the Draft EIS

Response

There are no wetlands on the eastern side near the abutment It is anticipated that any areas around Low Point populated by birds will receive noise levels similar to that from a busy highway The same will apply to the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels which would presumably cause them to move further north into the wetland area

Monitoring during constructiondecommissioning

A number of submissions questioned how the Monitoring of EPBC-listed spec ies referred to on page 15-24 of the Draft EIS will ensure that construction operation and decommissioning activities do not impact on EPBC-listed species More information was sought on the fauna inspection to be carried out in the construction area before any vegetation clearance (Table 15-9 on pp 15-2526 of the Draft EIS)

Response

Monitoring during operation of the temporary weir will be coordinated as part of the SA MDB NRMB s na tura l resource condition monitoring program It will include additional monitoring efforts as per expert advice

of the EPBC-listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life and breeding cycles The monitoring focus will be of an observational nature in regards to compliance monitoring This is to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by the Commonwealth and the South Australian Native Vegetation Council) and that the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora and fauna expert advice if warranted In addition the Contrac tor s EMP will identify based on a risk assessment whic h spec ific mitiga tion and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations needs to be recorded

It is rec ognised tha t the monitoring

A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water Corporation and DEH (Ecological Associates 2008) This knowledge has been considered by the Commonwealth More specific instructions on how this can be used will be included in the CEMP The project will ensure that expert advice is available throughout the duration of the construction phase

Supplementary EIS for the temporary weir near Pomanda Island -27shy

Timing of construction and presence of migratory species

One respondent commented that the Draft EIS did not appear to consider the interaction between the timing of construction and the presence of migratory species eg Orange-bellied Parrot potentially present from March to early November

Response

The Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to help protect Orange-bellied Parrots might however impact on other species Migratory shorebirds for example return in late August and spend the entire summer at the site

Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coorong_S urvey_lowpdf

Downstream impacts

Impacts of water level changes upon aquatic vegetation

A respondent noted that in Section 1246 on page 12-11 of the Draft EIS under the heading Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion are

considered insignificant as many of these species reproduce sexually and through wind or bird-d riven seed d ispersa l This is only a c onsidera tion of impac ts upon rep roduc tion not a consideration of whether the plants will even survive to reproduce

Response

Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately +035 m AHD At a water level of -15 m AHD (when the temporary weir would close) this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the water body and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long-term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the Lake be refilled with freshwater to its pre-drought level (+05 to +08 m AHD) while the below-ground storage organs remain viable

Impacts of temporary increase in salinity upon aquatic biota

A significant number of submissions raised concerns regarding the impact of the temporary weir upon salinity in the Lower Lakes and consequent impacts upon biota There were also concerns that not all Matters of NES potentially impacted by the temporary salinity increase caused by the temporary weir had been adequately addressed One submission predicted the salinity increase would cause a mass die-off of Common Carp which would lead to poor water quality in Lake Alexandrina

Response

The scope of the EIS dictates that it consider the impacts of the temporary weir upon biota that are listed as threatened under the EPBC Act or that contribute to the ecological character of the Coorong Lakes Alexandrina and Albert Ramsar site These include all of the freshwater diadromous and estuarine fish species of the freshwater units (Lower Lakes) as well as a large number of bird taxa many of which are piscivorous (Phillips and Muller 2006) Taxa other than fish and birds need only be considered by the EIS if impacts upon them are likely to be transferred into a significant impact upon fish or bird communities

Supplementary EIS for the temporary weir near Pomanda Island -28shy

The impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake (Fig 10-5 in the Draft EIS) The salinity of Lake Alexandrina is predicted to be higher than both the limits of acceptable change (700 EC (Phillips and Muller 2006)) and the typical seasonal maximum (1500 EC) from January 2010 onwards at all loc a tions under both the weir and no weir sc enarios Modelling shows tha t the d ifferenc e in salinity in Lake Alexandrina (modelling assuming continued pumping to Lake Albert however on 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009) under the weir and no weir sc enarios va ries with location At all sites modelled salinity is similar in early 2011 one year after weir construction under both the weir and no weir sc enarios (Sec tion 10) However immediately following weir construction a temporary increase in salinity three to five months in duration is predicted at most sites The magnitude of the salinity increase varies between sites but is pronounced at several sites

A salinity threshold that is important in terms of the maintenance of ecological character is the salinity tolerance of the resident native freshwater fish species of the Lower Lakes Salinity tolerance varies between species but for the temporary weir to have no significant impact upon native fish species its construction should not cause salinity to exceed the tolerance of the most salinity-sensitive species

Several species of rare or threatened small-bodied native freshwater fish that are resident in the Lower Lakes under pre-drought water levels (+04 to +08 m AHD) are unlikely to be present in Lake Alexandrina at a water level of 15 m AHD Yarra Pygmy Perch have probably become locally extinct in the CLLMM as a consequence of the current low water levels (Bice and Ye 2009) Mountain Galaxias Murray Rainbowfish and Southern Purple-spotted Gudgeon are all very rare possibly extinct from the CLLMM with no records for a number of years (Bice and Ye 2009) All of these small-bodied species are associated with fringing aquatic vegetation They are unlikely to be present in Lake Alexandrina when water levels have declined to the extent that all fringing aquatic vegetation has become disconnected from the water body

Prior to the drought the only part of the Coorong Lower Lakes and Murray Mouth where River Blackfish had been recorded were the upper reaches of the Eastern Mt Lofty Ranges tributaries that enter Lake Alexandrina (Bice and Ye 2009) The species prefers permanently flowing freshwater streams with cool clear water where it is strongly associated with the in-stream cover habitats provided by undercut banks and boulders (Khan et al 2004) It is unlikely to be present in the open water habitat of Lake Alexandrina that is disconnected from fringing aquatic vegetation and other forms of cover

A number of short-lived (lifespan generally 3 years or less) small-bodied native freshwater fish species could potentially be present in Lake Alexandrina when the water level reaches

15 m AHD These species are dependent upon fringing or benthic aquatic vegetation during part of their lifecycle particularly egg and larval stages (Lintermans 2007) with the exception of Australian Smelt which is a more pelagic species Therefore conditions in Lake Alexandrina are likely to be unfavourable for their persistence due to the disconnection of fringing vegetation and the water body Although unlikely it is possible that these species may persist providing important remnant populations that could potentially increase in abundance and repopulate the Lake when water levels return to pre-drought levels Due to their brief lifespans the salinity tolerances of all stages of the life cycle are relevant to the potential impacts of the temporary weir upon them Egg and larval stages typically have the lowest salinity tolerance (Bice and Ye 2009) Because breeding occurs in spring and summer for most of these species (Lintermans 2007) the summer-autumn timing of the short-term increase in salinity levels caused by weir construction could have implications for breeding success and thus persistence of these short-lived species in the Lower Lakes The species and salinity tolerances of their most salinity-sensitive lifestage are Southern Pygmy Perch (15500 EC (adult tolerance - egg and larval tolerance not known)) Murray Hardyhead (80000 EC (low confidence)) Carp Gudgeon complex (9800 EC) Flat-headed Gudgeon (19200 EC) Dwarf Flat-headed Gudgeon (10800 EC) Australian Smelt (92200 EC (adult tolerance - egg and larval tolerance not known)) and Unspecked Hardyhead (68300 EC (adult tolerance - egg and larval tolerance not known)) (Bice and Ye 2009)

The large-bodied native freshwater fish of Lake Alexandrina all have a lifespan of at least several years Thus a short-term (three to five month) increase in salinity that exceeds the tolerance of eggs or larvae does not represent a significant impact to the species if adults are unaffected and can subsequently successfully reproduce when salinities return to tolerable

Supplementary EIS for the temporary weir near Pomanda Island -29shy

levels for sub-adult life stages Large-bodied native freshwater fish species potentially present in the Lake Alexandrina at a water level of 15 m AHD and their respective adult salinity tolerances are Murray Cod (24 500 EC) Silver Perch (25 000 EC) Eel-tailed Catfish (28 000 EC) Golden Perch (Callop) (51 500 EC) and Bony Herring (54 500 EC) (Bice and Ye 2009)

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9) Thus construction of the temporary weir causes salinity to shift from tolerable to intolerable for the eggs or larvae of Carp Gudgeon complex Dwarf Flat-headed Gudgeon and possibly Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead Although the period of intolerable salinity is temporary it will lead to declines in their abundance in the Lower Lakes There are no modelled sites at which salinities will shift from tolerable to intolerable for large-bodied species

Carp Gudgeon complex Dwarf Flat-headed Gudgeon Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead

Declines or complete loss of small-bodied native freshwater fish

from Lake Alexandrina if this occurs is anticipated to be temporary All of these species occur in the River Murray channel and their downstream migration past the temporary weir (which is to feature a fishway) into the Lower Lakes is anticipated to recommence following the period of reduced flow (see page 13) during weir construction Therefore any declines in abundance due to the short-term increase in salinity levels associated with weir construction are likely to be temporary

Adult Common Carp have a salinity tolerance of ~23 500 EC (Bice and Ye 2009) Modelling indicates that the temporary increase in salinity levels caused by weir construction will not cause salinity to increase from tolerable to intolerable for adult Common Carp at any site Most of Lake Alexandrina will remain below the salinity threshold for this species Therefore the temporary increase in salinity caused by the temporary weir is not anticipated to cause a mass die-off of Common Carp or associated water pollution

Recently collected data puts the above discussion into context Fish surveys conducted during weeks 13 17 April 2009 in the Goolwa channel (between Clayton and Goolwa barrages) indicated the obligate freshwater fish community of this area of the Lower Lakes was composed primarily of three species Australian Smelt Flat-headed Gudgeon and Bony Herring (SARDI unpublished data) Salinities at Clayton during the same period ranged from ~18000 to ~24000 EC (DWLBC 2009) These three species are clearly able to persist in the Lower Lakes despite loss of connectivity with fringing aquatic vegetation and elevated salinity Their persistence indicates that both their habitat and feeding requirements are met When the water level in the main body of Lake Alexandrina falls to 15 m AHD triggering weir construction it is likely that the obligate freshwater fish community will be comprised primarily of these three species The temporary increase in salinity levels anticipated will not lead to salinities in excess of those that these species are currently experiencing in the Goolwa channel

The above discussion illustrates that the temporary increase in salinity levels caused by the construction of a temporary weir near Pomanda Island is unlikely to have a significant impact upon the resident native freshwater fish species of the Lower Lakes The temporary increase in salinity levels will cause salinity in Lake Alexandrina to shift from tolerable to intolerable for a small number of short-lived small-bodied native freshwater fish species However at the time of weir construction these species are likely to be in decline or absent due to other factors primarily the loss of fringing aquatic vegetation habitat unrelated to weir construction Additionally the unfavourable salinities caused by weir construction are predicted to be temporary and repopulation of the Lower Lakes via downstream migration from the River Murray channel is anticipated to occur following weir construction Ongoing fish monitoring of the lower lakes will provide further information regarding impacts to native freshwater fish

The above discussion has focussed primarily upon obligate freshwater fish of the Lower Lakes However a number of diadromous and estuarine species are also common in the Lower Lakes (Phillips and Muller 2006) The salinity tolerances of these species are much higher than those for obligate freshwater fish species (Bice and Ye 2009) and the temporary increase in salinity levels due to weir construction is not anticipated to have a significant impact upon diadromous or estuarine species

Supplementary EIS for the temporary weir near Pomanda Island -30shy

It is likely that the impacts of the temporary weir upon fish in the Lower Lakes will be transferred to piscivorous birds Given that the temporary weir is unlikely to have a significant impact upon obligate freshwater diadromous or estuarine native fish species a significant impact upon piscivorous birds due to declines in native fish abundance is also unlikely Therefore piscivorous birds are not anticipated to be significantly impacted by weir construction

The impact of the temporary increase in salinity levels upon the invasive polychaete tubeworm Ficopomatus enigmaticus should be examined in the light of the research being undertaken by Dr Sabine Dittmann for the SA MDB NRMB The tubeworm itself has not been identified as a Matter of NES however changes to its abundance may impact upon Matters of NES

The Long-necked Tortoise is not listed as threatened under the EPBC Act nor is it considered a Ramsar-significant species or a primary determinant of ecological character for the CLLMM (Phillips and Muller 2006) The Long-necked Tortoise population of the CLLMM is therefore not a matter of national environmental significance and the impact of the temporary weir upon it is outside the scope of the EIS

Impacts upon tributary wetlands

A number of submissions were received regarding the impacts upon the ecosystems of the tributary wetlands of disconnection of surface waters and groundwater interactions caused by construction of the temporary weir

Response

The Swamps of the Fleurieu Peninsulas geographic distribution include swamps fringing Currency Creek Finniss River Goolwa Channel and Lake Alexandrina near Milang These swamps have already disconnected from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into Lake Alexandrina and were the first to disconnect at a water level of approximately +03 m AHD

The Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton (EPBC Reference No 20094833) The South Australian Government commenced construction of the regulator in June 2009 This regulator is expected to be completed in August 2009 and will result in the Goolwa Channel Currency Creek and Finniss River being disconnected from Lake Alexandrina

The Hindmarsh Island channels disconnected at approximately +01 m AHD These well-vegetated water bodies were significant habitat for the EPBC-listed Yarra Pygmy Perch and thus a captured breeding and recovery program has been implemented to ensure that the populations survive the current drawdown and can be released once water levels and habitat conditions improve

In terms of groundwater connection it is assumed that the tributaries and Lake Alexandrina will remain connected through groundwater at water levels less than -28 m AHD and thus could potentially be impacted upon by construction of the temporary weir During development of the EIS DWLBC staff were consulted on whether the predicted decrease in the Lake Alexandrina level of 210 mm near the tributaries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the water level drop caused by drought and over-allocation already experienced

Impacts upon the Milang Snipe sanctuary

One submission argued that the Draft EIS had not adequately addressed impacts upon the Milang Snipe Sanctuary

Response

The Milang Snipe sanc tuary is a very signific ant refuge for Japanese (La tham s) Snipe a recognised migratory species under the EPBC legislation and a listed species under the China Australia Migratory Bird Agreement (CAMBA) Japan Australia Migratory Bird Agreement (JAMBA) and the Republic of Korea Australia Migratory Bird Agreement (ROKAMBA) In

Supplementary EIS for the temporary weir near Pomanda Island -31shy

addition the presence of mature aquatic vegetation and the mosaic of ponds have provided excellent habitat for a suite of other waterbird species

The Japanese Snipe requires freshwater wetlands and vegetated meadows and preferably seasonal or semi permanent freshwater swamps Under a different hydrological regime the inundation frequency of the wetlands will change and the habitat will no longer remain optimal This site is a very good example of a wetland that may become compromised by altered hydrology

The Milang Snipe sanctuary is inundated when water levels in the Lower Lakes are high The site is currently dry The temporary weir is not anticipated to impact upon the water regime at the Milang Snipe sanctuary and therefore no significant impact upon the ecosystem of this site is predicted as a consequence of weir construction and operation

Impacts upon primary determinants of ecological character

One respondent noted that the summary of ecological impacts upon the primary determinants of ecological character (pg 12-20 section 126) appears to relate more to current drought-related ecological impacts and not specifically to the additional (likely to be small in comparison) ecological impacts of temporarily reducing flow to Lake Alexandrina

Response

This is agreed Additional comment is as follows Section 12-6 of the Draft EIS summarises the predicted impacts of the temporary weir upon the primary determinants of ecological character of the CLLMM Ramsar site It covers impacts to two primary determinants keystone aquatic plant species and habitat availability However it does not address the other four primary determinants outlined in the ECD It also fails to clarify the difference between drought impacts and weir impacts upon the primary determinants The following changes are proposed

In Section 12-6 pages 12-20 under the dot point Hab ita t ava ilab ility add the following four dot points

Salinity assigned a red light highlighting that conditions in 2006 were leading to loss of species (including keystones) and that salinities in the saline-estuarine units needed to be reduced urgently in order to maintain ecological character

Turbidity and sedimentation patterns assigned an orange light assessment highlighting that knowledge was poor and improved flows were required in 2006

Water levels assigned an orange light assessment highlighting that the regime in 2006 was counter-seasonal to the natural one and too static to support the full complement of the Lakes b iota and

Water regime particularly flow patterns in relation to inflows from the River Murray assigned a red light assessment highlighting that change to the ecological character of the site is largely a consequence of reduced flows from the River Murray

Additionally the first paragraph on page 1221 of the Draft EIS should be replaced by the expanded discussion under the six sub-headings which follow

Impact upon keystone species

Keystone aquatic plant species and assemblages in the Lower Lakes and tributary wetlands have become disconnected from the water body threatening their ongoing persistence Disconnection occurs at water levels below approximately +035 m AHD and is a consequence of the drought and upstream diversions Modelling indicates that disconnection will continue indefinitely under anticipated low flow conditions (see Section 10) with or without the weir in place The temporary weir will not alter the duration of disconnection between the keystone aquatic plant species and the water body The impact of the temporary weir upon this primary determinant of ecological character is therefore considered insignificant

Impact upon habitat availability

Habitat availability (particularly spatial and temporal connectivity) has been dramatically reduced by the drought due to the disconnection between the various parts of the system Key water levels for disconnection include

Supplementary EIS for the temporary weir near Pomanda Island -32shy

+05 m AHD disconnection between the freshwater and saline-estuarine units occurs (permanent barrage closure is required to prevent seawater incursion into the Lower Lakes)

+035 m AHD disconnection between fringing aquatic vegetation of the Lower Lakes and the water body

03 m AHD disconnection between Lake Alexandrina and Lake Albert occurs and

12 m AHD disconnection between the Goolwa channel (and associated tributary wetlands) and Lake Alexandrina occurs

Water levels of lt 15 m AHD will persist for the 2010-2012 period (the nominal lifespan of the temporary weir) should low flows continue (896 GLyr at the SAVic border) whether the temporary weir is built or not (Section 10) Thus the temporary weir will have no impact upon connectivity within the Ramsar site connectivity having already been lost due to the drought However the temporary weir will have an impact upon connectivity between the River Murray channel upstream and the Coorong Lakes Alexandrina and Albert Ramsar site downstream The impact upon this loss of connectivity upon fish and potential mitigation measures is discussed in Section 1353 of the draft EIS

Impact upon salinity

As discussed on page 31 the impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9)

Impact upon turbidity and sedimentation patterns

The turbidity and sedimentation patterns in the Ramsar site are not predicted to be significantly impacted by the temporary weir The impact of current and ongoing low water levels upon this primary determinant of ecological character is anticipated to overwhelm any additional impact caused by the temporary weir The potential for temporary increases in turbidity during the construction phase of the temporary weir will be addressed by mitigation measures discussed in Sections 114 and 115 of the draft EIS

Impact upon water levels

The impact of the temporary weir upon water levels is discussed extensively in Section 10 of the d ra ft EIS Under both weir and no weir sc enarios wa ter levels in the Lower Lakes will be well outside those recommended by Phillips and Muller (2006) ie +01 to +08 m AHD Modelling shows that the temporary weir leads to lower water levels in Lake Alexandrina than would occur if it were not constructed but that the effect is reduced as time post construction increases (Table 10-7) Of particular note is the impact of weir construction upon the timing of exposure of sulfidic sediments in Lake Alexandrina Construction of the temporary weir is anticipated to lead to the critical water level of 15 m AHD which is expected to lead to acidification of the Lake being reached earlier than would occur if it were not constructed However modelling indicates that such water levels will be reached irrespective of a temporary weir being constructed should low flows continue Measures to avoid acidification are discussed in Sections 1126 and 15412 of the draft EIS

Impact upon water regime

The impact of the temporary weir upon water regime particularly flow patterns is considered insignificant

As indicated on page 32 the Angas and Bremer have been disconnected since 2007 and the Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton

Lake Albert was disconnected with the cessation of pumping from Lake Alexandrina on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -33shy

By mid to late 2010 the water level in Lake Alexandrina will be at approximately 15 m AHD Thus the Lake will be disconnected from all other parts of the Ramsar site (ie the Coorong)

Thus any impact of the temporary weir upon water regime affects only Lake Alexandrina and the small area of the Ramsar site located upstream of the weir site The impact upon Lake Alexandrina is a temporarily increased rate of water level decline with various consequences discussed above The impact of increased water level upon the area of the Ramsar site upstream of the temporary weir and upon the River Murray channel upstream of the Ramsar site is considered to be positive provided acidification can be avoided or mitigated

Impacts upon migratory shorebirds

A number of submissions argued that the potential impacts of the temporary weir upon migratory shorebirds had not been adequately addressed Additionally several submissions expressed concern that by limiting the discussion of impacts to regularly recorded migratory shorebirds important impacts could be overlooked It was argued that species recorded infrequently and in low numbers should be a priority for protection as it is likely that they are more susceptible to localised impacts

Response

The temporary weir is unlikely to impact negatively upon the abundance of migratory shorebirds using Lake Alexandrina Under previous management arrangements the Lake was surcharged with water each year and only small areas of exposed mudflat were useable by shorebirds Over the past 18 months the wa ter line has rec eded and the Lake s edges have a t times been used preferentially (compared with the Coorong) for foraging purposes (Wainwright and Christie (in press))

Section 14 of the Draft EIS examines the likely interactions should the temporary weir proceed All migratory shorebirds are listed as matters of NES under the EPBC legislation The separation of seven spec ies into a group desc ribed as regula rly rec orded rela tes to the abundanc e of these species in comparison with any other migratory shorebird and tern species that have been observed a t Lake Alexandrina The regula rly rec orded group a re a t least two orders of magnitude more common Waterbird data collected monthly from 16 sites (2003 to current) around Lake Alexandrina informs this thinking

Impacts upon Australian Painted Snipe

A number of submissions argued that the Draft EIS should have addressed impacts upon the Australian Painted Snipe

Response

The Australian Painted Snipe is nomadic and adopts wetlands opportunistically It requires freshwater and well vegetated wetlands with internal complexity Recent records from Lake Alexandrina are scarce (Letch 2007) presumably because the recent drought has eliminated all suitable habitats However historic records suggest that the fringing habitats around Lake Alexandrina when intermittently favourable have been frequented by the species Recent information suggests that the Australian Painted Snipe may be present close to the site of the temporary weir

Low water levels in the Lower Lakes appear to have led to a significant loss of habitat for the Australian Painted Snipe However given the suggestion that it may be present in the vicinity of the temporary weir construction area it should be considered in the EMP to be prepared for weir construction

Impacts upon Orange-bellied Parrot

One respondent noted that discussion of the Orange-bellied Parrot did not mention the importance of samphire habitat to this species One submission argued that potential impacts upon the Orange-bellied Parrot had not been properly addressed in the Draft EIS

Response

Within South Australia the Orange-bellied Parrot appears to be less dependent than previously suspected on samphire vegetation Recent observations in South Australia suggest that the

Supplementary EIS for the temporary weir near Pomanda Island -34shy

species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

The Orange-bellied Parrot is critically endangered and interactions with proposed weir operations are considered possible The species is known to use a range of habitats including highly disturbed areas Accordingly it is a subject discussed in Chapter 13 of the draft EIS

Impacts upon Great Egret Cattle Egret and Caspian Tern

One respondent expressed concern that the Great Egret Cattle Egret and Caspian Tern are not dealt with satisfactorily One submission noted problems with the nomenclature concerning egrets

Response

The two Egret species being discussed in Section 761 are the Great Egret Egretta (Ardea) Alba and the Cattle Egret Ardea ibis Both species are listed migratory species under the EPBC legislation The Cattle Egret is listed as a migratory species using the binomial Ardeola ibis The reference in Section 77 to the White Egret for consistency should read Great Egret Both are recognised English names for the species Egretta (Ardea) Alba

The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in south-eastern Queensland and north-eastern New South Wales (Marchant and Higgins 1993)

The movements of Caspian Tern are poorly understood they are partly resident partly dispersive and possibly partly migratory (Marchant and Higgins 1993) The species is commonly observed on fresh and marine waters foraging on the wing for fish

Impacts upon pelagic birds

One submission argued that potential impacts upon pelagic bird species had not been properly addressed in the Draft EIS

Response

Pelagic bird species listed in the draft EIS (including all listed Albatross species Blue Petrel Giant Petrels and the Soft-plumaged Petrel) are all oceanic species that have no dependence on Lake Alexandrina for food or habitat Their presence at the site is fortuitous Records are mostly of ocean beach-washed specimens or live animals temporarily blown inland during storm events The weir construction has no effect on their endurance

Impacts upon bush birds

One submission argued that potential impacts upon bush bird species had not been properly addressed in the Draft EIS

Response

The Black-eared Miner Red-Lored Whistler Malleefowl and Regent Parrot are all species that require mallee or woodland habitats that are now largely absent from the edges of Lake Alexandrina These bird species are now locally extinct from the Lakes area because of landscape scale changes to adjacent woodland and mallee habitats Recent observations of these spec ies in the reg ion (as c ited in The Natura l History of Stra tha lbyn and Goolwa Distric ts 2000) are from locations that support very different habitats to those immediately adjacent to

Supplementary EIS for the temporary weir near Pomanda Island -35shy

the Lakes It is highly unlikely that any of these species would be affected by the temporary weir

The Spotted Quail-Thrush is now considered extinct in the Mount Lofty Ranges and Fleurieu Peninsula

Impacts upon Mt Lofty Ranges Southern Emu Wren

Several submissions argued that potential impacts upon the Mt Lofty Ranges Southern Emu Wren had not been adequately addressed in the Draft EIS

Response

The Mount Lofty Ranges Southern Emu-Wren is recognised as an endangered species that inhabits fragmented wet and dry heath in the vicinity of the proposed weir site The nearest known rec ords of the spec ies (sourc e Biolog ic a l Da tabases of SA ) determined by extensive surveys are 35 kilometres from the temporary weir site at the top of the Finniss estuary It most unlikely that the temporary weir proposal would impact negatively on the species however it has been considered in the discussion about impacts in Chapter 13 of the Draft EIS

Impacts upon White-bellied Sea Eagle

One submission argued that potential impacts upon the White-bellied Sea Eagle had not been properly addressed in the Draft EIS

Response

The White-bellied Sea Eagle is regularly observed but not so commonly recorded in the Lower Lakes and Coorong area The species exploits the protected waters at both sites for fishing A recent sighting of a juvenile bird suggests that local breeding also occurs The implications of the temporary weir on this species are outlined in Chapter 14 of the draft EIS

Issues of scope adequacy and definition

Adequacy of species and communities examined

There were a significant number of submissions on this issue and one respondent who argued that the Draft EIS was inadequate in its assessment of ecological impact because the range of species and communities examined was too limited The Draft EIS assessment was constrained to the Matters of NES listed in the EPBC referral documents Submissions raise the criticism that all components of the Ramsar site should be assessed not just nominated Matters of NES because they are interconnected and interdependent

Response

This statement is true in terms of defining changes to ecological character of the Ramsar site And if the temporary weir were to be built under normal operating conditions all ecological components would have been assessed However the impacts of the temporary weir per se were restricted to those ecological components that would occupy the Ramsar Type O (permanent freshwater lakes) wetlands at a water level of -15 m AHD because this will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir

It is also assumed that at -15 m AHD there will be little or no aquatic vegetation in the Type O wetland because historical high turbidity and static water levels have precluded growth of plants that far out into the Lakes The water body that remains would generally be several kilometres from the existing aquatic plant seedbank and would remain very high in turbidity and experience high energy water movement Thus it is not predicted that keystone aquatic plant species will colonise this area before construction of the temporary weir The benthos was not assessed specifically and further research into the species and distribution of benthic fauna at very low lake levels would improve this draft EIS particularly given the dependence of EPBC-listed fish and bird species on benthic fauna

Impacts on other Ramsar Wetland Types (that is the rest of the Ramsar site) were not considered because the impacts of the drought and over allocation were considered to be the primary determinants of change in ecological character for those wetlands

Supplementary EIS for the temporary weir near Pomanda Island -36shy

Current status of waterbirds

One submission noted that the current status of waterbirds and migratory shorebirds at the CLLMM had not been adequately stated and that recent research (Kingsford 2009) had not been referred to

Response

Most waterbird species are migratory to some degree Some species have predictable movements but most species respond opportunistically to climatic events that bring about favourable changes in habitat quality or food resources Local and continental rainfall patterns have a strong influence on the abundance of waterbirds using the Lower Lakes At the continental scale there were significant changes in the amount of rainfall (and subsequent change in area of wetland habitat) between November 2007 and early 2009 In late 2007 the Murray-Darling and Lake Eyre Basins were both drought affected During 2008 South-eastern Queensland and northern New South Wales received record rainfall and a 1-10 year flood occurred in the Lake Eyre Basin The entire populations of some species (Pink-eared Duck for example) respond to these events adopting the most favourable habitat available The large amount of variability in waterbird numbers is expected and it is a strategy waterbirds use to survive the natural variability in the Australian climate

Regular bird survey work at 23 sites around Lake Alexandrina during the last 12 months suggests that there are no detectable changes in the species richness of waterbirds using the Lower Lakes There are more obvious changes in abundance and as a generalisation waterfowl numbers have decreased while shorebird abundance has increased

Adequacy of EPBC Act threatened species and communities lists

One submission argued that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the Murray-Darling Basin including the CLLMM region are currently being evaluated for EPBC listing

Response

The scope of the EIS is confined to Matters of NES Only nationally listed threatened species or nationally listed migratory species or those that contribute to the ecological character of a Ramsar site are matters of NES Species and communities that are under evaluation for listing as threatened but not yet listed are not matters of NES

Adequacy of discussion of EPBC Act-listed species

One submission argued that the discussion of EPBC Act-listed species in the EIS is incomplete and superficial

Response

Additional detail regarding potential impacts to EPBC Act-listed species is provided in several chapters of this supplementary EIS

Omitted flora and fauna records

Natura l History of Stra tha lbyn and Goolwa Distric ts (2000) (Stra tha lbyn Natura lists Club Inc ) and the Tolderol Wetland Management Plan Severa l submissions mentioned tha t the

c onta in information on a number of EPBC Act-listed species that have been recorded in fringing wetlands of the Lower Lakes but were not discussed in the EIS

Response

Natural History of Strathalbyn and Goolwa Distric ts (2000) and the Tolderol Wetland Management Plan may revea l EPBC Act-listed species that have been recorded in the CLLMM in addition to those mentioned in the draft EIS However given the current disconnection of the wetland habitats of the area and the predicted absence of any impact of the temporary weir upon their water regime the temporary weir is not anticipated to cause a significant impact upon the wetland-dependent species of the fringing wetlands of the Lower Lakes

A more thorough examina tion of the litera ture foc ussing on the

Supplementary EIS for the temporary weir near Pomanda Island -37shy

Definition of keystone species

Severa l submissions a rgued tha t the term keystone spec ies had been misused in the Dra ft EIS It was argued that all species that are critical to food chain processes in the Lower Lakes (ie keystone species) should be identified and discussed and that conceptual models detailing the importance of these key biota would help the reader to understand the processes

Response

The Ecological Character Description (ECD) for the site (Phillips and Muller 2006) describes the keystone species of the CLLMM The draft EIS uses the same language and examples of keystone species as does the ECD Correcting an incorrect ECD is beyond the scope of the EIS

Species considered of particular significance

One submission argued that Murray Hardyhead Yarra Pygmy Perch and Murray Cod should be on the partic ula r signific anc e list

Response

list (Section 7-5 of the Draft EIS) The impact of the temporary weir upon these species is examined in Chapter 13 of the Draft EIS

Murray Hardyhead Yarra Pygmy Perc h and Murray Cod a re on the partic ula r signific anc e

Adequacy of description of different wetland types

A number of submissions argued that the ecological information regarding each of the 15 wetland types of the CLLMM was inadequate to assess impacts of the temporary weir upon them

Response

The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170mm occurs only during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD is not a direct impact of the temporary weir and thus is beyond the scope of the draft EIS

Regional importance of the Coorong Lower Lakes and Murray Mouth

It was noted in several submissions that the Chowilla Ramsar wetland has been disregarded as it is greater than 200km from the Lower Lakes and Coorong The EIS needs to consider the regional implications of a degraded Lakes and Coorong and the use of aquatic habitats by migratory bird species If environmental water is not being delivered to the Lower Lakes and Coorong provision for suitable aquatic habitat needs to be made in other areas of the state as a minimum

Response

The proponent notes that both the CLLMM and Chowilla Ramsar sites are regionally significant and that adequate inflows to maintain the ecological character of both are required This issue is outside the scope of the Draft EIS

Australia s Ramsar obligations

A number of submissions raised the issue that Australia does not appear to be committed to wise use of the Coorong and Lakes Alexandrina and Albert Ramsar site and its obligations

under the Ramsar Convention in terms of proposing that this temporary weir be built

Response

The principal factor impacting on the Ramsar site is the low flow of freshwater to the site particularly over the last few years of drought and over-allocation across the Murray-Darling Basin ra ther than a lac k of c ommitment to wise use

Supplementary EIS for the temporary weir near Pomanda Island -38shy

6 Notes on significant issues outside the scope of the draft EIS

For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities

Notes on social and economic issues raised in submissions

In this section a number of significant concerns and ideas detailed in submissions by individuals organizations and local government are canvassed

These concerns and ideas do not focus on Matters of NES protected under Part 3 of the EPBC Ac t and as suc h a re outside the sc ope of Guidelines for the Content of a Dra ft Environmenta l Impact Statement on the Proposed Temporary Weir at Pomanda Island near Wellington South Australia Environment Protection and Biodiversity Conservation Act 1999 (Reference Number 2007 3484) da ted 30 August 2007

However they are registered here because they reflect strong community positions

These concerns and ideas will be taken into consideration during the development of the long term plan for the Coorong Lower Lakes and Murray Mouth region The first step in developing the long-term plan was the release of the Directions for a healthy future document for public c omment during May 2009

Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

One submission raised concern that Ngarrindjeri People has to compete for attention in the consultation process

An additional concern is that the Ngarrindjeri People is not recognised as Traditional Owners

The Coorong District Council emphasized that the Coorong and Lower Lakes have particular significance to the Ngarrindjeri and

Another submission (supported by the River Lakes and Coorong Action Group) stated tha t the Dra ft EIS d isp lays little or no understand ing of the importanc e of c ultura l flows to the Ngarrindjeri

Social and economic issues

A number of submissions noted the lack of content in the Draft EIS on social and economic measures associated with the temporary weir

Generally submissions from individuals organizations and local government indicate that the current social and economic conditions in the Coorong Lower Lakes and Murray Mouth area (as a result of drought lack of fresh water River flows and over allocation of water resources across the Murray-Darling Basin) are very negative When putting forward these concerns submission writers did not usually make clear how the construction of the temporary weir will further contribute to enhancing negative social or economic trends

A submission from the Southern Alexandrina Business Association Inc claims that the boating industry in the region under current conditions is losing $200 million per annum

A detailed submission from the Boating Industry Association of SA Inc claims that business of the leisure tourism and recreational sector and those that support them are suffering enormously from the existing droughtover allocation conditions The

Supplementary EIS for the temporary weir near Pomanda Island -39shy

submission proposes that we need to replenish water stocks including water for the environment Water for the Community and water for the EconomyTertiary Sector

The Rural City of Murray Bridge is concerned that professional fishermen can move up and down the River

The Coorong District Council notes that the dairy industry irrigated horticulture fodder production and beef cattle production have been negatively impacted by lack of access to water Property values have declined by 50 per cent in some cases and most of the 17 dairies in the Coorong District have closed or relocated Council rate revenue is down and

One submission (endorsed by other submission writers) provides a researched and extensive argument about the predominance of contemporary social and economic ideas which favour growth for example of expansionary plantings of a variety of unsustainable crops and growth of human populations and notes the South Australian population expansion in the South Australia Strategic Plan The writer suggests that new ideas about limitations and replenishments are required as well as a move towards adoption of tools like the Genuine Progress Indicator rather than reliance on indicators like Gross Domestic Product

Climate change

One submission asked for a rethink of the Draft EIS based on additional scenarios to the d rought sc enario whic h preva ils in the d ra ft EIS This sc enario is based is the worst

case climate scenario to date

Dust and health

A number of submissions raise concerns about current health problems caused by excess dust being blown from the dry lake bed

Other themes

A number of submissions a rgued tha t the temporary would nec essarily bec ome permanent and some of these argued that a navigable Lock with fish passages would therefore be preferable

A number of submissions argued for a seawater solution rather than a limited inflow to control the possible risks associated with ASS

Some submissions especially from government agencies or Non Government Organisa tions (NGO s) pointed out tha t further approva ls will be required in add ition to those cited in the Draft EIS The MDBA advised that it will require at least six weeks to undertake its approval processes from the time that the additional details are provided On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

Supplementary EIS for the temporary weir near Pomanda Island -40shy

7 Suggested text changes errata additions clarifications and

references

Page Issue raised by submission(s)respondent(s)

Recommended changes

vi Page vi acid sulfate soils box last sentence should read See Chap ters 6 8 11 and 15 for d eta ils

Make suggested changes

115 Pg 1-16 section 152 Environment Protection Act 1993 The Environment Protection (Air quality) Policy could also be included in this section as it applies to potential dust and noise impacts

Reword sentence 1 paragraph 1 section 152 page 115 to read

The Environment Protection Act 1993 (the Environment Protection Act) and the Environment Protection (Air quality) Policy provide legislation for the protection of the environment and the establishment and definition of the powers and functions of the Environment Protec tion Authority (EPA) in South Austra lia

116

12

27

Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

Apparent inconsistency in water usage figures between Table 1-1 and pages 2-4 and 2-12

Pg 2-7 section 24 Red uc ed ra infa ll and

dec rea sed evapora tion should be increased evaporation (many of these inconsistencies throughout document)

Reference to Section 1554 should be changed to Section 15412 Acid Sulphate Soils Safeguards and Mitigation Measures and Table 15-6 titled Potential mitigation measures to manage acid sulphate soils

Appendix 1 question 91 provides clarification

Page 27 rep lac e text Red uc ed ra infa ll and d ec rea sed evapora tion with text Red uc ed ra infa ll and inc reased eva p ora tion

Supplementary EIS for the temporary weir near Pomanda Island -41shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

27 Issues raised concerning the accuracy of the data in Table 23 page 27

Update Table 2-3 to include the following

200607 Inflows

Total flow at the SA Border 1436 GL

Eastern Mount Lofty Ranges estimated inflow 39 GL

200607 Use and Loss

Net Loss(1) 1262 GL

SA Water pumped extraction(2) 245 GL

Irrigation Extraction(3) 377 GL

Total System Deficit -448 GL (4)

(1) Net loss is inclusive of evaporation seepage rainfall EMLR inflows unmetered diversions

(2) SA Water pumping from the River Murray includes 60 GL of water pumped to the MLR reservoirs for use in 200708

(3) note as in document

(4) Deficit is defined as Inflow at SA Border - losses - SA Water pumping - irrigation extraction and corresponds with the fall in water level in Lakes Alexandrina and Albert

2-13

213 219

215

References to 696 GLyr of dilution flow should be clarified

2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Pg 2-15 section 26 Current water level statement (-05m AHD) was incorrect at the time of EIS publication and should be updated and referenced

Appendix 1 questions 9 and 88 provide clarification

Reference to 940 GL on pages 213 and 219 should be changed to 896 GL

The water level in Lake Alexandrina is now at a new record low of -095 m AHD (reference Murray Darling Basin Authority Murray River System Drought update issue 18 APRIL 2009)

The MDBA drought upd a te sta tes tha t During winter in the absence of significant inflows reduced evaporative losses should allow the water level to remain fairly steady and even under a worst case scenario Lake Alexandrina is unlikely to reach the estimated acidification trigger of -15 m AHD prior to February 2010

Supplementary EIS for the temporary weir near Pomanda Island -42shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

215 The salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences

Delete Table 2-4 from the document It is not referred to in the text and therefore serves no purpose Add following text to section 26 para 3

Historic a lly Lake Alexand rina wa s a p red omina tely freshwater system with only brief periods of seawater intrusion during low outflow periods that did not extend beyond Point Sturt (Sim and Muller 2004) DEH is in process of contracting more work to The University of Adelaide to verify this understanding of the pre-European salinity regime of both Lakes Alexandrina and Albert by studying diatom species distribution in dated cores It is predicted that by May 2009 water in the Lake is expected to be at ~6000 EC (Figure 2-11) which is considered to be saline in terms of ecological func tiona lity (Williams 1986)

2-16 11-9 Section 1554 does not exist

The reference to section 1554 should read section 15412 Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant

334 Pg 3-34 Environment Protection (Water Quality) Policy 2003 The Environment Protection (Water Quality) Policy 2003 should be listed under legislation rather than policy section of this table

337 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

337 Pg 3-37 Table 3-5 The National Water Quality Management Strategy should be included in Table 3-5 as this is tool that is being utilised in this region for integrated catchment management to achieve improved water quality outcomes

349 Pg 3-49 Table 3-9 ASS and water quality the Centre for Water Research model should be grouped under this section together with EPACSIRO

4-4 Details and status of SA Water Corporation pump station upgrades

Update Table 3-4 beginning page 331 such that Environment Protection (Water Quality) Policy 2003 is listed under South Austra lian Leg isla tion instea d of und er Sta te Polic y and Pla nning Frameworks

In Table 3-5 Page 337 and anywhere else in the doc ument it is mentioned d elete referenc e to Na tiona l Ac tion Plan (NAP) and rep lac e with Caring for our Country (CFC)

Include National Water Quality Management Strategy in Table 3-5

In Table 3-9 inc lud e Centre for Wa ter Researc h a long with EPA CSIRO in row 3 c olumn 3

Upd a ted sta tus d eta ils of SA Wa ter Corp ora tion s pump station upgrades are provided in Appendix 1 question 14

Supplementary EIS for the temporary weir near Pomanda Island -43shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

442

5-8

510

517

61

Page 4-8 sta tes Costs for undertaking a similar ac tion for Ad ela id e s off takes from the Lower Murray are expected to be very significant (see table 4 3) and the implementation period would be approximately 3 yea rs from initia tion

58 states that once the water level exceeds +01m AHD the temporary weir will cease to serve any useful function

The last paragraph in section 542 should be rep la c ed with The fina l most viable solution may involve multiple rock types from multiple sources to achieve the optimum construction cost within the limited time frame Rock sources with clays fine silts and sands while suitably geotechnically may not be utilised to reduce the potential for environmental impact through turbidity and sedimentation

Insert the following for Section 563 Section 563 of the draft EIS only partially refers to the environmental safeguards and mitigation measures Section 563 should be ignored and Chapter 15 be referred to for safeguards and mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Management Plan (EMP)

Paragraph 1 page 6-1 needs to include rainfall on the Lakes as an input to the system

Delete reference to Table 4 3 from the document

Appendix 1 question 52 provides clarification

Page 510 make suggested changes

At the end of section 563 page 517 add the sentence

Chap ter 15 should b e referred to for sa feguard s a nd mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Ma nagement Pla n (EMP)

Reword sentence 2 paragraph 1 page 61 to read

Freshwa ter from the River Murray the Eastern Mount Lofty Ranges (EMLR) catchments Upper South East (USE) drainage scheme direct rainfall onto the lakes and from groundwater as well as salt water from the Southern Oc ea n a ll input to the Coorong a nd Lower Lakes site

Supplementary EIS for the temporary weir near Pomanda Island -44shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

61 Last paragraph of 61 needs to include a further condition in the list - that of the MDB before the advent of white people as that is the condition that has determined which species live amp belong here

For the sc ope of the d ra ft EIS the baseline c ond itions of the CLLMM are those that existed when the site was listed as a wetland of international significance under the Ramsar convention These conditions are discussed in the Ecological Character Description (ECD) for the site (Phillips and Muller 2006) The draft EIS correctly uses the ECD as a baseline regarding condition It should be noted that many parameters that describe the conditions of the CLLMM are currently beyond the acceptable limits of change as outlined by the ECD due to drought and over-allocation of water

63 Issue raised concerning wording of paragraph 4 page 63

63

65

Issue raised concerning impact of static water levels page 63

Issue raised concerning Barra ge Opera tion Page

65

Change text in paragraph 4 p 6-3 to read

Aquatic vegeta tion has sinc e declined due to static water levels such that only a fringing band of vegetation around the +03 to +06 m AHD water marks remains of the extensive submerged and emergent beds that extended several kilometres into the Lakes pre-European settlement (Sim and Muller 2004)

Remove first bullet point under Figure 6-1 d egra d ed shorelines in sheltered a rea s

Add text below as a new fourth and fifth paragraph under barrage operation (p 6-5)

The b a rrages impede ec o log ic a l c onnec tivity between the fresh estuarine and more saline parts of the Ramsar Of particular concern are the adverse impacts on fish migration and transfer of recruits from one part of the system to another Fish passages have been installed on some gates to facilitate fish movement during periods of barrage opening and the Barrage Operating Strategy seeks to optimise ecological outcomes with each barrage release

The Lower Lakes barrages have not been opened since October 2006 thus there has been no hydrological connectivity between the fresh and estuarinesaline a rea s of the Ramsar site sinc e then

66 Issue raised concerning Ripa ria n La nd

Ma nagement page 66

Add text below as second paragraph under Riparian land management (p6-6)

Inva sion of pest p la nts a nd a nima ls into the wetland s is also a major issue particularly given the close proximity of the agricultural land and the large expanses for wind and water borne weed s to b e d ispersed

69 Issue raised concerning keystone species listed on page 69

Change text in second bullet point under the keystone species for freshwater lakes include (p 6-9) to read

Assemb lages of emergent p la nts (eg Sc hoenop lec tus sp Baumea sp Phragmites australis) along the fringes of the lake and EMLR tributa ries

Supplementary EIS for the temporary weir near Pomanda Island -45shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

610 Issue raised concerning list of factors that influence aquatic plants bottom of page 610

Reword the statement at the bottom of page 6-10 of the Draft EIS with the following

Ganf (2000) identified four issues influenc ing the productivity distribution and community composition of macrophytes

salinity

turbidity

water regime and

wind and wave action

These factors combined mean that submerged aquatic plant growth is restricted to the littoral zone of the mod ern lake environment (Phillip s and Muller 2006)

612 Issue raised concerning wording of caption for Figure 66 page 612

612 Issue raised concerning section 63 page 612

614 A Respondent questioned page 6-14 section 65 of the Draft EIS determinants or drivers

72 73 Bool amp Hacks Lagoons are not upstream of this temporary weir as is implied in the text

74 Page 7-4 section 733 An error messages appears

75 736 Type M permanent rivers streams amp creeks -Lake Alexandrina also takes the flow from the Rivers Angas amp Bremer amp Mosquito Creek between Milang amp Langhorne Creek

Pg 6-12 Figure 66 c ap tion should rea d d rivers a nd levers (not d rivers and levels )

Section 63 shy Pg 6-12 Include the following text as sentence 2 of paragraph 3

Direc t ra infa ll on the lakes a nd evapora tive losses a re key components of local climate that have the potential to impact greatly on the resultant water reg ime of the site

Sec tion 65 first p a ra graph rep lac e The p rima ry d rivers for ecological character includ e with The p rima ry determinants of ecological character are (Phillips and Muller 2006)

Reword sentence 1 paragraph 2 section 73 page 72 as follows

Banroc k Sta tion Wetla nd Complex Riverland wetla nd s and Hattah-Kulkyne Lakes are located more than 200 km (minimum) upstream of Pomanda Island and are unlikely to be a ffec ted by the temporary weir

Following sentence 1 add additional sentence

Bool and Hacks Lagoons are located outside of the MDB and over 200 km from Pomanda Island and will therefore b e una ffec ted b y the temp ora ry weir

Rep la c e text Error Referenc e sourc e not found With text Figure 7-2

The Rivers Angus and Bremer and Mosquito Creek are classified as wetland Type N -seasonalintermittentirregular riversstreams and creeks These tributaries should be referred to in Section 737 of the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -46shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

731 756 Plant associations in close proximity to the temporary weir Only one of the 11 dot points is actually a plant association

Reword the sentenc e The p lant a ssoc ia tions in c lose p roximity to the temp ora ry weir site inc lud e to read

The d ominant or c o-dominant plant species in close proximity to the temp ora ry weir site inc lud e

Replace dot point Muehlenbeckia florulenta tall open shrub land with Phra gmites a ustra lis with two d ot points

Muehlenbec kia florulenta

Phra gmites austra lis

732 Page 205 - Table 7-6 should be checked for accuracy Cattle Egret is not EPBC listed migratory species

According to the EPBC Act website Cattle Egret is a listed migratory species therefore its listing in Table 7-6 is correct See

httpwwwenvironmentgovaucgishybinspratpublicpublicspeciespltaxon_id=59542`

Chapters 4 and 9

101

102

102

Text in the executive summary chapters 4 and 9 erroneously includes the use of toxins when the intended meaning is in fact toxicants Toxins are substances produced by living cells such as algal toxins etc whereas toxicants are a broader range of chemicals that produce a toxic response in living organisms

Correct the assertion in 102 Existing drought conditions that the dropping of Mungkuli (Lake Alexandrina) to below sea level for the first time in 7500 years is due to drought

Chapter 10 - Figure 10-1 -Lake Alexandrina water level 1962-2008 Full supply level = +075m AHD - EIS is incorrect

Tookayerta Creek is a tributary of the Finniss River and not Lake Alexandrina as stated Further the Finniss River and Currency Creek flow into the Lower Murray not into Lake Alexandrina

Delete the word toxins from c ha p ters 4 a nd 9 and rep la c e with the word toxic a nts

Change sentence to read

In rec ent times the wa ter level in the River Murray Coorong and Lower Lakes has been significantly lowered by the existing drought conditions and over-allocation of water associated with the entire MDB (Table 10 1)

It is the proponents understanding that +075 m AHD is referred to as full sup p ly level and tha t wa ter levels above this a re referred to as a surc ha rge

Reword sentenc e The EMLR tributa ries tha t d isc harge into Lake Alexand rina a re to read The EMLR tributaries that discharge into Lake Alexandrina and the Lower Murray a re

Delete d ot point Tooka yerta Creek from the bottom of page 10-2

Reword d ot point Finniss River to rea d Finniss River (inc lud ing Tookayerta Creek)

Supplementary EIS for the temporary weir near Pomanda Island -47shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

104

1013

1030

1030

Figure 10-3 Goolwa amp Lake Alexandrina Salinity Survey results - September 2008 EIS in error re the salinity level of Lake Albert This figure 10-3 states that 7300EC (which is approx

sea wa ter) is semi-saline

1035 - Predicted water level in Lake Alexandrina -water levels are also affected by rainfall which is not mentioned

To say that potable water supply is less than 2500EC is pushing the boundaries PIRSA documents state a salinity of 1000mgL (1666EC) is generally palatable to most tastes but up to 1500mgL (2500EC) can be acceptable in areas where better quality water is not available

The tolerable salinity limits for freshwater species needs to take into account peak levels not average levels

The d efinition of semi-sa line is p rovid ed in Tab le 2-4 of the draft EIS and refers to salinities between 5001 and 11666 EC Thus the document is consistent

Reword first sentence of Section 1035 as follows

Historic a lly wa ter levels in La ke Alexand rina have varied on a seasonal basis with water rising in winter through increased winter inflows direct rainfall and decreased evaporation and falling in summer through red uc ed inflows a nd inc reased eva p ora tion

This point is noted however it has no bearing upon the temporary weir since salinities in Lake Alexandrina are predicted to reach gt2500 EC throughout the lake during 2009 with or without the temporary weir

In Section 1043 (page 10-30) delete paragraph 3 since it has no biological or ecological relevance Revise paragraph 4 to read

Pea k or maximum sa linities a re most important ecologically because all aquatic species have salinity tolerances that if exceeded even briefly can be fatal Table 10-9 presents modelled peak salinities at points in Lake Alexand rina und er without weir and with weir scenarios during the first year of weir operation For all points modelled peak salinity in the first year is higher und er the with weir sc ena rio

10-32 Reference to 685 GL as extra water available is misleading

Agreed Clarified in Appendix 1 question 32

Supplementary EIS for the temporary weir near Pomanda Island -48shy

a ns

Page Issue raised by

submission(s)respondent(s) Recommended changes

1113 Pg 11-13 Figure 11-5 This graph could be updated to 2009 using current EPA data

Update Figure 11-5 on page 11-13 with the following which includes the most recent data

Turbidity Lake Alexandrina - Poltalloch Plains

20

40

60

80

100

120

140

160

180

200

24-Jul-98 6-Dec-99 19-Apr-01 1-Sep-02 14-Jan-04 28-May-05 10-Oct-06 22-Feb-08 6-Jul-09

Date T

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id it

y (N

T U

)

Lake Alexandrina - Poltalloch pl i Ecosystem protection guideline (ANZECC)

0

121 Section 121 It is certain that the temporary weir will interact with ecological values of lower river amp lakes

121 Pg 12-1 section 122 Bottom of page 12-1 In general temporary wetlands have few animal species than permanent ones is this referring to abundance or richness or what Too general and incorrect in some circumstances

122 Chapter 123 - Ramsar listed wetland upstream of expected weir site near Pomanda Island - EIS incorrect amp needs amendment

Delete the word may from sentenc e 1 p a ra grap h 3 section 121 page 121

Bottom of page 12-1 delete the following sentenc e In general temporary wetlands have fewer animal species than p ermanent ones

On pg 12-2 rep lac e the text There a re no Ra msar-listed wetla nd s between Loc k 1 a nd the temp ora ry weir site with the following There a re no Ramsa r-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ra msar site

Supplementary EIS for the temporary weir near Pomanda Island -49shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

125 Issues raised concerning wording of Table 123 commencing page 125

In Table 12-3 make the following changes

For Cla ss M ad d text to sixth c olumn Inc reased hea d pressure may result in increased drainage to the lakes and reduced groundwater baseflow in groundwater depend ent ec osystems

For Class M seventh column change existing sentence to read there is no interac tion of the weir with the surfa c e wa ter in these wetlands

For Class M add sentence to third column that reads Inc reased head p ressure of up to 21 c m may result in

c hang e in ground wa ter b a seflow

For Cla ss 4 und er Imp a c t of p roposed tempora ry weir within Ramsar wetla nd s to existing text ad d whic h oc c urs a t wa ter levels gt 087 m AHD

For Cla ss Xf und er Existing c ond ition (a p p roxima tely shy05 m AHD) rep la c e No rec ord ed c ha nge with Not connected to the main body of the lake Will only be a ffec ted b y ongoing d rought

For Cla ss Tp c hange text in sixth c olumn to read Most disconnected but some reconnection and marginal improvement from winter ra infa ll and tributa ry inflows

Formatting issue in title of sixth column the negative is there in the column heading but there has been line split between it and 15 so it looks like +15 m AHD not -15 m AHD (should be latter)

1215 Issue raised concerning wording of Section 125 page 1215

Reword Section 125 (pg 12-15) in its entirety to read

As d eta iled in Sec tion 1241 a ll wetland hab ita ts downstream of the proposed temporary weir location are expected to be affected by the drought and by 2012 only Ramsar-wetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flows as described on page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

1216 Issue raised concerning potential positive impact of rewetting of acid sulphate soils

Section 1251 page 1216 remove reference to re-wetting of acid sulfate soils and pH drop to 2 (last dot point) from positive impacts list

Supplementary EIS for the temporary weir near Pomanda Island -50shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

12-20 Table 12-4 only lists predicted changes for 2 out of 6 primary determinants of ecological character

Update Table 12-4 to include the following

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts

(2010 2012)

Salinity Discussed extensively in Section 10

Water Level Discussed extensively in Section 10

Water Regime Discussed extensively in Section 10

Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

1310 Issue raised concerning comprehensiveness of Table 133 page 1310

To Table 13-3 insert two additional rows

1st c olumn Intera c tion 2nd c olumn Disrup t d ispersa l of tadp oles

1st c olumn Spec ies p referenc e 2nd c olumn Present upstream and downstream of site but dispersal requirements of d ifferent p op ula tions a re unknown

141 Section 141 What is the definition of regularly recorded amp by whom were they recorded

In sec tion 141 p a ge 141 p a ragraph 4 rep lac e (see Chapter 7) with (Letc h 2007)

1519 pg 15-19 section 15412 Performance criteria The acid sulfate soil trigger levels are given in Table 15shy6 not Table 15-5 as stated in the document

In d ot p oint a t bottom of page 1519 rep lac e Tab le 15shy5 with Tab le 15-6

1519 Remove Table 15-5 There are no cross-references to the table

Table 15-5 is referred to on page 1519 and should be retained in the document

162 The summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Additional comment o be inserted in Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir) after text

The ECD of the Coorong and Lakes Alexa nd rina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Nationally listed threatened and migratory species are addressed elsewhere in this table Other species are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetla nd s will persist

Supplementary EIS for the temporary weir near Pomanda Island -51shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

Throughout document

Throughout document

Throughout document

Australia operates on SI system of measurements amp this includes the millimetre metre units of measurement amp does not include centimetres

Convert centimetres to millimetres or meters as appropriate throughout the document

Correct injustice throughout draft EIS of identifying Ngarrindjeri merely as custodians community or people (112 164 165 171 1522)

Cha nge Ngarrind jeri c ustod ians and Nga rrind jeri c ommunity to Ngarrind jeri Peop le as ap p ropria te

throughout the document (as per submission PTW00046)

Text in the executive summary and throughout the document (chapters 1 2 4 8 11 12 13 15 and 16) refers to the use of the wording heavy metals when in fact this is misleading and should simply be referred to as metals

Rep la c e a ll referenc es to hea vy meta ls with meta ls

Supplementary EIS for the temporary weir near Pomanda Island -52shy

References

Bice C and Ye Q (2009) Draft Report - Risk assessment of proposed management scenarios for Lake Alexandrina on the resident fish community South Australian Research and Development Institute (Aquatic Sciences) Adelaide South Australia

DWLBC (2009) River Murray Data Department of Water Land and Biodiversity Conservation Adelaide South Australia httpdatarivermurraysagovau

Wellington Weir Site Flora and Fauna Assessment (South Australian Water Corporation Adelaide South Australia) Ecological Associates (2008) Draft Report

Ganf G G (2000) Aqua tic and ripa rian vegeta tion in A Jensen M Good P Harvey P Tuc ker amp M Long (eds) River Murray Barrages Environmental Flows An evaluation of environmental flow needs in the Lower Lakes and Coorong report to MDBC pp 30 34

Khan M T Khan T A and Wilson M E (2004) Habitat use and movement of river blackfish (Gadopsis marmoratus R) in a highly modified Victorian stream Australia Ecology of Freshwater Fish 13(4) 285-293

Lintermans M (2007) Fishes of the Murray-Darling Basin An introductory guide Murray-Darling Basin Commission Canberra ACT

Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks (Oxford University Press Melbourne)

Williams WD (1986) Conductivity and salinity of Australian Salt Lakes in Australian Journal of Marine and Freshwater Research 37177-182

Supplementary EIS for the temporary weir near Pomanda Island -53shy

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA)

General comments

1 Lots of inconsistencies particularly in figures Several of these are the result of some sections of the EIS having been updated to reflect the current environmental conditions but not others however some are just contradictions

Response Inconsistencies are corrected in the Supplementary EIS

2 In general at -15m AHD many wetland types will have already disconnected so the weir will not cause further impacts but it will slow down any potential recovery from drought impacts Please discuss and quantify these implications

Response The temporary weir will cause a 17cm drop in Lake Alexandrina water levels during the weir pool filling period under modelled worst-c ase sc enario however in the longer term there is little difference in the water levels and salinity values between weir and no weir sc enarios Quantific a tion of the amount of wa ter tha t would be

needed to refill desiccated Acid Sulfate Soils remains a knowledge gap that could be filled through field trials

3 There is a general lack of detail on what measures will be used to mitigate impacts on species (eg on pg 13-6 it says measures should be taken to ensure the wetland vegeta tion and assoc ia ted c ommunities a re not c ompromised without going into any further detail) Please review any proposed measures and provide details and commitments to undertake measurable actions

Response Detailed measures will be written in the CEMP OEMP and DEMP by SA Water The d ra ft EIS EMF and EMP outline wha t SA Water s EMP s should add ress

expec ted etc Please clearly state where you are committing to do something A table showing actual commitments would be useful

4 Vague and uncommitted language throughout the whole document

Response The South Australian Government is committed to the following actions in relation to the weir near Pomanda Island

Development of a CEMP OEMP and DEMP and submission of the EMP to relevant authorities including the SA EPA prior to any works being undertaken Incorporation of a fishway to suit large and small species A detailed submission to the MDBA for approval under the Water Act 2007 (Cwth) On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure Mitigation strategies and monitoring program as detailed in the EMP and in the amended Table 15-3 (see question 5 below) o The CEMP will be based on a risk management framework and an

environmental impact assessment (EIA) o Monitoring of water quality will be included in a water quality report to be

made available through the SA EPA

Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth

A summary of all projects follows Projects highlighted in green are completed or currently underway Orange highlighted projects are those currently being investigated and are likely but not certain to be undertaken Pink highlighted projects are those either in the early stages of planning and may be difficult to implement or are considered only a last resort solution due to other undesirable implications

Supplementary EIS for the temporary weir near Pomanda Island -54shy

Project StatusTiming Completed or Underway

Pipelines Potable Lower Lakes districts Irrigation Langhorne amp Currency Creeks

Potable construction completed January 2009 Irrigation EPBC referral (20094743) not controlled action if undertaken in particular manner due for completion October 2009

Feasibility study Long term management plan for adaptive management

30 March 2009 - Version 1 - under review prior to public consultation May 2009 Public Consultation on Version 1 30 June 2009 - Version 2 August - public consultation on Version 2 30 September 2009 - Final

Lake Albert Blocking bank in Narrung Narrows Pumping from Lake Alexandrina Lake Albert Future paper Pumping ceases 30 June 2009 Bioremediation

Blocking bank completed in May 2008 Pumping began 02 May 2008 Expert workshop held 8 April 2009 Paper prepared On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from the end of June 2009 and that a bioremediation program will be instituted

Dredging Murray Mouth Ongoing almost continuous operation since October 2002

The Living Murray (TLM) Icon Site management Icon Site condition monitoring Modelling Indigenous partnership Communications and consultation Water bids

Coorong planning document completed TLM progress report sea level impact assessment and alternatives to keep Murray Mouth open underway Condition monitoring ongoing Monitoring methodology plan completed sent to MDBA Modelling Stages 1 2A completed 2B December 2009 Interim modelling results for LLCMM due June 2009 Indigenous partnership program ongoing

Regulators Goolwa Channel Mouth of Finniss River Mouth of Currency Creek

EPBC referral submitted for public notice on 6 April 2009 Initial closure of the regulators 17 July 2009 Commencement of pumping water from Lake Alexandrina to Goolwa Channel 17 July 2009 Practical completion of the regulator within the Goolwa Channel 17 Sept 2009

Assessment of acid sulfate soils Rapid Risk Assessment Lock 1 to Wellington

Fieldwork for both completed Laboratory analysis underway completed for 24 priority wetlands below Lock 1 Survey work and modelling undertaken on inlets to 24 priority wetlands below Lock 1 Identification of priority sites creation of an action plan and application for funding underway

Lower Murray Reclaimed Irrigation Areas (LMRIA) Program

Completion of Program by June 2009 Completion of all mandatory works achieved 2008 Non-mandatory works nearing completion Post-program review to be instigated in near future

Upgrade of Pomanda Peninsula Causeway

EPBC Referra l not a c ontrolled ac tion 23 January 2009 Works currently underway in preparation should it be necessary to construct the temporary weir

Currently Being Investigated

Mitigation of acid sulfate soils using Mulch Revegetation Liming

Trials for all three currently underway Large scale application dependent on trial results and acidification time of the lower lakes

Supplementary EIS for the temporary weir near Pomanda Island -55shy

Project StatusTiming Increase inflows to Coorong South Lagoon REFLOWS Upper South East Drainage scheme (USED) water via Salt Creek Fairview Drain link

REFLOWS funding available REFLOWS cultural heritage underway REFLOWS native vegetation assessment almost complete REFLOWS landholder consultation complete REFLOWS community perceptions survey complete USED second stage feasibility study due 30 June 2009 USED 3 to 4 years to investigate and then implement Fairview initial landholder engagement commenced on hold until Reflows and Bald Hill decision made

Temporary Weir near Pomanda Island Draft EIS released for public consultation Supplementary EIS in progress Construction works to begin if Lake Alexandrina levels drop to -15 m AHD Could be avoided if sufficient freshwater flows obtained Early Planning Stages

Salinity build up in Coorong South Lagoon Dredging between north south lagoons Pump hyper-saline water to ocean

Both under preliminary investigation Pumping could only be done during autumnwinter to allow flows to replace pumped out water hence may not happen till 2010

Seawater intrusion into the lower lakes As a last resort to mitigate acid sulfate soils

EPBC referra l (EPBC 2008 4618) c ontrolled ac tion requiring EIS The final guidelines for the EIS released 13 March 2009 EIS targeted September October 2009

The projects can be divided into three categories

1 Long term plans looking to address the bigger picture with sustainable solutions Projects such as

Potable pipelines around lower lakes districts Irrigation pipelines Langhorne and Currency creeks Feasibility StudyLong Term Plan for Adaptive Management for CLLMM Lake Albert Future paper The Living Murray (TLM) programs Lower Murray Reclaimed Irrigation Areas (LMRIA) Program REFLOWS Upper South East Drainage scheme (USED) water into the Coorong via Salt Creek and Fairview Drain to Coorong link

2 Emergency measures designed to mitigate urgent issues with severe impacts Most are not long term and are designed to address a specific issue

Blocking bank in Narrung Pumping from Lake Alexandrina to Lake Albert2 Dredging Murray Mouth Goolwa Channel regulator Finniss River low level regulator Currency Creek low level regulator Pump water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel Rapid Risk Assessment of acid sulfate soils Assessment of acid sulfate soils from Lock 1 to Wellington Mitigation of acid sulfate soils

2 On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -56shy

o Bioremediation using mulch o Bioremediation using revegetation o Liming of exposed lake beds and o Liming of inflows

Salinity build up in Coorong South Lagoon o Dredging between north south lagoons and o Pump hyper-saline water to ocean

3 Last resort emergency measures only to be undertaken at critical trigger points when all other alternatives have been exhausted

Temporary weir near Pomanda Island Seawater intrusion into the Lower Lakes

Further details on each project are available if required

5 In several places throughout Chapter 15 monitoring is proposed as a mitigation measure by itself monitoring does not mitigate an impact it can only help inform when to implement a mitigation measure Please provide an actual mitigation response linked to monitoring

Response The Environmental Management Plan in Chapter 15 of the Draft EIS has been augmented in the Supplementary EIS SA Water is responsible for preparing the CEMP OEMP and DEMP Environmental Management Plan that will detail the mitigation strategies and monitoring program This will be written in conjunction with the contractor

SA Water will be responsib le to ensure tha t the c onstruc tion c ontrac tor s EMP inc ludes adequate monitoring protocols for water quality and other environmental issues throughout the construction phase The EPA DWLBC SA MDB NRMB NVC local council and other relevant agencies will be consulted on the content of any environmental risk assessment and mitigation measure In addition specific State approvals will be obtained these usually stipulate specific conditions to be included in an EMP or similar management tool

The Contractor EMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

See also 80

Table 15-3 has been amended

Table 15-3 Potential mitigation measures for water quality parameters

Project PhaseParameter Potential mitigation measure

Co

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Develop and implement a Soil Erosion and Drainage Management Plan in accordance with the Stormwater Pollution Prevention Code of Practice for Local State and Federal Government

Works are expected to be planned and carried out to minimise the effects of runoff and erosion on the site and downstream areas

Surface water quality

Ensure that erosion and sediment control measures are in place prior to commencing any earthworks

Supplementary EIS for the temporary weir near Pomanda Island -57shy

Project PhaseParameter Potential mitigation measure

Co

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Op

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Sediment control structures are expected to be established around all areas prone to erosion including stockpiles batters and drainage lines Careful placementremoval of embankment material to reduce turbidity

Scouring mud waves and bank slump are a potential consequence of installation of the temporary weir Scouring and mud waves may be reduced by controlling flows and spillway width while area of impact associated with bank slump is expected to be reduced by weir design and careful placement of embankment materials

Use of sediment curtains around weir placementremoval to limit effects of turbidity created with placement of material and subsequent mud-wave Stabilisation of River banks immediately following constructiondecommissioning Treatments may include

Revegetation

Placement of geofabric

Obtain EPA Endorsement of the proposed approach to surface water

Exception to allow placement of fill material to create weir structure

Wetland management Develop and implement a Wetland Management Plan to manage the change in flow patterns resulting from the construction operation and decommissioning of the proposed temporary weir

Develop and implement a Groundwater Management Plan for the project

Groundwater

Groundwater is expected to be monitored throughout the construction operation and decommissioning phases of the temporary weir project

Groundwater parameters which may require monitoring include

Confined and unconfined water levels

Salinity

Hydraulic gradient

Supplementary EIS for the temporary weir near Pomanda Island -58shy

Project PhaseParameter Potential mitigation measure

Monitoring is expected to take place both upstream and downstream of the temporary weir

Existing monitoring programs which may be relevant include

DLWBC OBSWELL database

RMCWMB groundwater monitoring program

CSIRO Water for a Healthy Country

Obtain endorsement of the proposed approach to groundwater monitoring from DWLBC andor the EPA

Develop and implement a water quality monitoring program based on existing programs and monitoring stations

Monitoring

If water quality parameters are exceeded the following measures may be implemented

Increase use of geofabrics and turbidity curtains to address inadequacies in turbidity management

Cease work if turbidity if triggers are exceeded until such time as the triggers return to desired levels

Aeration should monitoring indicate that oxygen is required

Mixing to prevent temperature stratification of weir pool

Mixing aeration to prevent temperature stratification of weir pool

Co

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6 The extent of the Ecological Character (EC) of the Ramsar site is greater than the fringing Wetlands It includes the bodies of water in the lakes the species in on and above Although the individual aspects of the EC are mostly noted in the EIS the summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Response Additional comment o be inserted in Errata Chapter Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir)

The ECD of the Coorong and Lakes Alexandrina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Those species that are not listed nationally are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetlands will persist

7 Is it likely that the water body of Lake Alexandrina will acidify during the no-flow period given the drop in water level If so how does SA propose to manage this Does this mean that the weir closure period will bring the real time management strategy water level acidification trigger forward

Response See page 22 and 23 of the Supplementary EIS

Supplementary EIS for the temporary weir near Pomanda Island -59shy

The South Australian Government is investigating and implementing a range of acid sulfate mitigation measure including application of limestone and bioremediation The possible use of seawater is also being examined (EPBC Act reference 20084618 and an EIS is currently being prepared Introduction of seawater will only be undertaken if the temporary weir is in place the acidification triggers are reached and relevant approvals in place

Water quality monitoring in Lake Alexandrina (eg at -10 m AHD) indicates alkalinity is high (between 170 and 250 mgL as CaCO3) which means the water has relatively good buffering capacity depending on the transport of acidity (fluxes) from exposed sediments During periods of no flow pulses of acid can be transported to the water by rainfall or seiching (wave action) events However given that sulfuric materials have already formed over large areas the higher risk of acidification comes with refilling of the waterbody when mineral salts can be dissolved and acidic porewater can diffuse into the water column (note some research indicates this could occur with freshwater or saltwater ingress)

Management trigger levels for alkalinity and pH have been developed and trends are being monitored fortnightly If any of the trigger levels are approached (ie at different alert levels) the Government of South Australia will instigate certain actions such as monitoring at a higher frequency or implementing limestone slurry dosing programs

The biogeochemical modelling points to waterbody acidification at either a pH less than 6 or water levels below -15 m AHD Further refining of the modelling and investigations of sulfide oxidation rates and acidity transport are being undertaken and early indications are that waterbody acidification is more complex than relating it just to water level As such the weir closure period may not necessarily bring forward Lake Alexandrina acidification

8 The EIS states there will be a number of plans that do not appear to be available yet it is difficult to assess the effectiveness of mitigation without seeing these plans When will these be provided

Response Development of plans and actions is ongoing Response to 4 above lists many of these including the Long Term Plan Many plans have been provided to DEWHA as they are prepared

9 The EIS indicates that disconnection is likely to occur for 2-35 months even though under worst case scenarios it could be up to 7 or 8 months (Table 10-6) The EIS assessment is based on no flow period of 3 months Is the reason for this because SA is currently receiving 896GL over the border and they anticipate getting at least this amount in the 2009-2010 water year and subsequent years Or is there other justification for the reasons for using 25-3 month disconnection This difference in time period could change the likely impacts on hydrology and water levels which are key determinants of ec olog ic a l c harac ter DEWHA s assessment will take into ac c ount the worst case scenario

Response South Australia is now guaranteed a flow of at least 896GL during 2009-10 as the 200GL required for Critical Human Needs has already been secured and is held in reserve Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream The estimated time for disconnection for the 696 GL scenario is not relevant

The Errata chapter includes replacement of references to 940 GL with 896 GL on pages 2-13 and 2-19 of the Draft EIS

The time required to fill the weir pool from approximately -15m AHD to +01m AHD will be approximately 25 3 months If it is necessary to fill the weir pool more slowly (eg to minimise damage to upstream wetlands banks and levees) the flow at Lock 1 will not be reduced and any additional water will be delivered into Lake Alexandrina through a by-pass structure

10 As specified in 1(g) of the EIS Guidelines can you please detail the interaction between this action and others in the CLLAMM

Response Discussed at 4 above

Supplementary EIS for the temporary weir near Pomanda Island -60shy

11 In Part 3 of the EIS Guidelines you are required to take into account the long-term options for the CLLAMM While the Department acknowledges the actions that are being undertaken to develop a long term solution how will this action limit long term options

Response As discussed in the Supplementary EIS South Australia considers that the weir if constructed will not limit long term options Long term options are being actively planned in the knowledge that the temporary weir may be constructed

12 Section 11 of the EIS Guidelines require the objectives of the EPBC Act to be addressed Can you please provide further information addressing these objectives

Response The Draft EIS endeavoured to address the Guidelines for the Proposed Temporary Weir This Supplementary EIS supplements this by the addition of the community consultation report and a detailed review of issues raised

The response to question 4 details all related actions that the government is taking in the Coorong and Lakes Alexandrina and Albert Ramsar site including the development of a comprehensive long term environmental plan that shortly will be released for community consideration

Objects of the EPBC Act

(a) In the face of unprecedented environmental degradation of the Ramsar site and matters of national environmental significance caused by low freshwater inflows we are undertaking substantial conservation and remediation work involving many South Australian Government agencies These are outlined in the Supplementary EIS

(b) (c) (d) Further specific actions to conserve natural resources and bio-diversity are likely to be announced shortly in conjunction with the Australian Minister for Climate Change and Water It is expected that majority of these actions will be undertaken by local government the community land holders and the Ngarrindjeri People

(e) As the South Australian agency responsible for the Environment and Heritage and one of the custodians of the internationally listed Ramsar site the Proponent seeks to c oopera tively imp lement Austra lia s interna tiona l environmenta l responsibilities

(f) (g) The South Australian Government acknowledges the Ngarrindjeri People as traditional owners within the area of their current Native Title Claim within the context of the Aboriginal Heritage Act 1988 The Ngarrindjeri People collectively and individually have been consulted and given an opportunity to comment on the Draft EIS along with all other stakeholders and members of the c ommunity The State Government is endeavouring to develop a formal overarching agreement with the Ngarrindjeri in relation to consultation and negotiation on a range of environmental and cultural matters of joint interest

Work with Aboriginal people to manage biodiversity cooperatively and contribute to the reconciliation of past actions

Comments on ESD are included at question 25

More specific comments

13 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

Response Noted Corrected in Errata

14 On pg 4-4 it says that 3 of the 4 pumping stations are complete with only Murray Bridge to be completed but in Table 4-4 on the same page and on pg 2-3 it says Swan Reach is the only pumping station still to be completed

Response Mannum and Tailem Bend are complete Swan Reach was completed late December 2008 Murray Bridge has 2 pumps modified for lower water level operation but we are delaying some work on one pump at Murray Bridge in order to test it (unshymodified) in order to be better able to confirm the lower limit of operation

DEH s Corp ora te Plan inc lud es the objective

Supplementary EIS for the temporary weir near Pomanda Island -61shy

15 Orange-bellied Parrot sec tion 752 doesn t mention samphire hab ita t

Response Firstly in the history of documentation relating to this EIS on the preferred habitat of the Orange-bellied Parrot There appears to have been some confusion over the use of the words saltmarsh and samphire

Samphire is used interchangeably in South Australia to describe

a) species in the genera Sarcocornia and Tecticornia (formerly Halosarcia and Sclerostegia) and

b) habitat dominated by such species

Thus saltmarsh and samphire are interchangeable terms to describe the same habitat

Food plants associated with samphire (or saltmarsh) habitat are certainly known to be used as feeding habitat by the Orange-bellied Parrot in the lower lakesupper Coorong with recent records from this habitat from the Snake Pit (Tauwitchere Point) and Sir Richard Peninsula (Beacon 19) in recent years (06-08) predominantly from Sarcocornia

However it appears that within South Australia the Orange-bellied Parrot is less dependent than previously suspected on samphire vegetation Recent observations in South Australia (2003-) suggest that the species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

While most records are within 10km of the coast Orange-bellied Parrots were recorded in winter in the Tolderol area (north-western shore of Lake Alexandrina) between 1981 and 1985 (John Eckert sightings lodged with Birds Australia) and there is an anecdotal record of this species foraging in the Wellington area at Nalpa Station

In the referral for the Pomanda Island causeway (EPBC 4676) it is stated that the Causeway upgrade could at worst disturb less than 014 ha of samphire shrubland With 1289 ha of this habitat within the Ramsar boundaries the maximum loss of samphire species would be 001 In addition Ecological Associates (2008) identify that samphire species regenerate relatively quickly after disturbance

16 The Great Egret Cattle Egret and the Caspian Tern are not dealt with satisfactorily (pp 7-3334)

Response The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in SE Qld and NE NSW (HANZAB3)

The movements of Caspian Tern are poorly understood partly resident partly dispersive and possibly partly migratory (HANZAB1) The species is commonly observed on fresh and marine waters foraging on the wing for fish

17 The potential decommissioning impacts (pg 8-7) says tha t The impac ts a re expec ted to be further assessed during the planning for the decommissioning p rojec t as the

3 Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks Oxford University Press Melbourne

Supplementary EIS for the temporary weir near Pomanda Island -62shy

decommissioning is part of the referred action details will need to be provided to determine what the potential impacts are

Response The nominal design life for the temporary weir is 3 years and therefore not all impacts of the decommissioning are able to be assessed at this point in time For example it is difficult to be able to identify projects where the removed rock can be usefully employed

There a re no Ramsar-listed wetlands between Lock 1 and the p roposed temporary weir site however the Coorong and Lakes Alexandrina and Albert Ramsar site extends someway upstream of the weir site

18 On pg 12-2 the EIS sta tes

Response The Coorong and Lakes Alexandrina and Albert Ramsar site extends approx ten kilometres upstream of the proposed weir site (at the apex) to a point that represents the confluence between Lake Alexandrina and River Murray proper The relevant sentence on Pg 12-2 has been reworded to say There a re no Ramsar-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ramsar site

19 On pg 12-15 the EIS says tha t the weir will ac c elera te d rops in wa ter level during the period of d isc onnec tion however all the downstream wetlands will supposedly have already disconnected due to drought conditions with the exception of wetland type O whic h is not expec ted to d isc onnec t It is not c lear what period of d isc onnec tion is being referred to

Response The period of disconnection being referred to is the time during which there will be reduced flow over the temporary weir from the River Murray channel into Lake Alexandrina nominally 25 3 months (as discussed under question 9 and page 13)

Reword Section 125 (pg 12-15) in its entirety to read

As deta iled in Sec tion 1241 a ll wetland habitats downstream of the temporary weir location are expected to be affected by the drought and by 2012 only Ramsarshywetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state

Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flow see page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

20 Throughout Chapter 12 the EIS refers to impacts on EPBC-listed flora and fauna species only but it should be considering all flora and fauna within the Ramsar site

Matters of Na tiona l Environmenta l Signific anc e as a matter of p riority however implic it in the EIS and in our Ramsar obligations are the impacts upon all flora and fauna within the Ramsar site Tortoises and Japanese Snipe are good examples of non-threatened species that have been or are likely to be affected by altered hydrology or water quality There is an infinite list of taxa that could be considered in detail some of which we know little about but much of this work falls outside the scope of the EIS

Response The EIS foc uses on threa tened spec ies and

The EIS refers to Matters of NES (eg EPBC- listed flora and fauna) that will still be occupying Type O wetlands which will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir Impacts on other Ramsar Wetland Types (ie the rest of the Ramsar site) were not considered because the impacts of the drought were considered to be the primary determinants of change in ecological character for those wetlands Further discussed in Supplementary EIS

Pred ic ted c hanges to p rimary determinants of ec olog ic a l c harac ter ) only lists the p red ic ted c hanges for 2 out of the 6 p rimary determinants

21 Table 12-4 (titled

Response Update Table 12-4 to include the following

Supplementary EIS for the temporary weir near Pomanda Island -63shy

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts (2010 2012)

Salinity Discussed extensively in Section 10 Water Level Discussed extensively in Section 10 Water Regime Discussed extensively in Section 10 Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

22 Sec tion 127 (Summary of Chapter 12) doesn t summarise the impac ts as a result of the weir only the impacts from the drought

Response Discussed in Supplementary EIS

23 There doesn t appear to be any c onsidera tion of the interac tion between the timing of construction and when migratory species will be present (eg no consideration on pp 13-78 of whether the timing of construction (potentially October-January) will impact on when the Orange-bellied Parrot will be there (potentially March-early November))

Response As indicated in chapter 13 of the draft EIS there is a low risk that construction will impact on OBPs Construction works are localised and OBP habitat is not affected The only impacts to migratory birds including OBP may occur during the actual construction phase (displacement and habitat loss) and are expected to be short lived

Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to minimise the impact on Orange-bellied Parrots may result in construction occurring when other migratory species are present Migratory shorebirds for example generally return in late August and spend the entire summer at the Lower Lakes

24 In Table 15-9 on pp 15-2526 it says that a fauna inspection will be carried out in the construction area before any vegetation clearance and that any fauna located within the construction area shall be either relocated or dealt with in accordance with recommendations made by the qualified persons more information is needed eg a decision tree flowchart

Response A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water and DEH This knowledge has been considered by the Commonwealth It is acknowledged that more specific instructions on how this can be ac hieved will be inc luded in the Contrac tor s EMP The p rojec t will ensure tha t expert advice is available throughout the duration of the construction phase

25 Please re-consider 163 ESD whole approach The purpose of the weir is to protect water supplies not to prevent degradation

Response They have become one and the same over the life of the project To secure water quality is to secure supply The emergence of acid sulfate soil threats has presented us with a major risk for the water to become un-potable

The transitory effects of the temporary weir are far less than the long term effects of low freshwater flows

Principles of Ecologically Sustainable Development Guidelines Attachment 1 Part 3A

(a) The social and economic consequences of a city of 12 million not having a secure water supply are incalculable

(b) The threats of serious or irreversible environmental damage are discussed extensively in the EIS Whilst there is no full scientific certainty we are continuing to undertake extensive measurements modelling trials and emergency actions to minimise environmental degradation caused both by low freshwater inflows and the short term impact of the temporary weir

with the purpose of the weir in mind Not South Austra lia s

Supplementary EIS for the temporary weir near Pomanda Island -64shy

(c) Both the construction of the temporary weir if required and the actions being taken throughout the Ramsar site will benefit the present and future generations

(d) Whilst the purpose of the temporary weir is to protect water supplies we will take all reasonable steps to minimise any impact of the temporary weir on biological diversity and ecological integrity For example we are now proposing to include a fishway

(e) South Australia is a buyer in the water markets as required and supports the COAG initiatives to improve water markets and trade water information and research and an enhanced urban water reform framework We see no specific application of the ESD principles of improved valuation pricing and incentive mechanisms in the case of the temporary weir

26 If pumping to Lake Albert was not continued beyond June 2009 how would this affect the projections for impacts on the site (water levels the no flow period ASS exposure salinity levels)

Response On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009

The potential for acidification in Lake Alexandrina is based on worst-case scenario rainfall and inflows during 2009 South Australia receives most of its rainfall in winter and spring so the extent of inflows and how trigger points may be favorably impacted by improvements will not be known until later in 2009 Over winter and into 201011 there will be some recovery in the water level (as has occurred each winter over the last three years of minimum flows) above the critical acidification level due to reduced losses and local rainfall Once losses increase during the warmer months the water level would again fall without any additional inflows

As described in the draft EIS under worst case conditions and with continued pumping to Lake Albert it was projected that the water level in Lake Alexandrina will reach the critical acidification water level of -15 m AHD at the beginning of January 2010

However with 220 GL delivered to Lake Alexandrina during 200910 the water level could be maintained above trigger level for the remainder of the 200910 water year 170 GL of the 220 GL requirement is now being secured by no longer pumping to Lake Albert The remaining requirement of 50 GL has already been secured by South Australia through the purchase of temporary water during the 200809 water year

The South Australian Government has assessed the potential savings that could be made by the decision to cease pumping to Lake Albert and how these savings combined with other water sources may delay the need to construct the temporary weir The 170 GL which now will be retained in Lake Alexandrina each year must still flow past Wellington to ensure that the salinity at the major pumping station at Murray Bridge remains below 1400 EC and therefore cannot be retained up-stream of Murray Bridge and used for other purposes

In conjunction with the additional 50 GL already purchased by South Australia (making a total of 220 GL for the full year) this will delay reaching the critical acidification level in Lake Alexandrina until mid to late 2010 maintain lake salinities at lower levels during this period than would occur if water levels continued to fall and maintain lower ASS exposure during this period

Updated model projections for both water level and salinity in Lake Alexandrina are presented below

Supplementary EIS for the temporary weir near Pomanda Island -65shy

_

Lake Alexandrina Level Forecasting from 16 May 2009

-24

-23

-22

-21

-2

-19

-18

-17

-16

-15

-14

-13

-12

-11

-1

-09

-08

-07

-06

-05

-04

-03

-02

-01

0

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Wat

er L

evel

(m A

HD

)

Projected Level w ith Maximum Net Evaporation (1982) Conditions

Level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Level

Critical Acidif ication Level (-15m AHD)

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Losses Maxmimum Net Evaporation (1982) Conditions

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 and no irrigation in 200910)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD unless stated

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank filled to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -66-

_

Lake Alexandrina Salinity

Forecasting from 16 May 2009

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

11000

12000

13000

14000

15000

16000

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Sal

inity

(E

C)

Projected Salinity w ith Maximum Net Evaporation (1982) Conditions

Salinity w ith level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Salinity

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Salinity Salinity of Flow to SA varies from 200 to 350 EC (f low rate dependent)

Losses as stated

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 no irrigation 200910 onw ards)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank f illed to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -67-

Water supply

the weir is expec ted to have negligible effects on sa linity between Loc k 1 and Wellington

27 On pg 10-22 the EIS sta tes tha t then why is the weir needed to protect water

quality

Response The temporary weir will have minimal impact on water quality upstream of the temporary weir in terms of the inputs (particularly salinity) from upstream The primary purpose of the temporary weir is to prevent contaminated water from Lake Alexandrina being pushed into the River Murray channel upstream of Wellington through wind seiching Monitoring and modelling have demonstrated that even at the relatively low salinities in the lake currently incidents where water with a salinity in excess of the maximum target level of 1400 EC penetrates upstream to Tailem Bend may occur

28 Figure 1-3 (pg 1-4) shows a water level of -15m AHD (ie the critical acidification date) being reached in January 2009 What is the interaction between this and the proposed Clayton blocking bank which would bring the critical acidification date forward by at least 2 weeks into December 09

Response Pumping water to the Goolwa Channel will bring forward the time when the trigger water level of -15m AHD is reached by about 2 weeks however the critical acidification date will be delayed with the 220 GL delivered to Lake Alexandrina during 200910 (see response to question 26)

Should more than 896 GL year be ava ilab le [flowing ac ross the SA border] the potential effects of the proposed temporary weir are likely to be reduced in the Lower Lakes Does this mean that any water in excess of 896 GL will be allowed to flow into the lower lakes

29 On pg 10-7 it says tha t

Response Water allocated to South Australia in excess of 896 GL plus private and state carry-over will be allocated on a priority basis within the state Some of this may be allowed to flow to the Lower Lakes The application of any water in excess of 896 GL per year has not been determined and it is also dependent on the reason why there is exc ess wa ter For example unregula ted flows whic h a re flows tha t the MDBA is not able to capture a re likely to flow to the lakes while regula ted flows a re ava ilab le for allocation to support irrigation

30 The 201 GL critical human needs volume is based on level 5 water restrictions (pg 4-6) what is the plan for moving SA onto level 5 water restrictions considering only 896 GL is expected in 2009-10 (pg 1-3)

Response The total volume available to South Australia in 2008-09 is currently predicted to be at least 1140 GL Areas in South Australia reliant on River Murray water are currently on enhanced level 3 water restrictions The extra saving in moving to level 5 is 17 GL which is negligible in terms of the Lower Lakes

The Metropolitan Adelaide water supply is derived from two sources Inflows in the Mount Lofty Ranges during winter 2009 will impact on any decisions on water restrictions There is currently no plan to increase the restriction level from the current enhanced level 3 restrictions as the difference may be provided by additional MLR inflows

what is the increase in SA water use based on Population growth

31 Fig 2-2 on pg 2-5 shows 40 GL more being demanded than supplied by 2025

Response The 40 GL is the net effect of increasing demand further water conservation initiatives as described in the Water Proofing Adelaide strategy and reduction in available sources of water due to the impact of climate change

The weir is expec ted to a ffec t the amount of wa ter held between Lock 1 and Wellington and provide confidence that an extra [emphasis added ] 685 GL is ava ilab le for South Austra lians The 685 GL represents the amount of water needed to fill the weir pool from -15m AHD to +01m AHD but is not extra water that is available for extraction

32 On pg 10-32 the EIS says tha t

this needs to be clarified

Response Agreed The extra volume could only be available as a last resort and drawing down this weir pool would jeopardise water quality (salinity) as there would be no through flow to the Lower Lakes

Supplementary EIS for the temporary weir near Pomanda Island -68shy

33 On pg 2-2 the EIS states that roof run-off stormwater and recycled water are used for non-potable purposes how much Has this reduced reliance on Murray water Also mentions desalination plant will this reduce reliance on Murray water

Response Use of roof-runoff and stormwater particularly in the northern suburbs of Adelaide has provided additional water to reduce the demand on the traditional sources River Murray and the Mount Lofty Ranges Predominantly these have provided non-potable water for new development and as such are preventing increased demand from the traditional sources

It is clear that in critical periods of drought the 100 GL Adelaide desalination plant currently under construction will reduce reliance on the River Murray

While the desalination plant will reduce reliance on the River Murray this does not necessarily have a direct impact on the flow to South Australia required to maintain salinity at a satisfactory level (target lt1400EC at Murray Bridge) None of these nonshytraditional sources will remove reliance on the River Murray and it should be noted that a minimum flow to South Australia of about 900 GL per year is required to maintain salinity at Murray Bridge at less than 1400EC which is required for all potable use whatever the level of demand for Adelaide and regional South Australia

what is their estimated reduced reliance on Murray water Pg 4-17

34 Strategies 1 and 2 on pg 4-13 same question

Response Water conservation and recycling reduce the average water extracted from the River Murray and the recently released Water for Good plan quantifies this However in periods of extreme drought the same water savings are traditionally achieved through water restrictions and consequently these initiatives do not greatly reduce the need for River Murray water during critical periods

35 What is the safe operating height of SA Water pumping off-takes (pg 4-2)

Response Following modification to the pumps the safe operating level is currently -22m AHD Prior to the modifications the safe operating limit was around -04m AHD The estimates of the critical limits for the pumping stations have varied over time as the river level has dropped and the pumps could be tested outside of their normal operating ranges

36 If the pumps can pump down to -22m AHD then why is the weir pool at +01m AHD Does this factor in evaporation of the weir pool during times of low flow which would lower the water level Or is this considering the water quality of the lower lakes How can this be the case when the weir expected to have negligible effects on salinity between Lock 1 and Wellington

Response This level is set taking into account the requirements of the temporary weir during the recovery phase If Lake Alexandrina becomes saline the temporary weir needs to maintain a physical separation between the river and the lake as the lake level increases to allow the saline lake water to be flushed to sea

The level of 01m is a compromise While a higher level (up to 075m AHD or higher) would be preferred to facilitate flushing of lake water to the sea the foundation conditions for the temporary weir are not suitable for such a high weir if the lake levels continue to drop

c areful p lac ement remova l of embankment material

37 In Table 15-3 on pg 15-17 it says there will be what does this mean

Response Careful placement removal of the weir embankment material during constructionremoval will minimise both the area and quantity of disturbed bed material and hence minimise the immediate water quality impacts (mainly turbidity) and the inadvertent release of sulphuric acid from the sediments

38 SA has previously indicated it would legislate to ensure removal of the weir has this been done When will it be done

Response No The temporary weir will be removed when the decommissioning criteria (as agreed by the Water Security Council and accepted by the MDBA) are met

39 How will additional water secured through SA water security strategy and efficiency measures be managed ie will any be provided to Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -69-

Response See response to Q29

40 Are there any the implications of predicted future water demand in SA on the period of time that the weir is in place

Response This is not expected to be material during the expected life of the temporary weir

Predicted future demand for potable water for the major off-takes will have minimal impact on the time the temporary weir is needed The temporary weir is required to prevent saline or acid contaminated water from the Lower Lakes entering the river channel until such time as the quality in Lake Alexandrina no longer provides a threat to these water supplies whatever the demand

41 Will salinity increase behind the weir in the weir pool Given that saline water sinks the water overtopping the weir may potentially be fresher water Will salinity levels in the weir pool build up to a point where it might impact on the offtakes

Response Large quantities of salt flow down the River Murray every day but it is largely mixed and therefore will not separate and sink Therefore salinity levels in the pool between Lock 1 and the temporary weir are not expected to impact on the offtakes (Note that there are saline groundwater inflows to the river which can cause localised pockets of salinity but this occurs in normal river operation and is independent of the construction of a temporary weir These pockets of high salinity eventually mix and the salt is carried away in the general water body)

In the absence of a temporary weir when more saline water from the lakes is forced under wind seiche into the river it does sink to the bottom rather than mix with the less saline river water and the saline water then moves upstream This is exacerbated by the differing depths of the water at Pomanda Island and in the river channel upstream of Wellington

Modelling indicates an initial rise in upstream salinity during the weir filling period and then after that no major change in the long-term Provided there is no significant input of highly saline water from Lake Alexandrina (the purpose of the temporary weir is to stop this) the salinity gradients generated by evapoconcentration of the relatively low salinity river water will not be sufficient to resist the natural mixing as temperatures and wind conditions change This has been demonstrated by the natural break-up of the saline intrusions on the bottom of the river due to inflows from Lake Alexandrina which have been identified through monitoring over the past year

42 Can SA provide the modelling on the 696GL scenarios with and without the weir on water levels the no flow period ASS exposure

Response Refer to the response to Q9

The flow scenario proposed is unrealistic as South Australia is guaranteed a minimum flow of over 896 GL in 2009-10 (including the reserve for Critical Human Needs and private carry-over) Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream

The requested modelling results will be provided but should not be taken as representative of any realistic scenario

Removal triggers (pg 1-6)

norma l opera ting levels in rela tion to Hume and Dartmouth and what period of time these levels have to be sustained for

43 No definition of

Response The MDBA states that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

44 How long to fill Hume and Dartmouth Dams and how likely is this What is the worst case scenario Best case Is the filling and operation of these dams likely to be impacted by MDBstate water management

Response It is not possible to predict how long filling these storages to this level may take Hume storage in partic ula r is quite vola tile and c ould easily fill and spill within less than one year Dartmouth storage is more likely to take longer but the average end of season

Supplementary EIS for the temporary weir near Pomanda Island -70-

level is commensurately lower Under continuing worst case conditions the storages will not reach these trigger levels

The filling of these storages could be affected by decisions by all jurisdictions regarding the management of the Murray-Darling Basin including future sharing and reserve arrangements

45 Why was this trigger chosen rather than one focussed around water made available to South Australia from shared River Murray water or based on discontinuationreduction of dry-inflow contingency

Response These triggers were determined because they are open and transparent They are based on the best available technical advice

The triggers were agreed by the Water Security Council and accepted by the MDBA

need to meet a ll triggers Can SA provide any indication about the likely timeframe in which all triggers would be met

46 The timeframes on the removal triggers are unclear

Response Removal triggers are directly related to the drought and how much water is expected to become available It is not known when these triggers will be met

The MDBA notes that the specific timing of removal is highly dependant on the seasonal conditions at the time Lake Alexandrina next fills above +01 m AHD

no water quality impacts from Lakes water quality in the lakes is unlikely to improve with the weir in place so how realistic is this as a removal trigger If it is decided that seawater needs to be introduced to manage ASS this is likely to delay removal of the weir given the inability to meet this trigger

47 Regarding the 3rd removal trigger

Response Water quality in the lakes is unlikely to improve until additional fresh water flows down the river and either dilutes the lake water or flushes it to the sea If inflows to the lakes over the temporary weir exceed evaporation the water quality will begin to improve through dilution Major improvement in quality will not occur until there is a discharge of water from the barrages which cannot occur until the water level is restored to at least +05m AHD The critical salinity level in the lakes has been calculated at 3000 EC If inflows are predicted to reduce the lake salinity to less than this value the potential impact of lake water on major water supply offtakes is considered acceptable If seawater has been introduced to prevent acidification the volume required to dilute discharge salt to the extent that this target of lt3000EC can be met will be greater than if no seawater has been introduced However the volume of inflows required to improve lake water quality to an acceptable level if the lake has been allowed to acidify is likely to be even greater

This trigger has been purposely expressed as water quality rather than salinity because no decision has been made on whether seawater is to be used to manage acid sulphate soils (EPBC Reference 20084618) or whether an alternative strategy is to be adopted

If seawater is not introduced acidification may introduce a number of other water quality issues that need to be resolved before the temporary weir can be removed

48 In relation to the salinity trigger how much water is required to flow in to reduce salinity levels to below triggers stated What is the likely timeframe on getting this volume

Response The volume of water required to dilute salinity in Lake Alexandrina to meet the removal trigger will depend on the quality of water remaining in the lake and when the dilution occurs At the time of closure of the temporary weir it is predicted that the salinity in Lake Alexandrina will be approaching 10000EC Salinity will increase to about 28000EC within 12 months due to river inflows and evapo-concentration and will be significantly higher if seawater is introduced

Figure 211 in the Draft EIS shows how salinity in Lake Alexandrina continues to rise with continued low inflows The volume of fresh water eventually needed to reduce the lake water below the trigger level depends on how long the drought continues Typically the salinity of water in Lake Alexandrina will be diluted by 30 just by re-filling the lakes to 01m AHD

49 If the Australian Drinking Water Guidelines (2004) say that 275 to 550 EC is the acceptable salinity of drinking water (pg 10-4) then why is the removal trigger set at 3000 EC

Supplementary EIS for the temporary weir near Pomanda Island -71-

Response The desirab le sa linity ta rget for d rinking wa ter supp lies in South Austra lia has been identified as 800 EC based on AWRC and WHO guidelines Many supplies do not always meet this desirable limit The removal trigger for salinity in the lakes has been set at 3000 EC higher than the maximum limit set for Tailem Bend (1400 EC) and much higher than the desirable limit for drinking water of 800 EC because based on experience and from the modelling results the risk of water from Lake Alexandrina raising the salinity at the major water supply off-takes above the maximum target level of 1400 EC is acceptable

50 No definition of what the water quality risks are and how these would be measured

Response Refer to response to Q47

The primary water quality risk is salinity and this is dealt with comprehensively throughout the document Additional water quality risks arise from water moving upstream for Lake Alexandrina if the lake has acidified (heavy metals metalloids nutrients) These risks are closely monitored through existing water quality sampling programs associated with a major public water supply Algal blooms (potentially toxic cyanobacterial in particular) present an additional water quality risk that is addressed in the Supplementary EIS The presence of algae is monitored closely through a program established when lake and river water levels started to decline This program which is in addition to the normal sampling for public water supply purposes includes regular airborne videography and infrared photography with immediate ground truthing of any sites identified through the aerial survey work

It is not possible to quantify all of the water quality risks unless the management strategy for ASS is known in particular whether a preventive approach using seawater is to be used or a remediation approach The full impacts of these options are currently being investigated for the EIS to allow seawater into the Lakes

51 Fourth removal trigger is subjective what does this mean in practice Confidence is immeasurable this alleged removal trigger is more on outcome of the other removal triggers being met than a trigger in itself

Response The confidence required is in the consistency and robustness of River Murray water resource projections in relation to being certain we will not return to a similar situation of extreme low water levels as we are currently experiencing in the near future which may require re-instatement of the temporary weir

To some extent the comment that this trigger is an outcome of the first 3 triggers is correct However this trigger is intended to allow for the considerable uncertainty around the management regime for ASS and changes to operating rules in the MDB

52 58 states that once the water level exceeds +01m AHD the weir will cease to serve any useful function How will the structure of the weir albeit below water level change flow rates past the submerged weir

Response The temporary weir will have very limited impact on flows once water levels return to greater than +01m AHD in the lakes When the water level exceeds 01m AHD the temporary weir becomes drowned but it still provides a (partial) barrier to saline river water moving upstream

The submerged weir will still allow the prevailing flow to pass Should flow rates exceed the design of the temporary weir action would be taken to widen the flow path

Additional modelling will be undertaken to identify any backwater impacts from high flows in a situation where the temporary weir has not been removed (eg 50 000 MLday) The presence of the temporary weir would still provide some benefit in restricting any saline flows from Lake Alexandrina in to the River Murray channel even if the temporary weir was d rowned

Wetlands

53 In section 1246 on pg 12-11 under the head ing Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion is c onsidered insignific ant as many of these species reproduce sexually and wind or bird-d riven seed d ispersa l This is only a consideration of impacts upon reproduction not a consideration of whether the plants will even survive to reproduce

Supplementary EIS for the temporary weir near Pomanda Island -72-

Response Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately 035 m AHD At a water level of -15 m AHD this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the waterbody and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the lake be refilled with fresh water to its pre-drought level (05 to 08 m AHD) while the below-ground storage organs remain viable

54 In Table 12-3 on pg 12-6 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type O it says that the slightly quicker decrease in water levels as a result of the weir is expected to bring forward the exposure of some sediment (including acid sulphate soils) that would otherwise have been exposed within 9 months how much acid sulphate soils Is this the 5200 ha mentioned on pg 11-7

Response Yes it is 5200 ha and this is reiterated in the Supplementary EIS As discussed in the Supplementary EIS the reduction of flow during the filling of the weir pool reduces the volume of water such that a further 5200 ha of sulfidic soils is exposed in Lake Alexandrina This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage acid sulfate soils will need to be implemented across the Lake in this case

55 In Table 12-3 on pg 12-8 for wetland type XI how can there be no recorded change at shy05m AHD but complete disconnection at -15m AHD

Response Presumably the comment refers to wetland type Xf not wetland type XI In Table 12-3 for wetland type Xf under Existing c ond ition (app roximately -05 m AHD) rep lac e No rec orded c hange with Not c onnec ted to the ma in body of the lake Will only be a ffec ted by ongoing d rought

Covered in Supplementary EIS

56 In Table 12-3 on pg 12-8 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type 4 the EIS says the weir is not expec ted to further impac t the management of seasonally flooded agricultural land when are they seasonally flooded Are the 25-3 months following weir closure going to prevent this seasonal inundation

Response In Table 12-3 for wetland type 4 under Impac t of p roposed temporary weir within Ramsar wetlands to existing text add whic h oc c urs a t wa ter levels gt 087 m AHD At the trigger level for weir construction (-15 m AHD) water levels will be 237 m below those that lead to inundation of surrounding agricultural land With or without the temporary weir in place water levels will remain well below 087 m AHD for the 25 3 month period following weir construction if it proceeds

Covered in Supplementary EIS

57 In Table 15-1 on pg 15-2 in the row on acid sulphate soils the EIS says that contingency measures may be c onsidered if a lka linity dec lined to a spec ified level what is this level How and where will this be measured What contingency measures would be implemented

Response Table 15-1 refers to Table 15-6 Potential mitigation measures to manage acid sulfate soils which contains the levels (100 and 25 mgL as CaCO3) In Table 15-6 for dot point 2 it c ould be c hanged to If a lka linity c onc entra tions dec line to 25 mgL as CaCO3 then immediate mitigation measures such as limestone slurry dosing are expec ted to be undertaken

Since August 2008 the SA MDB NRM Board has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (eg sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC

Supplementary EIS for the temporary weir near Pomanda Island -73-

It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (report 1 March 2009) The EPA also compiles the raw data in a spreadsheet available to South Australian government agencies

58 How will the Wetland Management Plan (Table 15-3 pg 15-17) manage the change in flow patterns Does have any suggestions on how to mitigate the impacts of the no-flow periodfirst year reduced flows period

Response Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

59 In Table 15-3 on pg 15-18 it mentions several potential water quality protection measures including use of a turbidity curtain stabilisation of river banks etc Under what conditions would each of these measures be implemented Same for contingency measures for acid sulphate soils outlined in Table 15-6 on pg 15-20

Response The EPA has pointed out that the EMP scope should include monitoring and managing turbidity impacts during construction and any EMP should be approved by relevant authorities including the EPA prior to any works being carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) which contains the overarching EMP SA Water and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Table 15-3 has been amended

60 Will there be any interactions with other referrals Will the presence of the weir impact on the Goolwa Channel referral

Response The temporary weir is part of a planned progressive response by the South Australian Government to worsening conditions in the Lower Murray in South Australia This Cabinet approved response plan is based on water levels in the barrages weir pool The critical trigger for the temporary weir is -15m AHD The trigger for the project to pump water to Lake Albert was -05m AHD and the trigger for the proposed Goolwa Channel Water Level Management Project is -12m AHD These actions are all linked as part of the overall response strategy The presence of the proposed temporary weir will not impact on the Goolwa Channel project as the latter project will be constructed well prior to the proposed temporary weir near Pomanda Island

61 It is likely that the presence of the weir may adversely impact on the recovery and management of the ecological character of the and therefore in the implementation of the long term plan for the site Does SA have any suggestions about how this will be managedmitigated

Response The temporary weir will not adversely impact on the recovery and management of the ecological character and will assist in preserving the range of options that can be considered under the long-term management strategy If the temporary weir is not constructed and the area acidifies or a greater volume of seawater is required to prevent this the detrimental impacts on the long-term plan will be greater

62 Page 10-25 will SA be purchasing water to ensure that the hydrological disconnection associated with the filling of the weir pool is reduced from 3 to 1month Please provide details under what circumstances would this occur

Response The South Australian Government is committed to pursuing a fresh water solution for the Lower Lakes including the purchase of water from the market However

Supplementary EIS for the temporary weir near Pomanda Island -74-

no commitment of additional water to the Lower Lakes can be made until the winter 2009 inflows are known

Re-wetting of upstream wetlands

63 Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

THIS SECTION DOES NOT EXIST and they do not appear to be described elsewhere (pg 10-10 also mentions likely changes to groundwater interactions and the re-wetting of dried sulfidic sediments and the associated ecological effects that would result and refers to Ch 15 for management tha t s in p lac e) mitiga tion measures mentioned aga in on pg 11-9 but no details

Response The reference to section 1554 should read 15412 and has been corrected in the Errata to the Supplementary EIS Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant Further details are provided in the response to question 64 in regards to ASS mitigation and management of wetlands above Pomanda Island All appropriate approvals for structures will be sought through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project

64 As the weir pool fills and upstream wetlands are re-wetted there exists a real potential for the introduction of low pH water with high metal concentrations into the River Murray (pg 11-8)

Response Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on potential impact refilling wetlands will have on water quality of the Main River Channel and ecological impact of further acidification of wetlands

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the MDBC Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from DEH project identifying acidification remediation options for the Lower Lakes Construction of structures and other on-ground works for remediation at priority wetlands and Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRM Board is managing the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project with a steering committee comprising of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRM Board DEH DWLBC MDBA SA Water EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of 01m AHD CSIRO have undertaken a preliminary assessment of the ASS hazard for each of the 75 wetlands An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of each wetland will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and

Supplementary EIS for the temporary weir near Pomanda Island -75-

ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island eg wetlands providing important aquatic refuges

65 Which wetlands will be re-wetted What are their sizes water levels condition etc

Response Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at +01m AHD The Table below provides information of the c ommenc e to fill level surfac e a reas and ASS management assessment for eac h of the 25 wetlands

NAME

SA (ha) at pool (~075m AHD)

SA (ha) at 02m AHD

commence to fill m AHD

Require ASS management

Riverglades 446 196 -051 Yes

Wellington Marina lt 191 lt 191 lt -080 Needs reassessment

Saltbush Flat 855 88 -025 No

Teal Flat Hut 202 15 -019 Yes

Walker Flat South Lagoon 888 601 -010 Yes

Wellington North (Murrundi) 9 32 -010 Yes Lake Carlet 3457 2998 -065 Yes

Devon Downs North 2627 822 -040 Yes Lake Bywaters 388 321 -017 No Marks Landing 1929 1453 -060 No

Coolcha Lagoon 1284 436 -045 Yes

Tailem Bend 957 811 -057 Yes

Younghusband 223 23 -010 Yes Younghusband West 1089 887 -062 Yes Caurnamont 903 464 -021 No Craignook 369 208 -002 Yes

Forster Lagoon 80 641 -022 No Henley Park 224 177 -027 No Bow Hill 475 140 -033 No Mannum Swamps 1977 1450 -035 Yes Mason Rock 258 91 -046 Yes Reedy Creek 986 436 -004 Yes Priess Landing 5 29 -069 No

Teal Flat 82 476 -011 No

Wongulla Lagoon 124 365 -046 No

Total 24449 13161

66 In the final paragraph on pg 12-16 the EIS says that re-wetting could potentially cause water in these wetlands to become acidic (if acid sulphate soils are re-wetted) which c ould c ause the following ac id ity would then remob ilise meta ls c onta ined within the sediments causing disease or death in fish due to metal toxicity Should this be experienced management measures identified in Chapter 15 will need to be undertaken What a re the management measures How will SA know if this has occurred (ie monitoring)

Response Refer to response in Ref 64 in regards to management of potential risk of ASS in wetlands inundated at 01m AHD The Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project incorporates the development of a monitoring program to assess the success of the ASS mitigation strategies and ecological impacts This will include the monitoring of water quality metals biota such as fish groundwater and vegetation

67 What will be the objectives of the management plan for re-wetting exposed acid sulphate soils How will it achieve these objectives (Table 15-6 pg 15-21)

Response The objectives of the management plan for re-wetting exposed acid sulphate soils are

To mitigate the risks of acid and metal mobilisation to the main River channel water quality and biota of the River Murray and associated wetlands

Supplementary EIS for the temporary weir near Pomanda Island -76-

Mitigate the risk of acid and metal mobilisation within the wetlands above Lock 1 when they are refilled and Ensure the development of ASS mitigation methods incorporate the environmental values of each of the wetlands

The objectives will be achieved through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project which will develop site-by-site management options for ASS hazards The risk assessment has been undertaken which has identified 14 wetlands that require management of ASS hazard Management options are currently being developed and may include regulating structures and other methods such as neutralising agents mulching and revegetation with the aim of ameliorating the risk to the main River channel due to the rewetting ASS hazard wetlands

68 Will the rewetting strategy for ASS areas in the weir pool affect the time it takes to fill the weir pool and therefore prolong the period of no flow to Lake Alex

Response The refill volumes for each of the 25 wetlands that will be inundated at 01m AHD with the construction of a temporary weir near Pomanda Island are currently being calculated using modelling and survey work It expected that the total volume of water required to refill these wetlands will be insignificant in relation to the volume of water required to fill the River channel and would not prolong the period of no flow to Lake Alexandrina

With only 3 of the 75 wetlands in this reach currently wet due to the low River levels it is important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island The re-wetted wetlands will provide important aquatic refuges and breeding opportunities for biota

Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

Threatened and migratory species

69 On pg 13-13 the EIS says The lac k of c onnec tivity [ie as a result of the weir b loc king migration] is expected to also hinder gene flow between populations potentially leading to a decrease in diversity in both Murray Cod and Murray Hardyhead populations if it c ontinues for a suffic ient period What would be a suffic ient period in this c ase Would three years (the design life of the weir) be a sufficient period Obviously for Murray Hardyhead even one year of interrupted reproduction could be significant as the species only lives for 2 years (pg 13-14)

Response A fishway to suit large and small species will be included in the weir design and design is currently underway

70 At what water level will the Swamps of the Fleurieu Peninsula disconnect from the main body of Lake Alexandrina (as per pg 13-4)

See page 32 of the supplementary EIS under the heading Impacts upon tributary wetlands

71 Lack of detail in section on Orange-bellied Parrot (pg 13-8) to exactly where will vehicle movement be spatially restricted How will the creation of new tracks be limited What vegetation will be cleared and how much

Response Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coor ong_Survey_lowpdf

In order to gauge the potential impact of the construction of the temporary weir on local biodiversity a thorough ecological survey of the immediate area in Spring 2009 is

Supplementary EIS for the temporary weir near Pomanda Island -77-

desirable Survey results can then inform relevant mitigation strategies to be included in the EMP

Construction activities on (Pomanda Island) will be restricted to along the northern edge of the island and locally around the abutment It is expected that the temporary weir will cause a minor loss of some of the reed beds along the western access road to the construction site due to the need to construct a wider road for truck traffic The construction footprint will be minimised as far as practically possible by minimising the road width and avoiding the reed beds where practically possible Construction activities on the eastern side will be localised to the immediate area around the abutment The landscape on the Eastern side is characterised by farmed paddocks Hence no reeds (and no habitat of the Orange bellied Parrot) are expected to be impacted on the Eastern side

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

72 In Section 1352 on pg 13-9 rela ting to the Southern Bell Frog it doesn t mention tha t the frogs have been found at Pelican Lagoon (pg 7-24) the section goes on to mention that the site at which the southern bell frog was recently recorded is expected to be disconnected from the water when Will the regulated pumping system continue to operate

Response The main body of Pelican Lagoon where Southern Bell Frogs (SBF) have previously been recorded (River Murray Wetlands Baseline Survey 2005) has been dry since 2007 It is unknown as to whether SBFs are still located in the dredged area closest to the river It is expected that this dredged area will remain inundated at +01m AHD but the rest of the wetland will remain dry

73 Where is the previously occupied southern bell frog habitat near Wellington How will the raised water level help frogs to recolonise this habitat (pg 13-10)

Response The previously occupied site for the Southern Bell Frog near Wellington is called Ferry Crossing (Coordinates139386 -35337) The recording was in the 2000 frog census on 15 September 2000 numbers were identified as few The only other areas where they have previously been recorded within the Lower Lakes are at Tolderol Game Reserve and Clayton (Dunn Lagoon) These sites are to the West of Wellington on the shores of Lake Alexandrina

The raised water level of the weir pool will re-hydrate the wetland and provide re connection with the main river channel This in turn enables the re-establishment of emergent and submergent vegetation within the wetland providing suitable habitat for the species to colonise and reproduce Reproduction requires still or slow moving water (Australian Government 2009)

Australian Government 2009 Significant Impact Guidelines for the vulnerable growling grass frog (Litoria raniformis) EPBC Act Policy Statement 314

74 An Environmental Management Plan is proposed as mitigation to the likely impact of disruption to Southern Bell Frog tadpole migration (Table 16-1 pg 16-3) how will the EMP mitigate this impact Need more information on the potential for the weir to disrupt the dispersal and migration of southern bell frog tadpoles (pg 13-10)

Response This response takes into consideration the history of inter-governmental documentation on this point in relation to the proposed Pomanda Island Temporary Weir and a lso the Dra ft EPBC Ac t Polic y Sta tement 314 Signific ant impac t Guidelines for the vulnerable growling grass frog (Litoria raniformis) [= southern bell frog] (Feb 2009)

Environmental conditions habitat and breeding

The preferred habitat for breeding of the southern bell frog is high emergent vegetation cover (eg Phragmites and Typha) and still or slowly-moving water (Stratman 2007 DEH 2009) Current conditions in the Lower Lakes region are poor and breeding is unlikely to be occurring in the region at the moment It is unlikely that breeding will occur immediately downstream of the temporary weir in the short-term Immediately upstream of the temporary weir it is likely that habitat conditions will be maintainedenhanced (see also page 30 of this document)

Supplementary EIS for the temporary weir near Pomanda Island -78-

Migration of southern bell frog

It is now considered that the original comment in the draft EIS of The likely impacts on this species are confined to possible Interruption to dispersal and migration of tadpoles Additional pressures resulting from the construction and operation of the temporary weir include short term changed water regimes water chemistry and localized noise As no individuals have been recently recorded at the proposed site these local disturbances are not expected to impact the population was incorrect in its reference to tadpoles The adults of the species are highly mobile (movement of up to 212 m in a single night has been recorded referred to in Schultz 2008) Less is known about the mobility of tadpoles Tadpoles may be involuntarily swept over the temporary weir during significant flow events The top height of the proposed temporary weir is lower than the normal operational sill level at the Goolwa barrages so the structure will only present a barrier to dispersal of the Southern Bell Frog during unfavourable conditions such as those that have prevailed for the last 18 months

Since adult frogs are highly mobile the causeway and abutments associated with the temporary weir may impact on the movement of adults along the banks of the river corridor Experimental developments in Victoria have used culverts or pipes placed beneath roads as corridors to try to link populations however Bell Frogs have not been observed using them to date (G Heard personal communication)

Survey

The SAMDB NRMB advised that a targeted frog survey was needed to determine whether Southern Bell Frogs still remain in the vicinity of Pelican Lagoon prior to the development of the Environmental Management Plan

DEH undertook a habitat preference survey during March 2009 and a follow-up survey is planned for Spring and Summer 2009 to assess population numbers The rapid assessment of suitable habitat for the Southern Bell Frog (March 2009) was conducted around the perimeter of Lake Alexandrina and Lake Albert with survey sites stretching along the edge of Lake Alexandrina from Milang to Wellington then Wellington to Meningie along Lake Albert around to Narrung The result of this habitat assessment is a proposed targeted species survey in line with the original project objectives

As indicated in Figure 7-4 of the Draft EIS L raniformis has been detected at wetland habitats around Lake Alexandrina and in the lower reaches of the Murray River upstream of the lake including locations near Narrung Point Malcolm Wellington and around Milang Most of the sites based on habitat mapping undertaken by DEH are characterised by permanent water and to some extent reedbeds

Mitigation

The comment on mitigation that was included in the draft EIS is relevant

All construction operation and decommissioning activities are expected to be done in accordance with an Environmental Management Plan A survey for this species is expec ted to be c onduc ted in 2009 to better understand the p resent d istribution The initial assessment to indicate likely target sites (preferred habitat survey) has now been completed and the follow-up survey is planned for spring summer later in 2009

75 On pg 13-11 the EIS says that the Yarra Pygmy Perch are more commonly found in the well-vegetated lake margins and the channels of Hindmarsh Island and the lower ranges of the eastern Mt Lofty Ranges tributaries but that these areas are currently disconnected from the main body of Lake Alexandrina (also on pg 14-1) When did the channels of Hindmarsh Island disconnect Yet it is stated in the EIS the eastern Mt Lofty Ranges tributaries (Currency and Finniss) a ren t expec ted to be d isc onnec ted until lake levels drop to -12m AHD (pg 10-1) do you mean Angas and Bremer

Response refer to the discussion on page 23 of the supplementary EIS regarding Connectivity of Surface and Ground Waters

76 Why do PIRSA Fisheries have a policy of not re-stocking fish species (pg 13-14) and what is different about these circumstances that would mean it is now a suitable option

Response PIRSA Fisheries advises that in the absence of a fishway stocking of fish to increase populations in a degraded habitat is unlikely to result in a net increase in the population However as the water is pooled upstream of the new temporary weir there could be some limited restocking as the environment improves to allay any concerns

Supplementary EIS for the temporary weir near Pomanda Island -79-

that cod populations have suffered from the weir works The PIRSA website has a policy paper4 which explains why large scale restocking is not supported (there are implications of spreading diseases in wild populations from those that have been housed in aquariumsgrown in aquaculture there is also the risk of limiting genetic diversity if stock have been bred from only a few source fish and a series of other issues)

In regards to the broader issue of re-stocking native fish species within the site that have been lost to the freshwater environment due to their complete disconnected from the lake re-stocking before recovery of the ecosystem is not appropriate Upon recovery of the ecosystem and re-establishment of an appropriate freshwater ecosystem these species will either re-colonise from elsewhere or if only located regionally re-introduced via a stocking program An existing program is in place whereby populations are being bred in captivity to allow later re-introduction in the future of EPBC listed (Yarra pygmy perch and Murray hardyhead) and regionally significant species (Southern pygmy perch River Blackfish and Southern Purple-spotted gudgeon) We are presently in the situation where for some species (those listed above) there are no remaining genetically-distinct populations remaining in-situ so the only option is to reintroduce those held in captivity if we want the population to persist Murray cod are believed to be a single genetic unit across South Australia and hence re-population from upstream populations should enable recovery This could be supplemented by a breeding program but would be subject to a complete collapse of the SA South Australian population and approval from PIRSA as would the re-introduction of other species presently held in captivity and would be subject to specific testing and satisfaction of relevant conditions

In addition to these potential activities a fishway is now being included in the design for the temporary weir to enable the egress of species from the lake environment into the river channel above Wellington

77 What is the evidence that Murray Cod and Murray Hardyhead are able to withstand high turbidity conditions (pg 13-15)

Response No data on the tolerances of Murray Cod and Murray Hardyhead to high turbidity conditions are available Evidence on tolerance to relatively high turbidity is correlative Both of these species are distributed across lower regions of the Murray-Darling Basin in areas subject to relatively high turbidity Turbidity in the River Murray in South Australia is highly variable and largely influenced by discharges from the clay-laden Darling River (Woodyer 1978) Turbidity at Morgan averaged 516 NTU between 1994 and 2004 with peaks as high as 304 NTU (Westwood and Ganf 2004) Turbidity in Lake Alexandrina is also highly variable with mean values between 1975 and 1978 varying from a high of 93 NTU to a low of 9 NTU with localised values as high as 150 NTU recorded (Geddes 1988)

78 What would the parameters be for reintroduction of Yarra Pygmy Perch andor Murray Hardyhead (pg 13-16)

Response The reintroduction of the Yarra Pygmy Perch and the Murray Hardyhead would be undertaken once the habitat has been rehydrated and the keys components to their survival are in place such as

There is a level of confidence inflows into South Australia will be able to sustain the habitat at least in the medium term Habitat structure has recovered (eg aquatic plants) sufficiently to provide for o Spawning o Shelter o Food source and o Predation avoidance Water quality parameters are within tolerances (specified in the draft EIS) of each species such as o Salinity o pH o Dissolved oxygen o Water temperature o Turbidity and o Concentrations of contaminants particularly Aluminium

4 httpwwwpirsagovau__dataassetspdf_file000950895Stock_enhancement_policy_Aug_07pdf

Supplementary EIS for the temporary weir near Pomanda Island -80-

For Murray Hardyhead the following ranges of parameters have been utilised for reintroduction at a Lower Lakes site

EC 2000 30000 EC

DO gt50 mgL (ANZECC WQ Guidelines)

Turbidity 2-200 ntu (ANZECC WQ Guidelines)

84PH 70

Yarra Pygmy Perch would have similar parameters but with a much lower salinity range

79 On Pg 14-7 it says that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB what noise levels will construction create

Response At this stage it is difficult to predict what the average noise level might be Presumably levels will fluctuate and for short periods of time the 56db level may be exceeded Important also in the equation is the distance of the waterbirds from the noise source If the equipment levels a re say 85dB(A) then they ll d rop to 45db (A) within 100m

There are no wetlands on the eastern side near the abutment We expect any areas around Low Point populated by birds to receive noise levels similar to that from a busy highway This same comment will apply for the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels so it is assumed they would occur further north into the wetland area

Monitoring of EPBC-listed species throughout the project is expected to occur to ensure construction operation and decommissioning activities do not impact on EPBC-listed spec ies how will monitoring ensure this This can only work if particular contingency measures are undertaken if a particular measure is observed during monitoring

80 On pg 15-24 it says tha t

Response Monitoring during operation of the weir Monitoring efforts will be coordinated as part of the SA MDB NRMB s na tura l resourc e c ond ition monitoring program It will include additional monitoring efforts as per expert advice

Monitoring during the construction and decommissioning of the weir It is recognised that the monitoring of the EPBC listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life breeding cycles The monitoring focus will be of an observational nature mainly in regards to compliance monitoring to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by Commonwealth and NVC) and the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora amp fauna expert advic e if warranted In add ition the Contrac tor s EMP will identify based on a risk assessment which specific mitigation and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations is recorded

Fishway

81 One of SA s river hea lth ob jec tives under the River Murray Ac t is Barriers to the migra tion of native species within the River Murray system are to be avoided or overc ome (pg 3shy36) The weir would obviously impede the migration of native species without appropriate measures eg fishways

Response As explained in the Supplementary EIS a fishway is now included in the design for the temporary weir SARDI have indicated that they have sufficient knowledge to be able to design a fishway without the need for further site survey work

82 On pg 5-5 the EIS says that no provision is necessary for fish passage

Response See response to 81

83 The weir may impede upstream movement of juvenile and adult (spawning) Murray Cod and would possibly affect the downstream drift of larvae into if lake if spawning in the

Supplementary EIS for the temporary weir near Pomanda Island -81-

river was to occur (pg 7-29) possibility of fishway to allow larvae movement or other mitigation measures

Response See response to 81

84 On pg 13-12 the EIS says that the weir is expected to limit migration abilities

Response See response to 81

85 Why wouldn t Murray Cod use the fishway (Tab le 15-9 pp 15-2526)

Response Due to concerns about the lack of a fishway a design process has been initiated with the assistance of consultants to determine a suitable design concept that would allow passage of both NES and other fish species A concept design is expected to be available in July 2009 The inclusion of a fishway has a number of challenges not the least of which is the initial desire of the fish specialists to pass all the normal flow of approx 1 GLday through the fishway rather than over the spillway

86 Construction of the weir embankment begins when water levels in Lake Alexandrina are between -05m and -10m AHD (pg 5-11) however on pg 12-17 it says construction is preposed to commence when lake levels are at -11m AHD which will occur in October 2009 according to Figure 1-3 and then in Table 16-1 on pg 16-2 it says that construction is proposed to commence at 9 months before Lake Alexandrina is predicted to reach shy15m AHD

Response We will commence work at the latest date regardless of the water level that will allow closure of the river by the required deadline date It is expected to take approx 9 months from the award of contract to closure of the river but the weir construction will not be completed until a number of months after the closure date

87 2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Response South Australia is guaranteed 896 GL of dilution and loss flow plus 201 GL of Critical Human Needs reserved from 2008-09 The figure of 940 GL was a possibility in December 2008 but should not be used

The graphs provided clearly state 896 GL flow for 2009-2010

88 A dilution flow of 696 GL per year is available to SA which is used to maintain salinity levels at Murray Bridge below 1400 EC (pg 2-13) however on pg 4-5 it says than 200 GL in addition to the 696 GL is needed to maintain the salinity at this level at Murray Bridge on pg 10-7 it says that 695 GL is the dilution flow

Response The dilution and loss component of Entitlement Flow guaranteed to South Australia under the Murray-Darling Basin Agreement is 696 GL per year This does not meet the normal system losses within South Australia (average about 1130 GL per year) and this flow does not dilute salinity sufficiently to maintain lt1400EC at Murray Bridge Modelling has shown that an additional 200 GL is required to maintain salinity at Murray Bridge at lt 1400 EC (ie a total flow of 896 GL)

As stated in the response to question 9 South Australia is now guaranteed a flow of at least 896GL during 2009-10 The 896 GL includes 201 GL extracted for Critical Human Needs

Note that the 201 GL for Critical Human Needs serves a dual purpose in that it also contributes to the dilution of the salt loads as well as being extracted mainly in the lower reaches of the river for use in the potable water supply system

89 The text on pg 2-15 says that it is predicted that by May 2009 salinity in Lake Alexandrina will be about 7260 EC however Fig 2-11 on the same page and Fig 1-4 on pg 1-4 show that salinity is predicted to reach only just over 6000 EC by May 2009

Response Both graphs are the same and by May 2009 it was projected that the salinity would be around 6000 EC Current salinities indicate that this projection will be accurate The figure of 7260 EC on page 2-15 is incorrect and is corrected in the Errata

90 It would require 220 GL in 200910 and 365 GL in 201011 to maintain the lakes at 10cm above the critical acidification level [ie maintain the lakes at 1-4m AHD (sic)] however it is unclear if this means water flowing over the weir or additional water purchased from upstream (pp 4-78)

Supplementary EIS for the temporary weir near Pomanda Island -82-

Response South Australia is committed to providing a minimum River Murray flow of 350 GL per annum to Lake Alexandrina via Wellington This minimum flow is required to maintain potable water quality (salinity not exceeding 1400 EC) at the SA Water Corporation major pumping station at Murray Bridge

The cessation of pumping from Lake Alexandrina to Lake Albert preserves approximately 170 GL per annum in Lake Alexandrina and reduces the additional water requirement for 200910 from 220 to 50 GL and the requirement for 201011 and subsequent years to 195 GL per annum The 170 GL annual savings is a subset of the 350 GL annual commitment

The additional 50 GL (200910) and 195 GL (201011) requirements are over and above the 350 GL commitment and could be sourced from improvements in River Murray flows improvements in eastern Mount Lofty ranges tributary flows better than worst-case rainfall directly over Lake Alexandrina (Lake Albert is now under alternative management) better than worse case evaporative losses and purchases from intra and interstate

91 In 2007-08 SA was supplied 1564 GL of water and the River Murray supplied 95 of this (Table 1-1 pg 1-2 2) however on pg 2-4 it says that in 2007-08 SA Water provided SA with over 176 GL of water 95 of this was sourced from the Murray

Response Table 11 may be poorly labelled The figure of 1564 GL in 2007-08 is the demand from the Metropolitan Adelaide Water Supply System It includes water pumped through the Mannum Adelaide pipeline system and the Murray Bridge Onkaparinga pipeline system so therefore covers Adelaide plus the surrounding areas supplied from these pipelines The 176 GL figure in 2007-08 represents the above demand plus the usage from the other two major pipeline areas supplied from below Lock 1 (ie Swan Reach amp Tailem Bend)

92 On pg 2-12 the EIS says that in 2006-07 SA Water provided SA with just over 245 GL of water approximately 90 of which came from the Murray however in Table 1-1 on pg 1-2 2 it says SA used 1805 GL 79 of which came from the Murray

Response See Response to 91 above

Supplementary EIS for the temporary weir near Pomanda Island -83-

Supplementary EIS for the temporary weir near Pomanda Island -84-

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report

85

1 Introduction

Community Consultation Report purpose The Community Consultation Report is a companion document for the Supplementary Environmental Impact Statement (EIS) for temporary weir near Pomanda Island This Report is the record of activities completed during the public consultation period and a record of the submissions received on the draft EIS

This document demonstrates that the Department for Environment and Heritage (DEH) created a public interest context for the Environmental Impact Statement process

The Department gathered processed and responded to public submissions so that the Supplementary EIS was appropriately produced

Objectives for this Report are

to meet the requirements of the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act)

to record the actions of the Community Consultation process

to record all submission summaries and a response to them This is a significant aspect of the Community Consultation Report (Appendix IX)

to demonstrate that a diligent transparent and effective process was in place which optimised receipt of public submissions relevant to the draft EIS

Summary This document overviews

four Community Information Sessions about the Draft EIS for the general public targeted consultations with Ngarrindjeri and ten other specialist groups media generated during the consultation period processes for receiving submissions and for developing the Supplementary EIS

2 Community Information Sessions Advertising and materials distribution prepared the way for the Community Information Sessions

Community Information Sessions were advertised using newspaper advertisements the DEH website and the Coorong Lower Lakes and Murray Mouth Project (DEH) email Bulletin lists (See Appendix VI)

Draft EIS materials (CD hard copy Executive Summary) were distributed widely free of charge The full text Draft EIS was also made available in appropriately targeted local government offices and schools and a number of full text Draft EIS Appendices were also available Hard copy Draft EIS were available for $100 from one Adelaide retail outlet (See Appendix VI Distribution List)

Four Community Information Sessions were held as follows

Murray Bridge Tuesday 24 March 2009 1000am - 1230pm Uniting church Worship Hall Registered attendees 50 people

Meningie Tuesday 24 March 2009 300pm - 530pm Meningie Bowling Club Registered attendees 47 people

Goolwa Friday 27 March 2009 1000am - 1230pm Centenary Hall Registered attendees 93 people

Clayton Bay Friday 27 March 2009 400pm - 630pm Clayton Community Hall Registered attendees 53 people

Supplementary EIS for the temporary weir near Pomanda Island -86-

A total of 243 people attended the four Community Information Sessions

The agenda for these meetings were as follows

Community Information Sessions Agenda

Facilitator Lindsay Holmes (Meeting Success)

Session Length 25 hours

Timing Task Responsible person

(mins) 5 Welcome and Ground Rules Lindsay Holmes Welcome to Country 5 Explain purpose of Session Peter Croft 5 Introduce specialist panel Lindsay Holmes 20 Explain session agenda and process Hon Dean Brown

Water Presentation 25 EIS introduction presentation Russell Seaman 5 How to respond to the EIS Peter Lumb 5 Explain small group purpose Lindsay Holmes 15 Tea Break 20 Work in small groups Lindsay Holmes

Groups identify and prioritise questions for resourc e peop le

60 Resource people answer questions Chaired L Holmes 5 Meeting thanks and closure Peter Croft

Explanation of the agenda

The purpose of the Community Information Sessions was to provide information about the EIS process and to assist people in preparing their written submission (comment) on the draft EIS It was made clear that the sessions were about gaining information rather than making verbal public comment on the draft EIS

A range of options for lodging submissions was presented

At each Community Information Session there was a panel of five or six specialist resource people

Supplementary EIS for the temporary weir near Pomanda Island -87-

The panel was drawn from the following

Peter Croft DEH Director Coorong Lower Lakes and Murray Mouth Projects

Russell Seaman DEH Manager Environmental

Dr Kerri Muller Contract Ecologist

Ross Carter SA Water Manager Major Projects

Glynn Ricketts DWLBC Environmental Water amp Infrastructure

Judy Goode DWLBC River Murray Environmental Manager

Hon Dean Brown Drought Reference Group

Premier s Spec ia l Advisor on Drought

Paul Harvey Murray Darling Initiative

Program Leader

Jan Whittle SA Murray Darling Basin NRM Board

River Murray Environmental Manager Unit

The panel of specialists was introduced early in each meeting prior to two major presentations

Russell Seaman gave a PowerPoint presentation which overviewed key aspects of the draft EIS for the proposed temporary weir near Pomanda Island

The Hon Dean Brown gave a PowerPoint presentation which provided a Murray-Darling Basin water issues context for the proposed temporary weir

Participants formed groups of eight with a trained DEH facilitator The purpose of the group fac ilita tion was to write questions on la rge post-it notes These questions were to be sorted and answered by the specialist panel

As group facilitators wrote questions the questions were continuously collected and placed on a wall Specialist panel members gathered and discussed who would be the most appropriate panel member to answer each question Like-questions were assembled with like Duplicate or overlapping answers were avoided

The meeting regathered and the specialists answered questions in an open manner

DEH provided a light meal at the end of each Community Information Session Community members were invited to stay on after the meeting to informally discuss issues and ask questions of the specialists Many members of the public accepted the invitation

This meeting format allowed all community members the opportunity to ask questions hear answers from people with specialist knowledge and then to engage with them further This was a successful format for the purpose of sharing information A large number of questions were answered and the community had maximum exposure to specialist panel members Panel members and community members generally responded favourably to this format

The records of these meetings include the wording of each question submitted to the specialist panel (Appendix IV) A summary of broad indicative categories of questions are included in Appendix IV including a graph consolidating answers from the four Community Information Sessions

People who attended the Community Information Sessions were invited to pre-register via email at eisdehsagovau or to register through an EIS 1800 number hotline (Appendix VIII) Registrations were sought to ensure that venues had sufficient capacity there was a sufficient number of group facilitators and so that catering was adequate Registrations were also accepted on entry and all registrants were supplied with a

Draft EIS Executive summary

CD containing a submissions cover sheet the Executive Summary the full text Draft EIS and all Appendices of the Draft EIS and

paper summary of the main PowerPoint Draft EIS presentation

Registration also provided the option for people to provide an email address so that they could receive Coorong Lower Lakes and Murray Mouth project updates

Supplementary EIS for the temporary weir near Pomanda Island -88-

In addition copies of Sim T and Muller K (2004) A Fresh History of the Lakes Wellington to the Murray Mouth 1800 to 1935 SA Murray Darling Basin Natural Resources Management Board Government of South Australia were available to registrants courtesy of the MDB NRM Board

3 Targeted Meetings The Ngarrindjeri People individually and collectively are involved in ongoing consultation about the about the Draft EIS for the proposed temporary weir near Pomanda Island Consultation about the Long Term Plan for the Coorong Lower Lakes and Murray Mouth will be ongoing

Ten targeted meetings were held between 2 February and 2 April 2009 Two meeting were held in Adelaide and eight were in the region (Appendix III)

The targeted meetings were attended by Peter Croft Director Coorong Lower Lakes and Murray Mouth Projects and Russell Seaman Manager Environmental (Department for Environment and Heritage) Peter Croft briefly discussed the developments leading towards the Long Term Plan for the Coorong Lower Lakes and Murray Mouth while Russell Seaman provided the PowerPoint presentation used for the Community Information Sessions but tailored the presentation towards the interests of particular audiences Brief records of these meetings appear in Appendix V

In each case these targeted meetings were scheduled meetings which allocated time on their agenda for the additional presentations about the Draft EIS and the Long Term Plan

4 Overview of media articles (see Appendix VII) This section provides the media context during the time leading up to the opening for public comment on the Draft EIS for the proposed temporary weir near Pomanda Island (12 March) to the close of the comment period (9 April)

In January and February 2009 med ia foc ussed on d isc ussions about flood ing the Lower Lakes Two of the 15 stories provided mention of the proposed temporary weir Through March when the Draft EIS for the proposed temporary weir near Pomanda Island was released 18 of the 20 articles focussed on the proposed weir Some media reporting (as summarised by Media Monitors) did not clearly differentia te between the EIS for the flood ing of the Lower Lakes and the EIS for the Proposed Temporary Weir indicating and exacerbating some public confusion

Main discourse The South Austra lian Government s ma in message was tha t the weir is a last resort tha t will only proceed if absolutely necessary in a worst case scenario situation The South Australian Government is committed to seeking a fresh water solution - they do not want to build the weir

A consistent criticism of pursuing approval for the weir is that it indicates that the South Australian Government has given up on a freshwater solution The media surveyed indicates that a fresh water solution is the preferred and only suitable option If the South Australian Government was serious about providing a solution media discourse suggests they would use the money to purchase water rather than for construction of the proposed temporary weir

Many who are opposed to the weir are of the opinion that the government has already made its decision and the weir will go ahead

Other issues raised There were several other issues raised in the articles including

the proposed temporary weir will cut off the River Murray from the Lower Lakes (one article)

there are alternatives to the weir such as storm water harvesting and more water efficiency (one article)

if the weir is built it is a temporary weir and temporary solution and the final decision on the weir will come six months prior to decision to flood the lakes (one article)

the number of regulators and weirs being planned in addition to the proposed temporary weir Clayton Finniss Latham Point Goose or Goat Island (two articles)

Throughout the majority of articles the weir was referred to as the weir or the Wellington weir and approximately 10 per cent of the time it was called the Pomanda weir

Supplementary EIS for the temporary weir near Pomanda Island -89-

A media release by the Federal Minister for Environment Heritage and the Arts mentioned the need for a long term vision and noted that the Australian Government has committed $200 million from its Water for the Future Plan to assist in the planning process and an additional $10 million towards the development of a long term plan for the Coorong and Lower Lakes

Two media reports expressed concern about the triggers to remove the proposed temporary weir saying that unless increased salinity and acidification levels are addressed and there is freshwater released into the lakes one of the triggers that salinity levels drop below 3000EC - will not be able to happen

Summary

Media analysed

Medium (Total) Channel Number ABC 16 5AA 5Radio (22) Triple M 1 9 Network 2 10 Networks 1Television (4) ABC 1 1 Independent Weekly 1 Adelaide Advertiser 1 Stock Journal (Regional) 3 Times Victor Harbor 1 Murray Valley Standard 1

Print (8)

Lakelander 1

Media release The Hon Peter Garrett Minister for the Environment Heritage and the Arts (one)

Four were regional stations five were Adelaide metropolitan stations and seven were both Adelaide metropolitan and regional stations

Total - 35

5 Receiving submissions and developing the Supplementary EIS The Draft EIS was open for public comment from the 12 March to 9 April 2009

The public were invited to provide written submissions as emails as emails with word attachments or to send hard copy using a free post address

Seventy submissions were received from the public There were 49 individual submissions 18 from community and other organisations and three from local government All submissions are available on DEH website wwwenvironmentsagovaucllmmsubmissions-receivedhtml

Submissions were uploaded twice per week during the public comment period Submissions were listed by author or organisational author as per Appendix I and Appendix II

Supplementary EIS for the temporary weir near Pomanda Island -90-

Timeline of the post-Community Consultation period

9 April Acceptance of submissions closed at 5pm

10 13 April

During the four days over Easter submissions were read summarised and a statement provided in a response column Key words in submissions were identified Summaries and responses were entered into a specially prepared Microsoft access data base Summaries from the data base are provided as appendix ix

14 April

A list of key words was compiled from the access data base The data base was then searc hed by a ll relevant key word s All sub missions jud ged to be in sc ope and a ssoc ia ted with a key word or key word string were then assembled Submissions were then sent to thirteen specialist writers Most writers had attended a meeting at which the requirements for preparing responses were outlined and the constraints of the tight timeline emphasised Other writers had individual briefings Writers could choose to receive hardshycopy of all relevant submissions or access copy on the internet The broad objective provided to writers was to create an over view summary of issues in response to issues associated with the key words for which they were responsible

15 17 April Specialist writers had three days in which to write their over view summaries

17 April Summaries were returned for compilation into the supplementary EIS and an executive writer and assistants then had six days to create an integrated supplementary EIS

24 April A draft of the supplementary EIS was prepared and sent to specialist writers for comment to be returned by 12pm Monday 27 April

27 April

Comments were incorporated into the draft of the supplementary EIS and a new version prepared for a briefing meeting on Tuesday 28 April The objective of this meeting was to facilitate final changes before chief executive and ministerial sign off

30 April The supplementary EIS was prepared and sent to the chief executive and the minister s offic es

Supplementary EIS for the temporary weir near Pomanda Island -91-

Supplementary EIS for the temporary weir near Pomanda Island -92shy

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report ndash Appendices

93

Appendix I Submissions received Individuals

Surname First name Suburb Date Submission

number

Cooke Roger Goolwa 29032009 PTW00001

Galea Michael Clayton Bay 30032009 PTW00002

Fargher Philip Norwood 01042009 PTW00003

Zoerner Andrew Prospect 03042009 PTW00004

Smith Douglas Goolwa 03042009 PTW00005

Rees Melanie Henley Beach 03042009 PTW00006

Brisco Mike Campbelltown 04042009 PTW00008

Moyle Ian Woodcroft 05042009 PTW00009

Harvey Richard North Adelaide 06042009 PTW00011

Richards Sally Finniss 06042009 PTW00012

Giles Trevor Langhorne Creek 06042009 PTW00013

Lower Brenda Goolwa 06042009 PTW00014

Michelmore Frederick Gordon Middleton 07042009 PTW00015

Lucas Ann Goolwa 07042009 PTW00016

Jones Glen Adelaide 07042009 PTW00017

Fenton Derek Finniss 07042009 PTW00019

Tjukonai Vesper Meningie 07042009 PTW00020

McFarlane Keith Tailem Bend 07042009 PTW00021

Read Tony Beaumont 07042009 PTW00023

X Mick Mannum 08042009 PTW00024

Hartnett Anne Milang 08042009 PTW00025

Whitehead Alexander Hindmarsh Island 08042009 PTW00027

Fairweather Peter Adelaide 08042009 PTW00028

Thomas Robert Goolwa 08042009 PTW00029

Carroll Barbara Happy Valley 08042009 PTW00030

Jones Henry Clayton 08042009 PTW00031

Bagley Chris Milang 08042009 PTW00033

Yelland Liz Milang 09042009 PTW00034

Vonow Lynton Lobethal 09042009 PTW00035

Trigg Ruth Normanville 09042009 PTW00036

Yelland John Milang 09042009 PTW00037

Brooks Bruce Finniss 09042009 PTW00038

Walker Keith Yankalilla 09042009 PTW00039

Harden Trevor Finniss 09042009 PTW00041

Allnut Bruce Finniss 09042009 PTW00042

Shillabeer Neil Oakbank 09042009 PTW00043

Heyne Ron Goolwa 09042009 PTW00044

Showell Jacqui Goolwa Beach 09042009 PTW00048

South Cecily Milang 09042009 PTW00049

Moon Silver Finniss 09042009 PTW00051

Supplementary EIS for the temporary weir near Pomanda Island -94-

Surname First name Suburb Date Submission

number

Hunter Rex 09042009 PTW00052

Bradford Karen Milang 09042009 PTW00059

South Mike Milang 09042009 PTW00060

Belford Beryl Mt Barker 09042009 PTW00063

Hobbs Elizabeth Goolwa 09042009 PTW00064

Vizard Talina Victor Harbor 09042009 PTW00065

Carter Carlsa Bridgewater 09042009 PTW00066

Scobie Keith Meningie 09042009 PTW00069

Russell Ruth Magill 16042009 PTW00070

Young amp Jury Mike amp Ken Goolwa 16042009 PTW00071

Submission received under special circumstances Submission sent prior to end of community consultation period

Supplementary EIS for the temporary weir near Pomanda Island -95-

Appendix II Submissions received Organisations

Organisation Date Submission

number

Southern Alexandrina Business Association Inc 04042009 PTW00007

Signal Point Riverine Environment Group Inc 05042009 PTW00010

Alexandrina Council 07042009 PTW00018

The Marina Hindmarsh Island 07042009 PTW00022

SA MDB NRM Board 08042009 PTW00026

Rural City of Murray Bridge 08042009 PTW00032

Australian Institute of Landscape Architects 09042009 PTW00040

Ngarrindjeri People 09042009 PTW00046

DTEI 09042009 PTW00047

Environmental Defenders Office (SA) Inc 09042009 PTW00050

The Coorong District Council 09042009 PTW00053

River Lakes Coorong Action Group Inc 09042009 PTW00054

Nature Conservation Society 09042009 PTW00055

Murray-Darling Basin Authority 09042009 PTW00056

Australian Democrats 09042009 PTW00057

Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

09042009 PTW00058

PIRSA Fisheries 09042009 PTW00061

Natural Heritage Trust 09042009 PTW00062

Conservation Council of South Australia 09042009 PTW00067

Goolwa District Ratepayers and Residents Association Inc 09042009 PTW00068

Supplementary EIS for the temporary weir near Pomanda Island -96-

Appendix III Participants and notes from Targeted Meeting Sessions

Local Knowledge Reference Group

Date Wednesday 4th February 2009 1100am 200pm Location The Monastery

In attendance Dean Brown Bill Paterson Prof Diane Bell Mike Geddes Mike Hammer Neil Shillabeer Paul Davis Rebecca Lester Rob Fitzpatrick Sebastian Lamontagne Mary-Anne Healy

Summary of comments or issues

Draft EIS was presented to the Local Knowledge Reference Group (LKRG) - draft is confidential

Consequences of weir removal and ability for system to recover

Scope of EIS should extend beyond matters of NES

Management strategies for potential flooding should be addressed in the EIS

Approvals process

Concerns regarding high water mark in relation to the causeway and Ramsar boundaries

Apologies were given to the group in regards to the lack of communication around the draft EIS in the past

Discussion

Raised issue re water levels relating to the barrages should say 7000 years

Changed the word ing to levels never rec orded ra ther than not seen sinc e the c onstruc tion of the barrages

No work has been done on how to recover the environment after the removal of the weir

Not going to remove the roads and tracks

Impacts locally not Ramsar site

Weir sinks over time

Remove down to bed level should not be any impediment to what was originally there

Will take time but should result in no impact

Weir will be there for 3 years

SA Water suggests there will be minimum impact

Mud waves will cause impact but will be transported away from sedimentary processes

Increased sedimentation as a result of the structure and disagreement that there will be a significant impact after the removal

The need to conserve the Ramsar wetland and what might be the implications Is it just going to go ahead Worried about the significant damage and if the system will ever recover

Cannot assess what has been done Needs clarity about the purpose of the group

Issues around rates of change and thresholds associated with the weir Also life stages and ecological character

Limited scope about this in the EIS only addresses matters of NES

Will edit the factual errors

Will help edit as well

Worried about experts need for higher level expertise for public comment period

Supplementary EIS for the temporary weir near Pomanda Island -97-

What if there are natural water flows floods Recovery Should be reference in the document to flood event happening and the ability to manage that

Agrees with Bill and need to understand and have something in place if there is a flood and removal of the weir

States that the draft EIS seems to have solid blame on the drought but over-allocation and excessive use are contributing factors as well Look at the language and justification of the EIS Issues about the decision making Commonwealth SA Gov

Understands that it goes to Commonwealth and SA Govt makes the decision Need approval under the EPBC Act

Need approval for MDBA and Minister

Interested to see if the Ramsar site is actually the boundary of where the weir will be built and the implications of that and whether the weir can take place

Drew a diagram of where the cadastral boundary is and where the causeway and proposed temporary weir are Assuming this is where the high water mark is

The whole group are concerned that the high water mark is actually exceeding where the causeway is and if that is the case the causeway and where the weir will be built will actually be in the Ramsar site

Supplementary EIS for the temporary weir near Pomanda Island -98-

Meningie Community

Date Thursday 5th February 2009 700pm 1100pm Location Football Club Rooms Meningie

In attendance Approximately 200 locals Andrew Beal Prof Diane Bell Robyn McLeod Dean Brown Peter Croft AProf David Paton

Summary of comments or issues

Dean Brown Prof Diane Bell Andrew Beal Peter Croft Robyn McLeod and AProf David Paton each gave a short presentation on current issues based around the Coorong and Lower Lakes providing management options

Summary of conditions and long term plans to help secure a future for the Lower Lakes Coorong and Murray Mouth

Following the presentations the community members were given the opportunity to ask questions of the presenters

Neil Shillabeer facilitated the meeting

The meeting was a little heated and closed around 11pm with people staying to speak with the presenters and other expertsofficials

Questions and discussion

What can we do to make other states realise that we are in a dire situation and that we need more water

What is temporary

Groundwater

Over-allocation

Where is the support for the community

Ngarrindjeri hurting no one is speaking with them or the community

What are the government officials going to do to help the community

Yes they are helping the environment but not the economic values and people

Why c an t they have a p ipeline like the other side (referring to the Langhorne Creek irrigation line)

Why haven t they been told about the c osts involved with this p ipeline

Lake Albert s a lloc a tion

What level will the Lakes be once the weir is in place

What are the trigger points for removal

If the weir is built are they going to put in fish ladders or will they be blocked

If Lake Alexandrina gets lower how are they going to continue pumping into Lake Albert

If seawater is let in how are they going to deal with the millions of dead fish and the clean up

How are they going to fix South Austra lia s own wa ter issues and a lloc a tions Need to address what is happening here before we blame upstream

Supplementary EIS for the temporary weir near Pomanda Island -99-

Milang Community

Date Thursday 12th February 2009 130pm 500pm Location Milang Institute Building

In attendance Anne Hartnett Dianne Bell Ken Follett Tim Trevorrow (APOL) Rowena Brown Dr Rob Fitzpatrick Bruce Brooks Graham Gates Lesley Fischer Tony Randall Peter Alexander Wayne Brown Carol Richardson Greg Lundstrom Richard Owen Peter Croft Clare Manning Russell Seaman Karyn Bradford Kathryn Rothe Shirley Smith Liz Barnett Simon Oster

Summary of comments or issues

The Lower Lakes Partnerships for Recovery

Lower Lakes communities are keen to use their knowledge labour and community infrastructure to bring about Lakes and River recovery

The community seeks partnership with government to

- Rescue and remediate degraded environments

- Impede further degradation

- Instigate environmental management and development practices

- Address current and future effects of climate change

Projects have been identified for both immediate and long term implementation

Revegetation Revegetate areas subject to Acid Sulfate Soils with plants having low impact on soil

saturation in

- Priority areas in Finniss River and Currency Creek

- Receding lake shores

- Known ASS hot spots

- Spots at-risk of drying out wind erosion and sun exposure and affected by stock access

Revegetation capacity building Collect seeds for replanting (native plants)

Undertake at-risk plant rescue and propagation

Purchase propagation and planting of annuals

Plant large trees away (upwind) from Lake edge as leaf litter will provide sources of organic matter and iron to Lakes (builds resilience)

Flora and fauna protection Control of increased feral populations arising from revegetation

Establish refuges for endangered flora (and fauna)

Weed control

Protecting fringing vegetation Protect lake revegetation areas from cattle

Protect cattle from poor quality drinking water

Environmental remediation Community Acid Sulfate Soil treatment projects

Source local limestone for application to ASS

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Nurture and capture knowledge

Train communities to identify and map plants useful for land protection and remediation

Create systems for long term monitoring of soils vegetation growth and regrowth

Establish community survey systems to map current and changing status of soils

Collect and contribute data that will enhance GIS data banks and veracity

Create local administrative and data collation processes to manage the above incorporating two-way communication and mutual benefit from data

Monitor water use to aid in the beneficial allocation of water resources

Supplementary EIS for the temporary weir near Pomanda Island -101-

Peter Croft s Murray Futures update for the Lower River Murray Drought Reference Group representatives

Date Thursday 26th February 2009 200pm 500pm Location Murray Bridge

Summary of comments or issues

Status of Environmental Impact Statement for the proposed temporary weir near Pomanda Island

Timelines for the project

Community involvement

Timelines for the Long-Term Plan to secure a future for the Coorong and Lower Lakes Ramsar site

Community Action Planning

Information provided

EIS has not yet been finalised or lodged but is in the critical final stages and is expected to be lodged shortly

We will be holding some Community Information Sessions in the 4th week of March (pending approval from the Commonwealth)

There will be a media release of notices via national state and local press announcing the sessions locations and times to inform the communities (subject to Commonwealth approvals)

These sessions are to summarise the draft EIS allow community members to ask technical questions of some specialists and provide advice to the community on preparing submissions on the draft EIS

A Reference group has been developed (The Long-Term Plan Reference Group) and brings together community leaders scientists and government staff with a view to develop a long-term plan to secure a healthy future for the Coorong and Lower Lakes Ramsar site

This is an important first step to help identify a realistic sustainable future for the region one that will address the environmental community and economic values that are important to the region

Our aim is for a coordinated management response for the future of the Coorong and Lower Lakes And involving the community along the way is critical to the success of our work

We are aiming for a 1st version of the Long-Term Plan ready for public consultation in April We will ensure that a range of different communities get on the list of possible locations (eg Milang and Langhorne Creek)

Notices of such events will be distributed through the national state and local press as well as our website

On 12th February we met with representatives of Landcare Groups and Local Action Planning Groups to discuss proposals for community action around the Lakes

A number of areas of action were identified and a small team with representatives from DEH Regional Conservation Team and LAP Coordinators will flesh out the actions in more detail

A Plan of Action is being developed for trial projects with potential funding of $100000 that may be available to support some preliminary work We plan to finalise the details and get activities rolling ASAP

Supplementary EIS for the temporary weir near Pomanda Island -102-

Ramsar Taskforce Committee

Date Friday 13th March 2009 1100am 1230pm Location Wyndgate

In attendance Ramsar Taskforc e c ommittee members Peter Croft Russell Seaman and Peter Lumb

Summary of comments or issues

Peter Croft briefly introduces EIS processes and distributes draft EIS community development and hard copy Executive Summary

Russell Seaman gave a presentation in the EIS and asks for feedback

Broad range of questions ranging from fish ladders in the weir to alternative options

Questions and discussion

Will the Supplementary EIS be made public

Will the Australian Government then require community consultation on the Supplementary EIS

Why is there such a short time for public comment on the draft EIS

What do you mean by environmental hotspots

Has any thought been given to a natural causeway near Pomanda Island

Is the weir site within the Ramsar site

Where will the water come from to flow over the weir if a weir is built

Comment about the importance of fish ladders

Emphasise that the weir is not a trigger for sea water incursions

Emphasise that the presentation is mostly based on worst case scenarios

The EIS must mention over-allocation

Emphasise actions taken or about to be taken when possible

Emphasise terrestrial vegetation more as well as Lake bioremediation

How much employment will be created in the region

Is it possible to have Councils administer vegetation and bioremediation projects rather than the Attorney-General

Supplementary EIS for the temporary weir near Pomanda Island -103-

Scientific Advisory Group (SAG)

Date Monday 16 March 2009 930am 1130am Location L5 81 Flinders Street Adelaide

In attendance Rebecca Lester Ingrid Franssen Mardi van Wielan AProf David Paton Adrienne Frears Glynn Ricketts

Summary of comments or issues

Decision trees and timelines

Alternative options

Trigger points

Questionscomments

Needrequest to set aside 5 for science to underpin management

Lake Albert needs early consideration

Need a decision tree as some actions are alternatives or consequent actions

Link decision tree to timeline and water flows

Need to account for measures for Long Term Plan to prevent the need to do reactive work again in ten years

Assumption restore wetland functioning to build resilience

Focus on upper Finniss and Currency dam bypasses upstream modelling water allocation and managing low-flows

Scientific Advisory Group can assist with advice if needed

Pomanda weir s estimated c ost $150m

Need to find out if there is a major ecological downfall if the acidification occurs

Reduce or stop pumping for winter lower evaporation and stop wind erosion

Apply limestone only when triggers are reached

Any ideas for the Long-Term Plan will influence the second version of the Plan

Ephemera l systems a re na tura l Lake Albert is a termina l wetland no outflows

A more complete document will allow a more thorough examination of the situation (possibly in April)

Which trigger will come first

Is a virtual weir still on the table

Does the dam allow for a fishway

Supplementary EIS for the temporary weir near Pomanda Island -104-

South Australian Murray-Darling Basin Natural Resource Management Committee

Date Thursday 19 March 2009 930am 1200pm Location Murray Bridge

In attendance SA MDB NRM Board members Peter Croft Kerri Muller and Lindsay Holmes

Summary of comments or issues

Questions focussed on conditions climate and the environment

Questionscomments

How will the weir be deconstructed

Can we separate the effect of the weir from the effect of the drought

Is the 350GL of wa ter over the weir in c urrent c ond itions

Will water go into the Lake when there are disconnection issues

Will there be a short-term increase in salinity while the pool fills

What is the current river level

Does the EIS consider scouring

Is flooding risk considered (in EIS)

Mud waves are a major issue

Why will construction of the weir be worse during summer

What are other alternatives

When does the EPBC Act review end

Can we make a definitive statement about what happens to the wetlands

Supplementary EIS for the temporary weir near Pomanda Island -105-

Icon Site Community Reference Committee

Date Monday 23rd March 2009 930am 1200pm Location Langhorne Creek Bowling Club

Summary of comments or issues

Questioned the science and experts available

Alternative options were discussed

Questioned engineering aspects of the weir

Russell Seaman presented an overview of the draft EIS

Group showed concern for repercussions of actioninaction

Questions asked

Coorong evaporation 200GL of fresh or seawater

Who will DEH engage as experts to advise on seawater incursion

What will DEH be basing their knowledgeevidence on in regards to the seawater incursion

Has anything like it been done before

Mulching

Limestone locally sourced

Coorong North lagoon monitoring and ASS who is monitoring and what is being done to remediate the hyper-saline conditions

To what extent can we replicate what was in the past southeast freshwater

Salinity in the south lagoon would the level allow Rupia sp to establish itself

Mechanical mouth operation as opposed to dredging has this been considered

What are some other options

Has the department looked at Vortex sand pumping

Will there be culverts between the Lakes through the causeway for water to flow via wind seiching

More research needs to be done has the Department considered engaging the local knowledge Don t dup lic a te researc h

If temporary why are you considering installing fish passages in 5 years time Should that not be done at the time of the weir installation

What levels are you looking at for the lakes

Supplementary EIS for the temporary weir near Pomanda Island -106-

Russell Seaman presentation Overview of the draft EIS for the temporary weir near Pomanda Island

Questions asked Why 01 AHD for the spillway

At what Lake level will it start acidifying

Should we have a lower weir

What is the risk of salt levels increasing when you stop the flows for 3 months

Will ground waters be coming in

What about the banks collapsing

What is the water quality of ground water and will it contaminate the Lakes

What happens if water flow exceeds 15GL per day ie if flood occurs will the structure cope

How quickly will the structure sink is it 1m per year

Will the weir be in place by 1st January 2010 as the graph indicates

When is -15 AHD expected

Has the Premier decided to buy water to see the Lakes through to winter 2010

Have you factored in the local rainfall flows within Currency Creek and Finniss

Is there an indication of seepage of ground water into any region of the Lakes

Have you looked at Biochar for remediation purposes

Lime straight pH neutraliser or feed the bacteria

Why not put a carbon source in there as well

Supplementary EIS for the temporary weir near Pomanda Island -107-

Lower River Murray Drought Reference Group

Date Thursday 2nd April 2009 Location Murray Bridge Council Chambers

Chair Dean Brown In attendance 14 Reference Group members 15 people in the Public Gallery

Summary of comments or issues

EIS Presentation by Peter Croft 30 Minutes including questions

Peter Croft presented overview of the draft EIS

Issues relating to seepage

Costs and issues relating to weir construction

Weir removal

Timelines for weir construction

Questions and comments

All questions asked were from Reference Group members with occasional comments from the public gallery

If the weir is built will more wetlands be closed between the weir and Lock 1

Are estimates being made of loss of water to seepage through the cracked levee banks above the weir And will this seepage appear in the Lake

Will it be the case that water will stop flowing over Lock 1 at some stage to facilitate the construction of the weir

Adrian Pederick MP asked who wrote the draft EIS

Member referred to a rumour that irrigation will cease with weir construction

Can you be clear about the cost of the temporary weir if built

Is the cost of the causeway included

Where will the SA Government get the money to construct the weir (Some anxiety that it would be CLLMM money (Comment wasn t c learly aud ib le)

What is the likelihood of a virtual weir

There was a question (inaudible) about the height of the weir above sea level (Was it about the adequacy of the height to secure water supply if the Lake levels rose)

How much of the weir would be removed when decommissioned

Comment about the complexities of start times and the apparent late start to protect water supply

Update on other matters Peter Croft Closing date for submissions on the draft EIS on proposed temporary weir

Promotion of availability of all documents and information sources

The Goolwa Channel referral lodgement is imminent

Actions Application for projects under $120000 April 10

Approvals process for lime-stoning the first flush coming down the Finniss and Currency Creek

Seeding and bioremediation workshop held Tuesday 31 March

Rural Solutions developing a bioremediation plan around both Lakes

Supplementary EIS for the temporary weir near Pomanda Island -108-

Appendix IV Organisations that participated in Community Information Sessions

The Advertiser

Department for Environment and Heritage

University of South Australia

La Trobe University Centre for Sustainable Regional Communities

Native Food

Investigator College

River Lakes and Coorong Action Group Inc

South Australia Murray Darling Basin Natural Resources Management Board

River Murray Boat Owners Association

River Murray Museum of River History

Department for Sustainability and Environment

Wellington Lodge Pty Ltd

Ranges to River NRM Group

Food and Beverage Australia Ltd

Narrung Wetland Monitoring Group

BMT-WBM (Engineering and environmental consultants)

River Lakes and Coorong Action Group

All Land and Livestock

Clayton Bay Community Association

Finniss Catchment Group

Southern Alexandrina Business Association Inc

Coorong District Council

Narrung Dairy Farmers

Southern Fishermen s Assoc ia tion

Clayton Bay Foreshore Committee

SA Water Corporation

Fleurieu Regional Development

Alexandrina Council

University of Adelaide

Supplementary EIS for the temporary weir near Pomanda Island -109-

Appendix V Participants and notes from Community

Information Sessions

Community Information Sessions Agenda

Proposed Locations Meningie Murray Bridge Goolwa Clayton Bay Facilitator Lindsay Holmes (Meeting Success) Session Length 25 hours

Timing Task Responsible person

5 min Welcome and Ground Rules Lindsay Holmes

Welcome to Country

5 min Explain purpose of Session Peter Croft

5 min Introduce specialist panel Lindsay Holmes Explain session agenda and process

10 min Water Presentation Hon Dean Brown

25 min EIS Introduction presentation Russell Seaman

5 Min How to respond to the EIS Peter Lumb

5 min Explain small group purpose Lindsay Holmes

15 min Tea Break

30 min Work in small groups Lindsay Holmes Groups identify and prioritise questions for resourc e peop le

40 min Resource people answer questions Chaired Lindsay Holmes

5 min Meeting thanks and closure Peter Croft

Supplementary EIS for the temporary weir near Pomanda Island -110-

Meningie Community Information Session

Date Tuesday 24th March 2009 300pm 530pm Location Meningie Bowling Club

Questions asked of the specialist panel listed by category

Lake Albert Is pumping going to stop or continue at Lake Albert

In worst case scenario what will be done about Lake Albert if it runs dry

Assuming a weir will be built what actions will be taken to maintain Lake Albert

What is the future for Lake Albert

Why isn t Lake Albert written up more in the d ra ft EIS

River flows Why are upstream tributaries not included in the flow data considering it is the Murray-Darling Basin system (The information is then misleading for Min Garrett)

Inflow figures Are these figures based on whole basin or just the Murray River catchment

Is there information on how much water is coming in to the basin catchment (not just inflows)

Is 350GL guaranteed to come over the weir per annum Is that happening now

How will the weir pool level be maintained ie Where will the water come from Does this relate to water buy back

Why c an t some of the wa ter held on fa rm dams etc be released and peop le use a little less water to maintain levels (federally)

What measures are being considered to improve sharing and saving water throughout the Basin

How much area is considered Murray-Darling catchment

put in place to use alternative storagemake Adelaide less dependent on the Murray

Ramsar How will the Ramsar convention be respected

Australia signed the Japan-Australia migratory birds agreement (also with China) re wetlands of international significance How will the weir effect this agreement

Is government looking at taking control re Ramsar site

Wildlife What happens if there is a fish kill in Lake Albert

Will the weir affect cod numbers and is there a plan to recover this species

Has the magnitude of a fish kill been considered ifwhen the weir is built Consider Lake Albert amp Lake Alexandrina separately

What will happen to the fish turtles etc if salinity increases

Acid Sulfate Soils (ASS) Why hasn t the government looked a t other op tions for remed ia tion for ASS

What is the long term planmedium term plan for Lake Albert and the ASS issue

What is the gas that comes out of the mud in Lake Alexandrina (Three cases of dizziness when exposed to this)

What can be taken out of Menindee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Alternative catchments Adelaide is now taking 90 water from Murray What is being

Wha t c an be ta ken out of Menind ee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Supplementary EIS for the temporary weir near Pomanda Island -111-

Salinity issues What mitigation strategies are in place to mitigate hyper-salination in the Lakes

Salt water sits beneath fresh water How will the salt water flow over the weir

If the weir is pumped is the pumped-out water saltier

Does the salt water layer

How are they going to flush the salts that accumulate in the weir pool

What is the evaporation rate per annum at the present time considering the Lake levels today Is it still 800GL

Rainfall Was there rainfall measured over Lake Alexandrina in winter last year (No rainfall measured by farmers)

Why doesn t the d ra ft EIS mention Lake ra in

Will decreasing the surface area of water in the Lakes reduce rainfall over the Adelaide catchment increasing the strain of Adelaide Hills reservoirs

Proposed temporary weir impacts How is the weir going to be removed

What is the trigger point for the weir decommissioning

Given the modelling and g iven the government dec ides to build the weir why isn t a lock considered Would allow navigationfish passageflow management

Why is there no facility for navigation through the weir

Why a re there no fishways Why isn t it nec essa ry to have fishways

Is the base of the weir stable enough to stop slippage of the structure

How will they monitor the silt on the downside of the weir and particularly with ASS

Will time to fill the weir pool be more than three months (based on worst-case scenario) Will some leak out under the levee banks

When would construction start

What would it cost to move the intake points above Lock 1

Will the weir help mitigate acid soils in the Lower Lakes

Why does the EIS not address much between Lock 1 and the weir in relation to damage of embankmentshabitat above the weir

How can they guarantee that removal of the weir will allow things to go back to the way they were

Social and economic impacts What consideration has been given to sustaining cultural flows for Indigenous people

Are the social impacts of building the weir and low flows being considered in the decision to build the weir

What provision has been made in the EIS for socio-economic impact factors

Seawater If seawater is let in how far into the groundwater will the seawater penetrate What will be the impact on the level of groundwater

How will the weir affect the decision to allow seawater into the Lakes

How does the weir link with the seawater incursion and will it need another EIS

Politics and Government When is the Murray-Darling Basin Authority going to get up and running (currently only a CEO and Chairman) If it were in place then politics will be in order ()

There have been a lot off government bodies set up over the last few years What has their role been and what is their role now

What is the government doing to educate the public

Supplementary EIS for the temporary weir near Pomanda Island -112-

Miscellaneous Have the trigger points been addressed

Will the weir guarantee water for stock from existing pipelines

Will the weir cause impact on the positive impact that wind seiching plays in the system

Do submissions all go together to the Commonwealth

What will happen when a flood occurs at the Narrung pumping station Will it be removed and the channel opened

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 2 fishways) 14 River flowsallocations 11 Salinity issues 6 Lake Albert 5 Wildlife (Fishturtles) 4 Social and economic impacts (one Indigenous) 3 Ramsar 3 Sea water incursion 3 PoliticsGovernment 3 Acid Sulphate Soils 3 Rainfall (Lake rain) 3 Miscellaneous 4

Supplementary EIS for the temporary weir near Pomanda Island -113-

Murray Bridge Community Information Session

Date Tuesday 24th March 2009 1000am 1230pm Location Uniting Church Worship Hall

Questions asked of the specialist panel listed by category

Acid Sulfate Soils (ASS)

What effect will the weir have on the current situation of Acid Sulfate upstream given that the weir will not be constructed within the next three years

How extensive are the potential Acid Sulfate areas

How deep does the lake need to be to prevent ASS

What is the plan to deal with acidification post weir

What is worse Seawater or lake acidification

Salinity issues How will salt get back into the Lakes

What measures will be taken to address salt building up behind the weir (upstream)

How can you handle the salt (that will come down the river) How will it be managed

Have you considered installing pipesregulators to manage salinity at the base of the weir

Wildlife What evidence do we have that the birds will return after construction

Have we calculated impact of extinctions

River flows allocations Is there a lot of water available for sale

Why hasn t temporary wa ter been purc hased

What about buying water as an alternative to a weir

If a weir is built will there be more water allocations in SA

If the weir goes forward who will receive the water that will be saved from less evaporation Will the allocation be more

18 wa ter a lloc a tion Universa l na tiona l standard set a lloc a tion Why isn t there an agreed allocation standard to all usersirrigated Why not a special rule to override current allocation agreements

Has there been an audit on un-metered bores in the Basin and what action is being taken

How much have extractions increased and what were base extractions

Developed methods to estimate inflows model for calculating extractions How much water is prevented from entering the system Where do extractions go Why is there no graph for extractions for entire systems How is the flow calculated Where is this information available

What is the definition of inflows

Where is the water coming from to maintain the level of the weir pool and the river level

What are the differences in water quality in the channel with or without a weir How serious is the situation What about the use of water upstream Over-allocation

Proposed temporary weir Has consideration been given to the weir at Wellington having a fishway

Will the weir pool inundate the wetlands upstream

How will the water and salt discharge over the weir into Lake Alexandrina Spillway Gate

How will the process prevent the build up of algal blooms and nutrients behind the weir

Supplementary EIS for the temporary weir near Pomanda Island -114-

What will build up behind the weir (eg iron etc)

Water hitting the weir what is going to happen

Why a temporary weir Why remove it and rebuild it

When the weir is deconstructed what happens to debris rocks etc

What will the volume of seepage be What are the implications

Will construction of the weir begin in June

What are the trigger points for removal of the weir

Why is a permanent weir not being considered CSIRO says conditions will get worse

How are they going to remove the weir

How is the level going to be maintained as weir is expected to sink in sediment

Why is the weir being build to 01m above sea level

If and when the weir is removed can it be reassembled quickly

How long will the weir take to build

Were other options considered for construction of the weir and what were they

Have you found a solution to the weir foundation (ie mud and construction of the weir at Pomanda Point)

What is the trigger to open the weir

Are the triggers to demolish the weir strict

Why haven t they got sta rted on build ing the weir

Lock Have investigations been made to have a permanent weir with lock with fishway and means of allowing the bottom salt water to be discharged

Has there been consideration of a lock with the weir (or a bypass channel)

Why have we not considered a lock

Why consider a temporary weir when a permanent weir could be constructed with a lock to maintain a navigable river system

Politics government and planning What about the constitutional right that the river be navigable from top to mouth

When will the Murray-Darling be run federally Not by the states

Why not hand over water management to the Commonwealth

When will the government declare this a disaster

What grantsassistance will be provided (eg tourism) Irrigators get support Why not others Industry assistance

Why is the weir being considered as part of a piecemeal approach What about a long-term plan

Is the weir part of the broader management of the Lakes and Murray Wha t s the b igger picture and where does it fit

Why is there not an integrated plan including Goolwa Channel regulators rather than doing it piece by piece

What is the present status of the Goolwa Channel projects

Is there a trigger for putting in a desalination plant at Tailem Bend

How will the remediation be managed and the long-term effect of the silt build-up be dealt with

Will building of the weir delay the equitable distribution of water in relation to other states

If the weir is built what are the triggers for letting in seawater to the Lakes

Riverbanks What measures have been taken to ensure the levy banks do not collapse with the higher river levels

What proactive approach will be taken to care for river banks

Ifwhen we build the weir what about the raising of the head River bank decline

Supplementary EIS for the temporary weir near Pomanda Island -115-

Has there been any consideration given to realigning the Lake Alexandrina shoreline Reduce evaporation in future

Pumping stations

Cost of moving pump stations above Lock 1

Chapter 4 Relocation of pumping stations above Lock 1 (needs clarification)

If they put in the weir will they continue to pump water to Lake Albert

Society and economy What is the impact on peoplecommunities

Why is economic impact not dealt with in the EIS

Miscellaneous What s the likelihood of worst-case modelling becoming irrelevant Is it likely that worst-case modelling is over predicted

Numbers of questionscomments on each topic indicative

Proposed Temporary Weir (Locks 4) 27

River flowsallocations 13

Politics Government (2 Goolwa channel) 13

Acid Sulphate Soils 5

Riverbanks 4

Lock 4

Pumping stations 3

Society and Economy 2

Wildlife 2

Miscellaneous 1

Supplementary EIS for the temporary weir near Pomanda Island -116-

Goolwa Community Information Session

Date Friday 27th March 2009 10000am 1230pm

Location Centenary Hall

Questions asked by the specialist panel listed by category

Wetlands Milang wetlands identified as number one natural resource by Adelaide University It has now been disconnected for two years Why is it not mentioned in the EIS

Will the wetlands between Lock 1 and the weir be filled How much water is needed to fill these wetlands Will the filling of wetlands result in an increase in acid

Bioremediation Are they considering bioremediation rather than building a weir

Impac t of g rasses tha t a re na tura lly g rowing on beac hes of the Lake

River flowsallocations What s being done about the wa ter supp ly

How much inflow into the River Murray in SA comes from SA compared with inflow across the VicNSW border (see figure 0-2 of the Exec Summary)

What flows would be necessary past Wellington to support a virtual weir at AHDs of -15 shy2 -25m

Will the weir be able to withstand a significant flood

How will water flow over the weir and into the Lower Lakes or will it flow through a gate underneath

How much water bypasses the weir if it is built

What will happen to the temporary weir if there is a flood Will it get washed away

Has the sc enario of three months without flow into the Lakes to fill the weir pool been allowed for in determining the trigger date of Jan 2010

Is it possible to have a shorter period where there is no flow over the weir but take a longer time to fill the weir pool

Has the government considered buying water to maintain the annual 350GL to the Lower Lakes

If the Lower Lakes are without water for three months during construction will the government purchase additional water to factor this in

Why doesn t the environment get a wa ter a lloc a tion like every other user

Why does Adelaide not have underground storage or other measures to alleviate the need for taking water from the River and hence for need of a weir

What difference would it make if we moved down to critical human needs rather than gardens and swimming pools

What is the impact of the various private and public water storages when comparing the Federation Drought and the current drought

What proportion of the Living Murray water agreement will reach the Lower Lakes (of the 500GL from 30 June 2009)

Ramsar What is the potential threat to the Ramsar status of the wetlands

Has the Wellington weir been put to Ramsar

Could building the weir lead to international action and delisting

Wildlife (Four questions on fish passage a re listed under Proposed temporary weir )

How do we consider the impact on species which are not listed under the EPBC Act These species are part of the ecosystem and food chain

Has the EIS looked at all species that will be affected eg snakes kangaroos and others

Supplementary EIS for the temporary weir near Pomanda Island -117-

Will the weir reduce flows significantly downstream and continue to adversely affect wildlife already in distress

There will be a spike in salinity in the Lake after disconnection which may lead to fish kill in certain species eg carp Fish kill will give high ammonia and low dissolved oxygen what is the impact on the other species as a result of this

Acid Sulfate Soils (ASS) What is proposed to address Acid Sulfate Soils

Acidification problem on land There are options to cover sand other than freshwater

Is the lake bed soil at Pomanda sulfuric

What does the Department anticipate will be the result of disturbing and replacing thousands of cubic metres of sulfuric soil above and below the weir

What is the problem with ASS What does it do that is so bad

When acid soils dry out does they still retain their acidity What happens when they turn to dust

What problems have Acid Sulfate Soils caused so far Why do we need to be concerned about this problem

Wha t is the government s stra tegy to c ombat the ac id and heavy metals entering the river as a result of varying levels caused by wind seiching

Salinity issues Why after Lake Alexandrina has been sucked dry should the Lake have to put up with the salt from behind the weir therefore making the Lake worse with a high salt content

What happens to the salt which normally comes down the River and flushes to the sea via the Murray Mouth

Will the weir result in a highly saline weir pool

How will the accumulated salts be flushed at the weir

How quickly can the rocks be removed if it becomes apparent that the weir pool salinity levels have unexpectedly risen to unacceptable levels If not quick enough what is the contingency plan

What is happening to water above the weir Will salinity affect Adelaide water supply

Where are the salt and other contaminants going to go once the weir is constructed

What consideration has been given to the massive mobilisation of salt that would follow heavy inflows

Has the government considered increased salinity building up behind the weir

If the weir has a long life will salinity keep rising

Won t sa lt and toxin c onc entra tion inc rease upstream of the weir

What science is there that demonstrates the mixing of saline waters in the weir pool immediately above Wellington to be kept to acceptable levels while the weir is in operation Is there any precedent of a similar scale for this mixing scale

Proposed temporary weir impacts If the weir is there for a long time what are the groundwater impacts

Why are there far more truckloads of material being put into building the weir as opposed to taking it out

What are the implications of taking the weir down

Impact of increased vehicle access on Lakes beaches on Sulfate soils dust and wildlife

How do you intend to remove the weir given it is a massive structure

How do you intend to remove the weir given it is a temporary structure

What part of the structure and sub-structure will remain after decommissioning

What are the consequences if the weir fails to withstand a flood

If the temporary weir is engaged for three years but is required for longer what would it take to remain operable for as long as it is needed

Wha t will happen a fter the end of the three years of the weir s life

Is twin lakes concept a possibility Has it been sufficiently considered

Supplementary EIS for the temporary weir near Pomanda Island -118-

What is the effect of the weir on the water ecology in the channel (downstream) Eg water rats crustaceans birds beetles etc

Is a fishway being incorporated into the design of the weir

During the period of disconnection can a tunnel be built through the weir to allow fish passage

Will the temporary weir include provision for a fish ladder

What provisions are there in the weir construction for fish ladders and other access for boating

What is the level of the weir spillway and the level of the weir pool behind it

What is the level of the weir itself

Is it possible that the temporary weir will need to be replaced by a barrage if the drought continues

Why not build a permanent weirlock rather than building a temporary weir that may need to be re-built in a number of years

How long do you expect the weir to be in place

Social and economic impacts Where do we take our concerns about economic and social impacts of the situation

Politics and government What are the budget figures of water (both temporary and permanent) How much do they expect to pay per GL

The weir won t a llow boa t tra ffic Is this aga inst the c onstitution

Is it legal to build a weir which will hold the River flow to the detriment of the Riparian rights users downstream

Is it true that Commonwealth or State Laws require the River to remain navigable

How can I use this process to promote a change to the system of governance (States sharingallocations)

How can this consultation process address over-allocation

What is being done about over-allocation

Over-allocation in other states is at the root of the problem When will governments apply sufficient pressure to deal with the shortage of water coming over the border

What is going to happen with the issue of over-allocation and theft of water upstream

Would it be better to spend money on infrastructure instead of buying back water

We need a 50 year plan to remove all man-made infrastructure in the Murray

Why doesn t the federa l government focus on new sources of water being made available For example new engineering securing water from Queensland and delivering it to northern point of Murray-Darling

Is the Murray-Darling Basin Agreement still a legal document Is it still in force

What is the federa l Minister s responsib ility to the c ommunity c onsulta tion p roc ess (Specifically relating to issues submitted to state and if they disagree with the citizen who adjudicates)

What coordination is there between different government departments

Miscellaneous Why was A Fresh Water History g iven out today To influenc e thinking

How long under the worst case scenarios will the water contained by the temporary weir remain suitable for Adelaide use

What would be the cost of shifting the uptakes above Blanchetown

How are they measuring water quality in Lake Alexandrina What about DO and temperature

What role is the rising water temperature having on the aquatic species and water quality as a whole

Will the water beyond the weir cease to be aerated as a result of the weir

How much has wind seiching been considered in the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -119-

Why has there been no consultation with community in Milang Why have they been neglected

Wha t does spend mean in rea l wa ter terms We need a bold idea

If the weir is built will the blocking banks at Clayton Finniss and Currency Creek still be needed

If the blocking banks go ahead with the weir still go ahead

If the drought continues and the weir goes in and barrages are left closed what will happen to the Lakes and Coorong

Trigger Points What will be the indication to dismantle the weir

What is defined as temporary and what are the decommissioning triggers for the weir

Lake Albert What is the future of Lake Albert

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 4 on fish-ways) 21

River flowsallocations 16

PoliticsGovernment 15

Miscellaneous (including 5 on water quality) 12

Salinity issues 12

Acid Sulfate Soils 8

Wild-life (Fishturtles) 4

Ramsar 3

Wetlands 2

Bioremediation 2

Social and economic impacts 1

Lake Albert 1

Supplementary EIS for the temporary weir near Pomanda Island -120-

Clayton Community Information Session

Date Friday 27th March 2009 400pm 630pm Location Clayton Community Hall

Questions asked of the specialist panel listed by category

Regulators Why is a regulator at Clayton for pumping to the Goolwa Channel considered above letting seawater in to it

If the Clayton Regulator is built will it protect the water quality at the pumping stations (without building the weir)

How does the function of the Pomanda Island weir relate to the functions of regulators proposed for Currency and Finniss Creeks and Clayton

Is the weir going ahead as well as regulators If so why are both necessary

With the proposed regulators will the inflows of water to the next section be regulated from the bottom of the weir or from the top ie What will happen to accumulated salt behind the weir

Why is information on the regulators only in the papers and not mentioned in this forum

Lake Albert Should the weir at Pomanda Island proceed what are the ramifications for the future of Lake Albert

River flowsallocations Has blocking off the wetlands between the weir and Lock 1 to allow water when available to run into Lake Alexandrina been considered

If the weir is installed is the initial idea to pump water into the weir pool immediately or to leave it to whatever comes in

If the water extraction cap in other states is applied in 2012 will we get any water flow to SA

What are restrictions in other States on water use

What if anything happens in other states in allocating water as NSW has no meters

How is water removed from the River tracked

How is surface diversion tracked and measured

Has there been an assessment of all water storages available to the MDB

Do we believe SA will actually be able to get more freshwater from the larger eastern states as they are also growing

Would stormwater redirection help the Murray

What is stopping us from buying more water

How can the process of buying water be sped up

Ramsar

of the Murray-Darling Basin and River mouth is of paramount importance

Wildlife Ecology of LakeRiver studies on cod too late They have been in scarce supply for a long time

Given that the Yarra Pygmy perch is in other river systems why is it included

No cod in the Lower Lakes for decades Why are they included in the draft EIS

Is a base line study into Bell Frogs too late

Has anyone looked at the effect of the weir and its repercussion on micro-invertebrates etc on whic h a ll the Lakes residents (human anima l and p lant) depend

The Coorong and La kes site is reg istered a s an interna tiona l Ramsar wetla nd Isn t the Prime Minister responsib le for p rotec ting this a rea Isn t this the b ottom line The ec ology

Supplementary EIS for the temporary weir near Pomanda Island -121-

What effect will the proposed seawater introduction have on the Lower Lakes freshwater species

Why are marine species that were prevalent before the barrages not mentioned in the EIS

What study has been done on non-river marine species threatened by not allowing seawater in as nature would have done under these circumstances

How will species not listed in the EPBC Act be addressed

Acid Sulfate Soils What is the risk of potential ASS becoming actual ASS

The Executive Summary of the draft EIS alerts to the danger of acidification of the weir pool above the weir when wetlands are flooded again Is it intended to close off the entrances to them Has there been any decision yet about exactly what the effect of covering ASS with water (salt or fresh) will be

What will happen to the wetlands above the weir when they are refilled with water Is there a danger of the water being contaminated due to acidic soils

Due to ASS and extraction for urban use it appears that the weir must be in place by mid-January 2010 Is that the case

If the weir is installed is the intention to block off back waters and lagoons below Blanchetown If so are these subject to ASS

Bioremediation Is there something groupsindividuals can do to help with bioremediation projects etc How can we be involved

Will revegetating problem areas with dust fix the problem

Salinity issues What are the impacts of salt water within CurrencyFinniss Rivers

In the introduction it was stated that salt levels in the Goolwa Channel are 20000 ppm (parts per million) I believe they are 30000 ppm Is your information up to date

What will happen to salt accumulation when the proposed temporary weir is removed

Will the water coming over the weir spillway bring the salt with it or will salt build up at deeper levels

How will the salt coming past Pomanda Island be managed with a complete blockage that has a low level spillway in shallow water east of the main River channel

Does the weir prevent salts from being flushed out to sea (ie they will be built up behind the weir)

Rainfall Has consideration been given to constructing a barrage behind the temporary weir given continuing long-term low average rain fall

Proposed temporary weir Given the EIS indicates a 3 year lifespan of the weir what is the situation if the objectives of its installation are not met

Given the criteria for removal why is the design life for 3 years only

How permanent is this weir

If a weir is built upon removal will it all be removed or will it be a narrower channel

Figure 0-4 (lake level and the -15m red line) Is this the trigger for both the start of weir building and the introduction of seawater into the Lower Lakes

In the draft EIS statement there was no mention of effect on commercial social recreational or irrigation impacts Have these been considered

What is the impact of not constructing the weir

If the weir fails to guarantee water supply to Adelaide will it be removed

How long is the temporary weir to be in place

Why is the weir going to be temporary

Supplementary EIS for the temporary weir near Pomanda Island -122-

Has any consideration been given to building a barrage not a weir at Pomanda Point and removal of existing barrages below

Why not build a permanent structure which will service us for the next 100 years

Social and economic impacts Does the EPBC Act consider social and economic issues that the weir will impact on

How is this affecting tourism throughout the Lakes

How are the social and economic impacts being understood

Seawater If we let seawater in would it be flushed out again Would it return to fresh water

Is seawater into the Lakes seriously being considered What are the strong arguments against seawater as a sustainable option for the Lakes

Have we looked at letting seawater in at similar locations in Australia eg Mantra And the effects

Are Professor Gells results for c ore sampling about historic a l seawa ter being c onsidered (in letting seawater in)

Have any studies been conducted to consider the impact of salt water entering this Lake What were the outcomes of it

What prevents the weir height to be increased to say 07AHD to permit ingress of seawater to allow sufficient depth (~05AHD) and the operation of boat ramps jetties sailing clubs and safe navigation within the Lakes

Has a desalination plant option been considered for Beach 19 Lake Albert and Cantara (Replacement of fresh water from evaporation etc)

Politics and government Why has it been left so long for the urgency of this to be recognised and acted on

If the Federal government takes control of the MDB will that make this EIS invalid

Will the d ra ft EIS need to be reviewed due to the Government s rec ent dec isions regarding the blocking banks at Finniss amp Current Creeks

How does the EPBC Act deal with long-term management of the Lower Lakes

As it impacts on matters of NES does a state territory or industry need to get approval under the EPBC Act to get current or future water extractions

Why isn t the Commonwea lth ac ting to restric t a lloc a tions more urgently

Does the construction of the weir contravene Section 100 of the Australian Constitution that gives States or people rights to use water for conservation or irrigation

Due to state environmental assessments being overridden by emergency powers how a re issues suc h as wa ter a ffec ting ac tivities and wetland management p lans add ressed in this process

Miscellaneous Why is the Murray called a river when it is a series of pools

Has the idea of an island in the middle with dredging around it been considered for Lake Alexandrina

Why were 1982 figures used when 2006 was the worst case (until now)

Can we have hope that we will get to a sustainable system and that irrigation can provide Australian food

Has sea level rise been a consideration in the draft EIS and how may this impact on the weir if built

Were there EIS studies on any of the other 4000 barriers across the Murray

Has study of other precedence areas such as Mandura been done

Would it help if we had dry toilets

What level will the Lake be allowed to come up to once the weir is in place How far below the weir will the lake level be

Why have they decided on a pool of 01AHD given that previous pool level of the whole area was at +05 to 06 (Given that top of tide is +06m)

Supplementary EIS for the temporary weir near Pomanda Island -123-

How will water restrictions apply to small farmers on the river

Why wasn t Finniss Angas Bremer etc in MDB c a tc hment a rea

Why hasn t more been done about effic ienc y improvements in wa ter use by loc a ls as well as industry and people in Adelaide and beyond

If we all collected domestic water from properties etc would it negatively impact the Murray

Why isn t Myponga used to supp ly wa ter to the Fleurieu

Why has no impact study on underground water in the Currency Finniss and lower south east region been done

Has there been a comprehensive study of ground water and surface water into the area surrounding Lake Alexandrina

Why is there no navigation pass in the weir or no provision for one in the future

What will happen to Lake Alexandrina if water is pumped out into the Goolwa channel

Once the Lake is dry how will the Clayton channel then be refilled

Trigger Points Where are the trigger points for monitoring salinity and calcium carbonates sites located

Once we reach a certain trigger level at a monitoring site is the weir removed immediately or does it have to sit at a point for a certain amount of time

Will the weir be deconstructed if one trigger point is reached or all trigger points

Wha t is the trigger point for the guaranteed dec ommissioning of the weir

What are the triggers for removing the temporary weir

If the main a im of the weir is p reserva tion of Adela ide s water supp ly why is the level of water in the Lakes the trigger point for construction of the weir rather than the ability to extract water for Adelaide Is the real reason to do with Acid Sulfate in the Lakes

What is being done now to speed up the process of water allocation

Respiratory problems Low water levels are increasing the dust levels How quickly will this be covered to tackle health issues such as respiratory problems

Are health effects of the dust being surveyed What evidence is there of this

Has research been done regarding increases in respiratory problems

Supplementary EIS for the temporary weir near Pomanda Island -124-

Numbers of questionscomments on each topic indicative

Miscellaneous 20

Weir construction impacts 12

River flowsallocations 12

Wildlife 9

PoliticsGovernment 8

Sea water 7

Trigger Points 7

Regulators 6

Salinity 6

Acid Sulfate Soils 5

Social and economic impacts 3

Respiratory problemshealth 3

Lake Albert 1

Ramsar 1

Consolidated list of question topics from all Community Information Sessions

River flowsallocations 50

Weir construction impacts 47

Politics amp Government 39

Miscellaneous 37

Proposed Temporary Weir 27

Salinity issues 24

Acid Sulfate Soils 21

Wildlife 19

Seawater 10

Social and economic impacts 9

Lake Albert 7

Ramsar 7

Regulators 6

Trigger Points 7

Lock 4

Riverbanks 4

Pumping stations 3

Rainfall (Lake rain) 3

Respiratory problemshealth 3

Wetlands 2

Bioremediation 2

Supplementary EIS for the temporary weir near Pomanda Island -125-

Graph of consolidated question topics from all Community Information Sessions

All CIS Questions Summary

0

10

20

30

40

50

60

River flo

wsall

ocat

ions

Wei

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ion

impa

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Politi

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nel)

Miscel

laneo

us

Prop

osed

Tem

pora

ryW

eir(2

locks

)

Salin

ityiss

ues

AcidSu

lfate

Soils

Wild

life

Sea

water

Socia

l and

econ

omic

impa

cts

Lake

Albe

rt

Ramsa

r

Regul

ator

s

Trig

ger Po

ints

Lo

ck

Riverb

anks

Pum

ping

stat

ions

Rainfa

ll(L

ake

rain)

Respir

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ypr

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Wet

lands

Bior

emed

iation

Supplementary EIS for the temporary weir near Pomanda Island -126-

Appendix VI Advertising copy used in the consultation process

Date Thurs 12th March 2009

The Australian

The Victor Harbor Times

The Advertiser

The Southern Argus

The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -127-

Supplementary EIS for the temporary weir near Pomanda Island -128-

Date Thurs 12th March 2009

The Australian The Victor Harbor Times

The Advertiser The Southern Argus The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -129-

Supplementary EIS for the temporary weir near Pomanda Island -130-

Public Release Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island Email Update Sent 12th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -131-

Public Release Amended Draft Environmental Impact Statement for the

proposed temporary weir near Pomanda Island Email Update Sent 17th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -132-

Public Release Reminder re lodging submissions - Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 1st April 2009

Supplementary EIS for the temporary weir near Pomanda Island -133-

Public Release Submissions due 9 April 2009 Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 6th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -134-

Public Release Consultation period for draft EIS closes Draft Environment

Impact Statement for the proposed temporary weir near Pomanda Island

Email Update Sent 15th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -135-

CD Pack Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island

Supplementary EIS for the temporary weir near Pomanda Island -136-

Executive Summary

Supplementary EIS for the temporary weir near Pomanda Island -137-

Distribution of draft EIS Executive Summaries and CDs

Organisation Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Alexandrina Council 2 2 5 45 50 Coomandook Community Library

1 0 20 20 1

Coorong District Council 2 2 5 45 50 DEWHA library 2 2 5 5 Goolwa Public Library 1 50 50 1 Meningie Community Library 1 30 30 1 Milang Old Schoolhouse Community Centre

1 50 50

Mount Barker Community Library

1 20 20 1

Mt Barker Natural Resource Centre Mt Compass Library

1 20 20

1 Murray Bridge Library 1 Murray Bridge Natural Resource Centre

1

Rural City of Murray Bridge 2 1 National Library of Australia 2 Port Elliot Library 1 State Library Adelaide 2 1 Strathalbyn Community Library 1 Strathalbyn Council Office 2 Strathalbyn Natural Resource Centre Tailem Bend Community Library Tailem Bend Office of Coorong District Council Tintinara amp Coonalpyn Community Library Tintinara Office of Coorong District Council Victor Harbor Natural Resource Centre

1

5 5

20 20 1 30 30 1

30 30

95 100 5 5 30 30 1 50 50 50 50 1 30 30

30 30

1 30 30 1

1 30 30

1 30 30 1

1 30 30

1 30 30

Victor Harbor Public Library 1 30 30 1 Willunga Environment Centre 1 30 30 CLLMM Project Team 2 2 40 20 Mapland (DEH) 2 2 5 45 50 Meningie Community Information Session

200 100

Murray Bridge Community Information Session

200 100

Clayton Community Information Session

200 100

Goolwa Community Information Session

200 100

Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 SA Government Ministers Hon Mike Rann MP Premier Minister for Economic Development Minister for

1

20 20 20

20 20 20 10

2

10

2

Supplementary EIS for the temporary weir near Pomanda Island -138-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Sustainability and Climate Change Hon Paul Holloway MLC Minister for Urban Development and Planning

1 2 2

Hon Jay Weatherill MP Minister for Environment and Conservation

1 2 2

Hon Paul Caica MP Minister for Agriculture Food and Fisheries Minister for Regional Development

1 2 2

Hon Gail Gago MLC Minister for StateLocal Government Relations Hon M OBrien MP Minister for Employment Training and Further Education Hon T Koutsantonis MP Minister for Correctional Services Hon J Rankine MP Minister for Families and Communities Hon M Atkinson Attorney-General Hon M Wright MP Minister for Police Hon John Hill MP Minister for Health

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

Hon Kevin Foley MP Treasurer Minister for FederalState Relations

1 2 2

Hon Jane Lomax-Smith MP Minister for Tourism

1 2 2

Hon Patrick Conlon MP Minister for Transport Energy and Infrastructure

1 2 2

Hon Karlene Maywald MP Minister for the River Murray Minister for Water Security

1 2 2

Shadow Ministers Martin Hamilton-Smith MP 1 2 2 Adrian Pederick MP 1 2 2 Mitch Williams MP 1 2 2 Aust Govt Ministers Minister Penny Wong 1 2 2 Minister Peter Garret 1 2 2 SA Parliamentarians Parliamentary Leader SA Greens - Mark Parnell

1 2 2

Parliamentary Leader SA Democrats - Hon Sandra Kanck MLC

1 2 2

SA Parliamentary Library 1 1 Chief Exec DEH - Allan Holmes 1 Chief Exec EPA - Helen Fulcher 1

5 2 2

5 2 2

2Chief Exec DWLBC - Scott Ashby Chief Exec DTED - Brian

1 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -139-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Cunningham Chief Exec DTEI - Jim Hallion Chief Exec SA Water - Anne Howe Chief Exec DPC - Chris Eccles 1 2 2 Chief Exec DPLG - Ian Nightingale

1 2 2

Chief Exec PIRSA - Geoff Knight

1 2 2

Chief Exec DTF Rob Freeman 1 2 2 Dr Tony Sherbon 1 2 2 Mr Dean Brown 1 1 Mr Simon Stretton 1 2 2 Mr Sean Berg 1 2 2 CLLMM Steering Cttee 8 8 8 CLLMM Project board 4 4 4 Conservation Council of SA -Julie Pettett

1 2 5

Spares 2 2 500 500 92 15 25 2410 2012 11

Hard Copy Append CD Exec Sum CD Ordered 140 20 0 2500 2000

1 2 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -140-

Web content

Supplementary EIS for the temporary weir near Pomanda Island -141-

Supplementary EIS for the temporary weir near Pomanda Island -142-

Supplementary EIS for the temporary weir near Pomanda Island -143-

Fact Sheet

Supplementary EIS for the temporary weir near Pomanda Island -144-

Supplementary EIS for the temporary weir near Pomanda Island -145-

Appendix VII Media generated by the consultation process

Radio 12012009 410 PM ABC North amp West SA (Port Pirie) Late Afternoons - Kieran Weir Interviewees Michael Pengilly Liberal Member for Finniss Duration 10

18 01 2009 850 AM 5AA (Adela ide) Mic hael Keelan s Weekend - Michael Keelan Neil Humphrys amp June Taylor Interviewees Simon Birmingham South Australian Liberal Senator Duration 710

8012009 954 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 025

Newsreader News Director Ms Monique Crichton Duration 014

8012009 603 AM Triple M (Adelaide) 0600 News

8012009 1212 PM 5AA (Adelaide) Mornings - Mike Smithson Interviewees caller Jeff Mike Rann SA Premier Duration 1133

8012009 731 PM 5AA (Adelaide) Matthew Pantelis - Jeff Burzacott Interviewees Caller Robyn Duration 1605

8012009 1127 AM ABC 891 Adelaide (Adelaide) The Soapbox - Sonya Feldhoff Interviewees Michael Pengilly Member for Finniss Duration 328

8012009 1212 PM ABC North amp West SA ABC North amp West SA (Port Pirie) SA Country Hour -Annabelle Homer Interviewees Senator Sarah Hanson-Young Australian Greens SA Duration 415

8012009 100 PM ABC 891 Adelaide (Adelaide) 1300 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Martin Hamilton-Smith SA Opposition leader Mike Rann SA Premier Duration 119

8012009 600 PM ABC 891 Adelaide (Adelaide) 1800 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Duration 033

9012009 632 AM ABC 891 Adelaide (Adelaide) 0630 News - Newsreader Interviewees Arlene Buchan Australian Conservation Foundation (ACF) Duration 036

9012009 704 AM ABC 891 Adelaide (Adelaide) 0700 News - Newsreader Interviewees Arlene Buchan ACF Duration 050

3022009 1003 AM ABC 891 Adelaide (Adelaide) 1000 News - Newsreader Interviewees Karlene Maywald SA Minister for the River Murray Duration 046

12032009 830 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 017

12032009 521 PM ABC North amp West SA (Port Pirie) Late Afternoons - Annette Marner Interviewees Caller Tom Karlene Maywald Minister for Water Security

Supplementary EIS for the temporary weir near Pomanda Island -146-

Duration 847

13032009 809 AM 5AA (Adelaide) Pilkington amp Conlon - Tony Pilkington amp Keith Conlon Interviewees Karlene Maywald SA Minister for the River Murray and Water Security Duration 628

13032009 840 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan - live from Goolwa Interviewees Prof Diane Bell Resident and former Federal independent candidate for the Seat of Mayo Duration 239

13032009 910 AM 5AA (Adelaide) Mornings - Mike Smithson Interviewees Senator Sarah Hanson-Young Australian Greens Party Duration 612

13032009 1024 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan Interviewees Clem Mason Lower Lakes and Coorong Infrastructure Committee Lesley Fisher Lower Lakes and Coorong Infrastructure Committee Duration 923

13032009 1105 AM ABC 891 Adelaide (Adelaide) The Soapbox - Matthew Abraham and David Bevan live at the Goolwa Sailing Club Interviewees Dean Brown Premiers Special Drought Advisor Robyn McLeod SA Independent Water Commissioner Duration 603

31032009 835 AM ABC North amp West SA (Port Pirie) Morning Show - Kieran Weir Interviewees Dr Jochen Kaempf Oceanographer Senior Lecturer Flinders Uni Duration 1136

Television 8012009 600 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Martin Hamilton-Smith SA Opposition leader Peter Garrett Federal Minister for the Environment Rory McEwen Acting Water Minister Senator Sarah Hanson-Young Australian Greens Party Simon Birmingham Liberal Senator for SA Duration 135

8012009 601 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Henry Jones fisher Jock Veenstra tourism operator Kym McHugh Mayor Alexandrina Michael Smyth Channel 9 reporter Duration 200

12032009 516 PM Channel 10 (Adelaide) TEN News - George Donikian and Rebecca Morse Interviewees Karlene Maywald Water Security Minister Mark Parnell Australian Greens Martin Hamilton-Smith SA Opposition leader Duration 147

Print media PG227 13 March 2009 The Hon Peter Garrett MP Minister for the Environment Heritage and the Arts Final terms of reference for Barrage EIS httpwwwenvironmentgovauepbcnoticesassessmentslower-lakeshtml Stock Journal 19032009 p 8 General News Adelaide Advertiser 14032009 p 27 General News Lakelander 27032009 p 9 General News Stock Journal 19032009 p 12 General News Stock Journal 19032009 p 16 Letters Times Victor Harbour 19032009 p 1 General News Murray Valley Standard 19032009 p 4 General News

Supplementary EIS for the temporary weir near Pomanda Island -147-

Appendix VIII Summary information of enquiries and

submissions for provision of the proposed temporary weir

Summary information

Number of phone calls to EIS hotline 52 Number of emails to eisdehsagovau from unique individuals 82 Number of feedback comments on the CLLMM website 14 Number of subscriptions to e-newsletter via the CLLMM website 48 Number of Community Information Session registrations on the CLLMM website 47

Number of submissions received by email 61 Number of submissions received by letter 9 Total number of submissions received 70

Number of unique visitors to the CLLMM website 1588 Number of visits to the CLLMM website 2834 Number of page views on the CLLMM website 9343

Supplementary EIS for the temporary weir near Pomanda Island -148-

Submission Summary

Mr Roger Cooke The writer proposes a major scheme which aims to simultaneously drought-proof the Murray-Darling Basin and to meet 2020 emissions targets Features of the scheme include - Laying concurrently gas and water pipelines from the NW Shelf to major centres including SA mining towns and Adelaide - Laying irrigation pipes to replace open channels a financial stimulus package - Piping LNG to replace coal-fired energy production assisting Australia to meet 2020 emissions targets The submission outlines a national water distribution scheme as well as a proposal for creating a river channel in order to prevent evaporation across the Lakes while maintaining a freshwater channel The writer proposes a scheme for a long-term solution to the Lower Lakes The writer suggests a permanent weir is necessary as drought will increase in severity and frequency The proposed scheme would aim to reduce evaporation occurring over the Lakes by creating a channel from a proposed permanent weir to the barrages The writer suggests benefits to the Coorong mitigation of Acid Sulfate Soils a freshwater environment for boating while p rotec ting Ad ela id e s wa ter supp ly

Mr Michael Galea Argues there are too many unquantifiable risks associated with the proposed weir and freshwater is needed now The writer bases the submission on local knowledge and common sense He reports the awesome impact of low water on many plants and animals in recent years in the vicinity of Clayton Bay He expresses concern that a weir will pool polluted water upstream and the saline spike will kill tens of thousands of carp and pollute Lake Alexandrina

Mr Philip Fargher The writer is keen to see base environmental River flows established through the use of Commonwealth Government powers The writer outlines established processes of River flooding which periodically flushed out saline water from the Lower Lakes and Coorong Changes to the system due to locks allocations irrigation and the barrage are noted Seawater flooding of the Lakes is thought to lead to negative and unpredictable results as tidal exchanges are insufficient Acid Sulfate Soils require freshwater flows or peripheral lime sand

Mr Andrew Zoerner The writer is concerned that a freshwater environment in the Lower Lakes will not survive unless a Lock is built east of Clayton as well as a water pipeline from Wellington The aim is to maintain freshwater around Goolwa Hindmarsh Island and Clayton for environmental cultural historical industrial recreational and tourism reasons while preserving local flora and fauna

Mr Douglas Smith The submission has nine points The author seeks clarification identifies gaps and expresses points of view The author asks that the definition of sea level and salinity measures are clarified He notes that ferry operations are

Appendix IX Table of submissions

The table below provides a summary of submissions received during the public consultation period An electronic copy of the submission can be located on the DEH website httpwwwenvironmentsagovaucllmmtemporary-weirhtml

Submission no

PTW00001

PTW00002

PTW00003

PTW00004

Submission from

PTW00005

Supplementary EIS for the temporary weir near Pomanda Island -149--

Submission no

Submission from Submission Summary

not discussed under the do nothing option and notes that the difficulties of decommissioning a weir are understated He notices that there is no discussion of management of blue green algal blooms above the temporary weir

PTW00006 Ms Melanie Rees The author argues that efforts to mitigate negative impacts of a proposed temporary weir are grossly inadequate and any amendments envisaged to the draft EIS will not make the weir development acceptable Threats to species and communities are not adequately addressed or are downplayed or discountedThe author indicates concern about the lack of genuine community consultation and argues that the weir development should be considered with other developments because there are cumulative impacts She expresses points of view on public understanding of pertinent issues drought the importance of cost benefit analysis and suggests changed wordings The author suggests investigating filling reservoirs and drawing from them while relocating pumping stations She suggests that stormwater statistics are inaccurate and recommends increasing stormwater harvesting to alleviate reliance on the River Murray The author provides detailed information about the Southern Emu-wren noting Draft EIS information is out of date Gaps are identified in that phytophthora impacts are not considered at the weir building site and the impact of a weir on Callop fish is not discussed

PTW00007 Mr John Clark President Southern Alexandrina Business Association Inc

This submission puts a case for an alternative to the proposed temporary weir near Pomanda Island SABA argues for a permanent lock (Lock 0) in the vicinity of Tailem Bend SABA refers to Gell et al and notes the estuarine but predominantly freshwater environment of the Lower Lakes A navigable lock with a fishway would support the ecology and recreational fishing and boating (boating valued at $200m pa) and meet water security objectives SABA argues that climate change increases the logic of a permanent Lock 0 Supports remediation and revegetation where appropriate and seawaterif needed to check Acid Sulfate Soils

PTW00008 Mr Mike Brisco This submission draws on authoritative literature on climate change The author argues that the weir is proposed in an inadequate context that is the context of severe drought in south eastern Australia The proposed weir should be located in other scenarios - especially for example that of rapid climate change In the event that the weir needs to remain in place projected sea level rises need to be considered in its design The main point is that the impacts of the proposed weir cannot be understood in an inadequate context An additional chapter is suggested Other detailed suggestions are made for changes to the draft These changes show more dramatic water security issues than currently documented in the draft EIS (for example diminished run off over time into Adelaide water storages)

PTW00009 Mr Ian Moyle The writer has lived and worked at Narrung and has lasting educational and environmental interests in the Lakes and Coorong He is c onc erned b y governments lac k of acknowledgement of climate change and previous poor water management He urges the state government to get serious about collecting and using rainwater and grey

Supplementary EIS for the temporary weir near Pomanda Island -150shy

Submission no

Submission from Submission Summary

water re-use PTW00010 Ms Jan Meek

Secretary Signal Point Riverine Environment Group Inc

The group believes a weir willl become permanent and that a revised draft EIS should be prepared based on this premise There are seven issues of concern listed Gaps and lack of clarity in the draft EIS are identified The group indicates - that species rescue outside the Ramsar boundary is unacceptable and that the EIS needs to include species impact statements on a range of species - that an impact of a weir will be increased salt discharge salt interception schemes or mitigation measures need consideration - weir removal triggers are unrealistic and imprecise and out of the control of the SA Government

PTW00011 Mr Richard Harvey

PTW00012 Ms Sally Richards

The writer has a long association with the Coorong and Lower Lakes He indicates his opposition to any seawater incursion In relation to the weir he understands that in the order of 500 tonnes of salt a day would build up This would impair water piped to Narrung The writer urges strong action by Federal Government to reverse over-allocation The writers submission is informed by her residence in the Finniss Catchment and membership of the Finniss Catchment Group Points made by the writer include - more freshwater in the river system - over-allocation and poor management of water continues today - for example in the Finniss catchment where there is no Water Allocation Plan - system wide over-allocation must be addressed - more species than those listed in the draft EIS should be considered - the weir will have impacts beyond the weir site The writer advocates working with community and nature and and disallowing XXXXXXX water supply control (company not named for legal reasons)

PTW00013 Mr Trevor Giles

PTW00014 Ms Brenda Lower

The writer has very extensive experience living and working as a primary producer in the Langhorne Creek District and has a strong attachment to the Lower Murray Region He notes the lack of freshwater will lead to habitat loss and that all water supply proposals are interconnected All projects together are an overall threat to the environment Other concerns include - the bund at Narrung Narrows and proposed regulators prevent wind seiche - lack of consideration of groundwater - no fishway inclusion - the unsuitability of the weir site Freshwater is the only viable solution to retaining habitat The writer is concerned about the river and the people of the district and she asserts that water is needed now The author notes negative impacts of increasingly saline water on turtles birds and fish and is concerned about sulfidic soils and human health The author favours a permanent weir and seawater incursions to cover soils

PTW00015 Mr Frederick Gordon Michelmore Farmer

The author is concerned by the increasing salinity in the Lakes He suggests spending 10 of the cost of the weir on increasing rainwater capture from roofs Other sources of water must be found because the river can not keep up with demand

Supplementary EIS for the temporary weir near Pomanda Island -151shy

Submission Summary

Ms Ann Lucas The writer is concerned about previously estuarine areas between the Murray Mouth and Beacon 19Goolwa Barrage which are an important habitat for migratory birds It is suggested freshwater is accessed for the area in order to return it to estuarine conditions - possibly through the use of an inexpensive Desal plant

Mr Glen Jones General Manager Boating Industry Association of SA Inc (BIASA)

Points on matters of national environmental significance relating to the EIS no comment Concerns - BIASA would have liked to see provision for boating

ac c ess (a vessel loc k ) through the weir - the greatest concerns of BIASA are for both the natural environment and the declining economic viability of many businesses and communities along the River Murray downstream from Lock 1 and in the CLLMM region - concerns are for both the immediate situation and the longer term The submission documents the broad membership of BIASA the operation of BIASA and the organizations with which it liaises and for which it provides advice The submission documents financial losses being incurred (economic losses $ figures) as a result of low water levels and low water flows The cost of repairing river bank slumping and impact on ferry services and nearby communities are mentioned The impact of low water levels and low water flows in the CLLMM on social and health wellbeing of communities and jobs in boating and tourism businesses is documented in some detail and discussed The submission supports the immediate construction of a weir

Mr John Coombe Chief Executive Alexandrina Council

Points on matters of national environmental significance relating to the EIS - concern about the future health of the Ramsar protected areas - concern about the lack of fish passage between Lake Alexandrina and the River Murray and vice versa Concerns - most concerns are based on the premise that the weir will reduce water flows into the CLLMM region however this will be temporary only (90 days) - potential for unknown andor unforeseen impacts of building a weir on biodiversity and water quality both upstream and below the proposed weir - the biodiversity of the CLLMM region is dependent on freshwater for survival and is getting insufficient freshwater - infestations of tubeworms and other pests have the capacity to impact on biodiversity including turtles (not currently listed under EPBC Act) - health problems caused by excess dust from dry lake bed areas - increased impact of environmental condition on social and economic wellbeing of the region Suggestions building of a lock upstream is preferred because it will allow fish passage and boating access up and downstream

Mr Derek Fenton Points on matters of national environmental significance relating to the EIS No specific points were raised but a concern was expressed about impact on other species which are not listed under the EPBC Act

Submission no

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Submission from

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Supplementary EIS for the temporary weir near Pomanda Island -152shy

Submission Summary

Concerns the main concern is for lack of water for environmental flows in the River Murray in the CLLMM area

PTW00020 Ms Vesper Tjukonai Points on matters of national significance relating to the EIS not addressed except to say that in Ngarrindjeri traditional thinking animal bird and fish species (part of Ruwe) are not separated as in Chapter 13 but considered in an integrated way Concerns - questions the thoroughness of consultation with Ngarrindjeri Traditional Owners - impact of declining quality of river systems on humans (especially Ngarrindjeri in this case) - construction of weir would reduce water flows available for the Ngarrindjeri - continuing noise nuisance from pumps at Narrung Narrows pumping especially low frequency noise (health problem) - lack of clarity of the relationship between the Narrung Narrows bund the proposed weir and the future need for pumping at Narrung Narrows - potential health impacts of dust from the exposed edges of drying lakes - there could be increased pumping in summer and autumn at Narrung Narrows if the weir is built - current restriction of activities including collection of traditional foods basket making and others - soc ia l imp a c ts of the d rought a nd inappropriate water

hoard ing and fa rming method s Suggestions - Include the Ngarrindjeri Nation as Traditional Owners of the CLLMM region in the Draft EIS Executive Summary and Draft EIS Fact Sheet - Refer to Ngarrind jeri as Nation and Trad itiona l Owners - Go beyond consultation to partnership with traditional owners in planning and management - Consideration of impact of the drought and water quality situation on humans (Ngarrindjeri Nation and the wider community)

PTW00021 Mr Keith McFarlane

Background local landowner along Lake Alexandrina (family since 1845) cattle production irrigation Points relating to matters of national environmental significance EIS - Mr McFarlane says that the CLLMM is the most important part of the MBD and that river flows must be allowed for environmental maintenance as the highest priority - He is concerned that increased salinity below lock 1 caused by building the weir will be disastrous for the Ramsar-listed wetlands - He is also concerned that mud disturbance around the weir site during construction would turn the water saline and impact on all fish species Mr McFarlane does not support the building of the temporary weir at Pomanda Island The closure of wetlands along the River Murray is supported as long as there is periodic re-wetting Additional concerns Mr McFarlane is concerned that the seasonality of wind direction and speed across Lake Alexandrina may not have been taken into account when the modelling was done and that SW winds in winter and spring will counteract river flow such that river salinity will

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -153shy

Submission no

Submission from Submission Summary

build up more quickly than has been suggested in the draft EIS Suggestions - that Acid Sulfate Soils have not been a problem to date and could be counteracted in future by seeding into exposed areas - it is not necessary to keep the Lakes up to pool level in drought because the Lakes will present a smaller surface area for evaporation reducing amount of water lost - establishment of more rainfall recording stations around the Lower Lakes region to improve the accuracy of data used in modelling

PTW00022 Mr Tom Chapman Director The Marina Hindmarsh Island

Points relating to matters of national environmental significance EIS - the weir would reduce (economic and) environmental activities of the LLMM region - suggests that a fishway should be included in the weir Support the submission supports the proposed weir as a last resort but argues that a permanent lock between Tailem Bend is a better solution He views the weir as a high cost item to build and maintain as well as not allowing boating access between the Lakes and the River Concerns Mr Chapman is very concerned about the impact of lack of boating access through the proposed weir and the consequent negative impact on economic activity in the LLMM region especially on the recovery of boating but not necessarily limited to boating Perspective a worst case scenario and the weir might not be removed for a considerable time (many years) Alongside this he also supports the introduction of seawater into the LLMM and makes points about historic and current salinity levels in the LLMM

PTW00023 Mr Tony Read The author argues that there is no compelling evidence to build a weir He indicates that long-term investments are required for long-term solutions A short and a long-term solution exist The author refers to research into aquifers beneath the Adelaide Plains and provides a reference He indicates that groundwater bores can be increased quickly if necessary and argues that brackish bore water can be desalinated more cheaply than seawater He makes a case for a long-term solution that is the Twin Lakes concept He notes that the partial weir options do not support any argument to build a weir

PTW00024 Mr Mick The writer supports building a weir He notes that people upstream are suffering He is concerned about evaporation losses

PTW00025 Ms Anne Hartnett Points on matters of national environmental significance relating to the EIS - this EIS is only a partia l doc ument bec ause there a re many interrelated interventions occurring in the CLLMM region a single holistic EIS should be put together covering all of the interventions - the site of the proposed temporary weir is at or near a biodiversity hotspot as pointed out in Appendix 15 and was this considered when the site was chosen - potential for release of metals (including heavy metals) from sediments by acidification and associated ecological impacts are unknown

Supplementary EIS for the temporary weir near Pomanda Island -154shy

Submission no

Submission from Submission Summary

- the potential threat of blue-green algal outbreaks and the associated impact are not addressed sufficiently - concern that the honouring of international biodiversity agreements is not a high priority (migratory birds Ramsar wetlands) - an apparent inconsistency in that -15 m AHD is proposed as the trigger level for building a weir and is also the point at which Acid Sulfate Soil risk increases substantially yet the water level after building a weir

will drop below this to -167 m AHD concern that the scenario from here might need to include seawater introduction into the lakes and there is no EIS relating to this possible intervention Concerns - the size and therefore the impact of mud waves generated during the construction of the proposed weir are unknown - the lack of information on rates of acidification and lack of chemical analysis of the sediments and the potential for release of heavy metals upon acidification - cutting off the river from the Lake by building the weir leading to loss of the aerating wind seiche effect - if there are low water flows over the weir in future what will be the impact on water salinity levels upstream - has sought clarification on the cost of engineering solutions but not received information Expresses supports for 10 other submissions Suggestion - proposes that the money that would be spent on all interventions and engineering solutions be used instead to buy water for environmental benefit as well as human consumption

PTW00026 Ms Judy Goode River Murray Environment Manager SAMDB NRM Board

The SA MDB NRM Board agrees the weir should only be built when all other solutions have been exhausted The submission argues in detail and with reference to EPBC-listed species and numerous other species that a fish passage is required to support migration of species upstream and downstream and to support upstream movement as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river Upstream wetlands The submission asks for consideration of the environmental impacts of re-filling wetlands and potential impacts of Acid Sulfate Soil mobilising into the river The submission indicates inadequate measurement of water savings from wetland closures in Section 434 There is an unquantified assumption about the prevalence of the Southern bell frog in Section 1310 which requires consideration Water qualitywater quantity impacts A significant omission is identified in that salinity impacts are not modelled over three years The weir pool above the weir will be relatively small and the impact of wind seiche in the pool is not understood Additional modelling is sought for acid release from acid

Supplementary EIS for the temporary weir near Pomanda Island -155shy

Submission no

Submission from Submission Summary

soils metals release increased nutrient loads blue-green algal outbreaks increased sedimentation and turbidity increased temperatures fish and other biota kills odour dissolved dust fuel and oil spills Further modelling on a range of scenarios Impacts of construction The weir site is at a junction of the Lake and River and is a biodiversity hot spot A more comprehensive explanation of the choice of this weir site is required Technical issuesmore details which require more consideration What are the environmental impacts of sourcing the weir building materials SA Planning justification in writing for exemption under the Development Act Environment and Construction Management Plans How do all the costs which would be included in a properly constituted business plan compare to the potential purchase of water (for a freshwater solution)

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Mr Alexander Whitehead Hindmarsh Island resident

Supports the building of a weir at Pomanda Island Also suggests that regulators not be built in the lower reaches of the river and that seawater be allowed into the Lakes

Prof Peter Fairweather Professor of Marine Biology School of Biological Sciences

Background Research Associate and Prof of Marine Biology Flinders University Points on matters of national significance relating to the EIS - the submission raises a number of concerns about the adequacy of the geographic scope of the EIS the treatment of different types of aquatic habitat the use of averages in modelling and several other points listed below Concerns - there is a concern about gaps in the EIS relating to factors that drive ecosystem change the submission questions whether maxima minima and seasonality rates of change have been considered in addition

to average values as these are important - argues that the Coorong and Lake Albert will be affected and should therefore be included in the EIS - questions whether the impact of a weir really is insignificant relative to the effects of drought - questions the reliability of modelling for years 2 and 3 and suggests that more caution should be used in interpretation towards the end of the period - that there is a gap in the EIS in the treatment of aquatic habitat types such as the benthos and the water column - that the different models appear to use different weather sequences to predict outcomes for the same sets of years and that more attention should be given to variation as a result of different weather sequences The authors are not opposed to the need for or construction of a weir but argue that the accuracy of the EIS needs to be improved in relation to several matters of national environmental significance Other points raised The legibility of many Figures in the EIS was not adequate A comment about bird species discussed in 142 and 143 and whether these are the correct or appropriate species

Mr Robert Thomas Points on matters of national environmental significance relating to the EIS none

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Supplementary EIS for the temporary weir near Pomanda Island -156shy

Submission no

Submission from Submission Summary

Concerns - concerned about health problems relating to lowered Lake water levels (dust) Supports the construction of a weir at Pomanda Island Suggestions - not to build the regulators around the lower reaches of the River and allow seawater into the Lakes - as a longer term solution suggests the building of a barrage with a lock at Wellington

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Ms Barbara Carroll Native Foods amp Plants

Confidential submission

Mr Henry Jones Commercial Fisherman Boating Industry Association

The writer is a commercial fisherman He and his family have been in the Coorong Lower Lakes and Murray Mouth commercial fishing industry for six generations The industry in the area has achieved a number of significant firsts in sustainable fishery management The author now feels ashamed for the following reasons - the extinction of species - the dredging of the Murray Mouth - the death of two thirds of the Coorong - the changing from estuarine to marine of the remaining third of the Coorong - the change from once busy bustling wetlands to a sandy wind-blown desert - the exposure of Acid Sulfate Soils - the pain inflicted on our native animals especially the pain and death of turtles - the slow death of native water rats deprived of habitat - the death of small Lake birds who no longer have their sustaining habitat - the tonnes of dead mussels invertebrates and macro invertebrates - the Government blaming drought rather than providing environmental flows The writer submits that a weir will cause major fish kills and further environmental decay

Ms Gloria Booker Manager Development amp Environmental Services Rural City of Murray Bridge

The submission points out that there was insufficient time for Elected Members and the Council to provide formal comment The Murray Bridge community may receive aesthetic and environmental benefits from raising the River level but this should not be to the detriment of native wild life and migratory birds Points made include - the weir is a last resort in ensuring water for critical human needs - ecological damage is not irreversible - the proposed weir is of sufficient height to prevent salinity moving upstream from Wellington - professional fishermen are provided with access to Lake Alexandrina - the location of pumps does not allow salt water to be washed back into the river - consideration be given to allowing river craft and fish to move from the River to the Lake

Mr Chris Bagley Dryland Farmer

Points on matters of national environmental significance relating to the EIS - the Draft EIS carries no mention of the highly regarded and important Milang Snipe Sanctuary Concerns

Supplementary EIS for the temporary weir near Pomanda Island -157shy

Submission no

Submission from Submission Summary

- that SA water planning focuses too much on consumption - that the Draft EIS indicates that only 50 of the weir material is to be removed a the end of its life and that this is not acceptable - that there may be a weir collapse with associated impacts due to the nature of the base material Suggestions - the a uthor strong ly suggests tha t Dilution Flow be

rep lac ed by the c onc ep t of Maintena nc e Flow with a rationale and that MDB management should focus on this - that the Draft EIS focuses on a base flow of 350GLyear past Pomanda Island he suggests that other scenarios and their impacts also need to be considered including zero flow 700GLyr and 2000GLyr - the author supplies a water resource report for the MDB (Mar 09) and proceeds to argue that SA can buy environmental water to save the Lower Lakes without building the weir and for 25 less cost than weir

construction and removal a set of Tables outlining water purchases over the next 3 years is presented

PTW00034 Ms Liz Yelland General concerns are expressed about the draft EIS It fails to concentrate on all species and acknowledge interdependency It fails to persuade that sufficient water will overspill the weir into the Lake No or insufficient water could result in Carp dying and then all Lake life dying Suggests that the proposed temporary weir EIS should be considered with a seawater incursion EIS In relation to chapter 10 the author is concerned that Weir construction will signal to upstream river management that there is no need to provide water to replenish the Lakes as it evaporates Ch 10 is not predicated on the view that there is already an environmental emergency further endangering international treaty sites - Political will addressing over-allocation can save these wetlands - The author expresses concerns about Goolwa Channel and Finniss and Currency Creek regulators - Questions why so little attention is given to the Coorong Comments on Ch 5 - The writer provides an image of childrens Lego sinking in porridge - Local knowledge and draft EIS Appendix 6 are referred to as the author makes the case for the difficulty of establishing the weir at the designated site Comments on Ch 11 - Asks the question what is the possible effect of cutting off the seiche surges of water from Lake Alexandrina into the lower reaches of the River Murray - Local knowledge of seiching is provided which indicates that the River beyond Murray Bridge during times of very low flows has been oxygenated and saved - Also during low flow periods the seiche and wind variations allows salinity and pollution burden to be transported to the Murray Mouth Should seiching be interrupted increasing salt build up causes flocculation of clay particles suspended in the River Conditions then support the possibility of blue-green algae blooms

Supplementary EIS for the temporary weir near Pomanda Island -158shy

Submission no

Submission from Submission Summary

- The author is sceptical that temperature inversion will mix salt to an extent which allows low flow to transport it away - Negative effects of seiching - Salinity build up since 2002 is described (reference provided) - Acid A graph is provided with detailed interpretation of wind salinity water levels and pH The author concludes that generally wind seiching has positive outcomes and that acid is not showing signs of being a problem and salinity could be managed by intermittently ceasing pumping - Concerns about mobilising acid upstream from the weir in wetlands which have been cut from the River Comments on Chap 16 - It is the author s view tha t the EIS implies a n ac c ep tanc e of an unacceptable environmental collapse which shames country and governmentThe weir is an enormous gamble due to the possibility of the weir sinking that construction methods will be ineffective and there are probable unexpected consequences

PTW00035 Mr Lynton Vonow Points on matters of national environmental significance relating to the EIS - the EIS is deficient in that it is not presented as part of an integrated plan for the region and its water and environmental problems - potential impact of building a weircompared to only

having the sill a t the entra nc e to Lake Alexa nd rina a t Pomanda on fish eg Murray Cod Concerns - that the environmental impacts of permanent weirs along the River Murray are severe and the temporary weir poses a similar risk - that the weir would increase the likelihood of blue-green algal blooms in the river upstream of the weir (and associated risk to drinking water supply) - that the salinity spike that would occur in the water near Pomanda Island after construction of the weir would be very detrimental to long-necked tortoises through the negative direct impact of tubeworms which are salt-tolerant Suggestions - that better alternatives to building a weir are (a) purchasing water (b) increasing water harvesting in the metropolitan area of Adelaide (c) relocation of pumping stations to upstream of Lock 1 and that increasing the storage at Mt Bold reservoir has significant problems including negative environmental impacts - that as the Lake levels drop the problem of wind seiching of saline water into the river will decrease - that acid Sulfate Soils are not as serious a problem as was predicted - that allowing seawater into the Lower Lakes would be very destructive The author supports the submissions of 17 other people and groups

PTW00036 Ms Ruth Trigg Concerns - the author is concerned about the basic premise(s) for construction of a weir at Pomanda Island and offers a critique of the process which has led to this point She analyses Chapter 3 of the Draft EIS using an

Supplementary EIS for the temporary weir near Pomanda Island -159shy

Submission

no Submission from Submission Summary

ana lytic a l framework and a toolkit of d ifferent method s (such as Critical Discourse Analysis and a number of others) - from the list of 73 reports agreements and Acts of Parliament relevant to the River Murray system in the CLLMM region (cited in the submission and in Chapter 3) it is argued that the existence of these documents has not helped to retain the long-term health

of the river system - the lack of accountability with regard to the health of the MDB river system in the present system of government and interactions between governments - the unavailability of water audit figures for the whole MDB system for more than one month of data at a time (data seen as withheld) - tha t the voic e of multina tiona l c omp anies and sha rehold ers overrid es the environment s need s illustra ted

with recent quotes from the media about continued expansion of irrigation in upstream states - that the decision to build the proposed weir is connected

with the a im of g rowing South Austra lia s popula tion (to 2 million by 2050) and that keeping this expansion target in the face of present difficulties with the

sta te s wa ter sup p ly is unreasona b le - that the collective voices of knowledgeable people who live near and care about the River system in the CLLMM region will not be listened to Suggestions - the author suggests that new models of economic growth and development need to be urgently considered (eg further development and use of the Genuine Progress Indicator Dr P Lawn Flinders University) The author supports the submissions of 16 other individuals and groups

Supplementary EIS for the temporary weir near Pomanda Island -160shy

PTW00037 Mr John Yelland Points on matters of national environmental significance relating to the EIS - concern that the EIS guidelines have not been followed Concerns - the author seriously questions whether the weir structure can be built considering the nature of the foundation material especially the apparent unsuitability of the foundation at the western end and quotes material presented in Appendix 5 - the mud waves formed by the dumping of rock have not been studied adequately - the wetlands upstream of the proposed weir which are currently dry will be re-wet at some stage with potential for acid formation and release of heavy metals these acids and metals might not be adequately

flushed with the weir in place and the risks need to be studied - the Draft EIS is deficient in that it does not refer to other proposals such as the regulators at Clayton and at Finniss and Currency Creeks modelling of salinity and Lake water levels should take these other

developments into account The author supports the submissions of 13 other individuals and groups

PTW00038 Mr Bruce Brooks Points on matters of national environmental significance relating to the EIS no direct comment but questions are asked about some assumptions and the accuracy of

Submission

no Submission from Submission Summary

modelling presented in the EIS which lead to decision points (water levels wind speed and salinity) Concerns - argues that the problems of the CLLMM are not primarily a result of drought by comparing Figures 0-2 and a graph showing Murray-Darling Catchment annual rainfall trends 1950 2008 (both graphs with trendlines the latter graph possibly not in the draft EIS but presented at community consultation meetings) - argues that the data and modelling that have been used that point to -15 mAHD (trigger point) being reached in Lake Alexandrina in early 2010 may be incorrect and predicts that the levels reached will not be as low as this in the worst case scenario Further he presents data from Kotwicki 1993 (a factor relating evaporation from the lake to pan evaporation measured in situ at the lake) which differs from the factor used b y MDBC a nd uses Kotwic ki s factor to arrive at a higher Lake water level than predicted in the EIS - concern that the salinity levels in the Lakes in the modelling output presented in the EIS are underestimates and that the data need to be looked at again

PTW00039 Dr Keith Walker This is a detailed submission which provides important knowledge and information on a range of relevant issues including ecology and threatened species of the lower Murray and CLLMM The submission raises many pertinent questions Points on matters of national environmental significance relating to the EIS - a weir pool is not the same habitat for plants and animals as a river or a lake conditions in the pool will favour species such as common carp and discourage riverine species in particular - there should be a fish passage in plans for the weir - the author is concerned that diadromous fish (ie requiring access to the sea) are prevalent in the lower Murray but these would be unable to move beyond the weir - more consideration should have been given to the wetlands between Blanchetown and Wellington - contends that statements on page 13-17 (Interaction of salinity with EPBC-listed fish species) about salinity tolerance of early stages of freshwater fish are misleading - the author says that the discussion of EPBC-listed species is incomplete and superficial - states that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the MDB including the CLLMM region are currently being evaluated for EPBC listing

- the author disagrees with statements in the Draft EIS that suggest tha t the weir would not a ffec t c ond itions a fter d isc onnec tion a rguing instead tha t rec overy will b e delayed - suggests that Chowilla should be listed among the Ramsar wetlands because birds may need to move that far if food becomes scarce in the CLLMM region Concerns - the proposal should be considered alongside other current and planned interventions in the CLLMM regions for

Supplementary EIS for the temporary weir near Pomanda Island -161shy

Submission no

Submission from Submission Summary

the purpose of the EPBC Act - that over-allocation of water is likely to be a major contributor to the crisis in the CLLMM - that the alternatives to a weir have not been adequately considered in terms of feasibility costs and benefits in economic and environmental terms ideas such as shandying water are put forward - that there is a significant risk of development of algal blooms including toxic blooms in the weir pool and that there is scientific literature on this local situation - that the weir will be in place for at least 10 years (with reasoning for this conclusion) - the construction of access roads to Pomanda Island should have been subject to an EIS as it iswas a (dynamic) sand spit - that there is little reference in the EIS to work on Acid Sulfate Soils in other places - that the salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences that the tolerable salinity limits for freshwater species need to take into account peak levels not

average levels - that flooding of the Lakes region with seawater will cause a total ecosystem collapse of a Ramsar-listed wetland - that the weir will have an impact on pest species (common Carp and tubeworm) but this is not addressed in the Draft EIS - tha t the term keystone spec ies is misused in Chapter 6 Suggestions - more attention should be paid to mixing processes in the weir pool and Lake Alexandrina with respect to the perceived increased risk of algal bloom formation - tha t we should ma ke more use of others c onsid erab le experience on dealing with Acid Sulfate Soils

PTW00040 Ms Alison Radford SA President Australian Institute of Landscape Architects

The AILA notes that the following points appear to be missing from the Executive Summary under the terms of reference of the EIS and should be included there as they have been addressed in the body of the Draft EIS - what is the potential for deterioration of the quality of water in the weir pool - is there a soil acidification risk upstream as a result of the construction works - how will the weir pool be filled without increased water flows to the River - there d oes not a p p ear to b e any worst c ase sc ena rio discussion of the effects of further disrupting flows within the main River channel Also AILA notes that while there has been a lot of discussion of impacts downstream from the proposed weir in the Draft EIS there is not a corresponding examination of effects upstream AILA requests that future consultation processes include information sessions in the Adelaide metropolitan area

PTW00041 Mr Trevor Harden This submission argues that dust from exposed dry lake beds in the CLLMM region is a major problem and concern and that the best way to control this problem is to fill the Lower Lakes region with seawater a step which requires that the weir at Pomanda Island be built as soon as possible The author is opposed to community groups who advocate a freshwater solution only and argues that historically the

Supplementary EIS for the temporary weir near Pomanda Island -162shy

Submission no

Submission from Submission Summary

CLLMM area is very likely to have been saline especially at times of low river flow He takes issue with the d oc ument A Fresh History of the La kes by Sim and Muller a nd a rg ues with the support of quotes from journals and personal observations that the CLLMM has a history of being a saline estuary at certain times

PTW00042 Mr Bruce Angus Allnutt Committee Member River Lakes amp Coorong Action Group

The submission mainly addresses Chapters 8 and 10 of the Draft EIS Points on matters of national environmental significance relating to the EIS - queries why there is no fishway in the proposed weir - contends that many statements in the Draft EIS use

language tha t suggest there may be impac ts but the authors believe that many of these impacts will definitely eventuate - the authors suggest that impacts on non-listed EPBC-listed species can affect EPBC-listed species because they are part of the same food chain Errors - Page 10-2 of the Draft EIS the authors state that

Tookayerta Creek is a tributary of the Finniss River not of Lake Alexandrina also the Finniss River and Currency Creek flow into the Lower Murray not Lake Alexandrina Concerns - the lack of consideration of ground water resources in the

Draft EIS - that the site for the weir is unsuitable - the loss of habitat due to lack of freshwater flows - that the social issues and impacts are not addressed - that the effects of drought on low water levels are overstated and that the impacts of water over-allocation are likely to be substantial - Table 10-4 states that water levels in Lake Alexandrina will be maintained at +08 mAHD the authors argue that levels of no greater than +07 mAHD should be maintained otherwise there can be serious

erosion damage - the authors are concerned that the systems modelling uses incorrect assumptions or is not reliable (Table 10-8 and Section 1042) - that Section 107 may not be taking into account the extraction of water from pipelines being constructed that take off water upstream of the proposed weir Questions and suggestions - that the EIS should be part of a combined EIS for the larger set of interventions occurring in the CLLMM region - Section 823 that hazardous substances be stored well away from the weir site during construction - query whether the site of the spillway is optimal and suggest that in the present eastern location this will lead to worse silting problems than if it were placed further west - on page 10-3 there are additional reasons for increase in salinity in the Lower Lakes - in Table 10-3 the word sp illway should be inserted a fter weir in the sec ond aspec t point - query why the dilution flow would be disrupted apart from during the weir pool filling period (Table 10-3) - in Table 10-4 there should be a LAC for the Angas River - the modelling has used worst case scenarios was any modelling done with other scenarios

Supplementary EIS for the temporary weir near Pomanda Island -163shy

Submission no

Submission from Submission Summary

- the authors would like clarification of the last paragraph on page 10-30 - top of page 10-31 The authors endorse the majority of the key points of 15 other submissions

PTW00043 Mr Neil Shillabeer Chairperson Lower Lakes and Coorong Infrastructure Committee

Points on matters of national environmental significance relating to the EIS - potential effects of significant mud displacement during building of the weir on aquatic life - states that the Draft EIS Chapter 12 (page 12-2) is incorrect and that the Ramsar boundary does extend above the proposed weir site and quotes section 1248 (page 12-12) Some wetland s up stream of the

weir [that are] still within the Ramsar boundary are expec ted to experienc e eleva ted wa ter levels Concerns - that the time required to fill the weir pool will be greater that stated in the EIS because swamps between Wellington and Mypolonga have subsided and the soils under the swamps have dried out these will take time to be re-wet

- that the weir will be difficult to complete (close) satisfactorily given the design and construction method and that it may be unstable as a result - that the scale of the proposed weir is much larger than the example quoted in the EIS of the blocking bank at Narrung Narrows which has already had problems that required attention including recent problems not included in the Draft EIS

PTW00044 Mr Ron Heyne The author supports a weir or a permanent lock at Pomanda Island and seawater incursion into the Lakes The author is concerned about other weirs at Finniss River Currency Creek and Clayton and pumping water from Lake Alexandrina into the Goolwa channel He understands this will deplete the Lake and expose more Acid Sulfate SoilsHe proposes a channel into Lake Albert from the Coorong

PTW00046 Mr Shaun Berg Lawyer Ngarrindjeri People

This is a lengthy detailed submission which addresses a variety of issues and makes 57 points about the Draft EIS The submission suggests that the Draft EIS for Pomanda Island be rejected and that the building of the proposed weir should be rejected on a number of grounds It is argued that the EIS has failed to take into account Ngarrindjeri views and that Ngarrindjeri Native Title Rights are affected Finally the submission appends the disclaimers in the Draft EIS and the Appendices to the Draft EIS and thereby points to a number of uncertainties in systems modelling (eg salinity wind) and efforts made by Government and consultants to reduce these uncertainties This submission supports those made by two other individuals Early in the submission the following points are made about the wishes of the Ngarrindjeri

1 natural solutions should be used rather than engineering solutions

2 solutions should consider the CLLMM region as an integrated whole

3 the CLLMM region needs to be maintained as a freshwater area

4 environmental flows to the system are needed to

Supplementary EIS for the temporary weir near Pomanda Island -164shy

Submission no

Submission from Submission Summary

maintain freshwater ecology 5 exposed lake beds should be remediated by

plantings or sand 6 cattle and other animals should be excluded from

these areas to minimize acid soil problems 7 hot spots of acid soils should be treated with lime or

sand Omission Table 4-3 is referred to in the text of the Draft EIS but is not supplied Points on matters of national environmental significance relating to the EIS At least 5 points relate to the EPBC Act - the Australian Painted Snipe should be considered in the EIS (with reasoning) - the EPBC protec ted matters searc h tool wa s used to generate the list of EPBC-listed species likely to be found in the region This result is indicative only has consultation with experts also occurred - the draft EIS does not include the Coorong or Lake Albert in relation to impact on Ramsar listed wetlands yet the Coorong and Lakes Alexandrina and Albert were listed together as a wetland of international

importance under the Ramsar Convention the three are related especially given that water is being pumped from Lake Alexandrina to Lake Albert - the potential impacts of weir operation and removal on

EPBC-related matters has not been not addressed Concerns - EIS process at least 6 points deal with EIS process for

example there is concern that the Draft EIS is not a stand-alone document as required (eg accompanying documents referred to in the Draft are not all available)

- Integration is needed at least 5 points deal with the need to consider this Draft EIS together with the environmental impacts of other current or planned interventions in the region (such as the introduction of seawater into the Lower Lakes)

- Over-allocation it is suggested that over-allocation of water is a major reason for the current crisis

- Technical concern is expressed that too little detail is provided about the construction of the weir

- Removal of the weir no consideration has been given to the removal of the weir if the Lower Lakes have been flooded with seawater This needs to be considered

- Alternative solutions 14 points deal with alternative solutions to the building of a weir it is argued that alternative solutions have not been described or considered in sufficient detail particularly the possibility that

combinations of alternatives may be an effective way to gain sufficient freshwater supplies

- Systems modelling concern is expressed that (a) the impacts are assessed only with an inflow of 896 GLyear to SA other scenarios with lower inflows need to be considered (b) salinity is only modelled for one year (c) impacts of the weir on water temperature

and turbidity are not addressed sufficiently - Soil chemistry risks associated with Acid Sulfate Soils

upstream of the weir and potential impact on the potability of water around pumping stations should be given greater attention there are several questions

Supplementary EIS for the temporary weir near Pomanda Island -165shy

Submission no

Submission from Submission Summary

about Acid Sulfate Soils for example what is the likelihood that the building of the weir itself will lead to a pH crash

- Management and mitigation a number of concerns are raised about what monitoring enforcement mitigation and review procedures will be applied

Suggestions - that the Draft EIS for Pomanda Island be rejected on the grounds that it does not comply with the Guidelines - that the SA Government take into account the changed use of the weir (from a means of securing water supply only to also acting as a barrier to ingress of saline or polluted water into the river) and then resubmit an EIS which covers this broader scope - that the Draft EIS fails to support the construction of a weir at Pomanda Island on the following grounds

1 The proposal does not consider alternatives sufficiently particularly combinations of alternatives

2 That the draft fails to distinguish adequately between impacts of the scenarios with and without the weir

3 There is a risk that the water quality in the weir pool may be poor because of algal blooms

4 There is insufficient attention given to the problem of Acid Sulfate Soils and measures taken elsewhere to solve this problem

5 The proposal should be integrated with other proposals eg the proposal to allow seawater into the Lower Lakes

6 The treatment of EPBC-listed species is superficial and lack plans for mitigation of negative impacts

- that the Draft EIS fails because it does not take into account views of the Ngarrindjeri - that Ngarrindjeri Native Title Rights are affected by the proposal and a number of points are made in relation to this claim

PTW00047

PTW00048

PTW00049

Mr Andrew Milazzo Executive Director TSD DTEI

This submission details the requirements for technical aspects of commissioning the weir according to DTEI regulations Examples are the inclusion and positioning of warning lights on the structure and signage The submission notes that there was no mention in the Draft EIS of the operation of the Narrung Ferry

Ms Jacqui Showell Suggests Adela id e s wa ter supp ly is the main d river for the weir Questions if enough alternatives are being investigated Concerned that decommissioning criteria will never be met Suggests ecological effects downstream will also occur upstream affecting the whole country Believes the system should be treated as a whole Suggests acid and heavy metals will affect regions and Ad ela id e s d rinking wa ter Concern for flora fauna (particularly southern bell frog Murray cod and migratory birds) and Ramsar obligations

Ms Cecily South Over-allocation and human activities need to be addressed The Eastern Mount Lofty Ranges flows into Lake Alexandrina mitigate ASS and heavy metals Further water savings are possible if households have allocations rather than timing restrictions There is water upstream get it Crops that cannot be sustained with irrigation should be

Supplementary EIS for the temporary weir near Pomanda Island -166shy

Submission

no Submission from Submission Summary

abandoned - change to sheep and cereals Reference to technical paper written by Brooks and South The barrages all lead but must be kept closed The SA Government and SA Water should stop pumping from Lake Alexandrina into Adelaide storages Landowners are losing 2-3 metres of lakefront pa The author is opposed to seawater incursions

PTW00050

PTW00051

PTW00052

PTW00053

Ms Ruth Beach Solicitor Environmental Defenders Office (SA) Inc

Points on matters of national environmental significance relating to the EIS

- this submission argues that the proposed weir will be permanent rather than temporary because the conditions for its removal are not likely to be met and that it will be physically very difficult to remove the weir as such the proposed weir should be assessed under the Development Act and the Draft EIS should take into account permanent effects on the environment in the CLLMM region including the Ramsar-listed wetlands and associated fauna and flora

- proposes that the construction of the weir is in contravention of legislation (State and Federal) and international conventions (Federal EPBC Act Water Act Murray-Darling Basin Act State Development Act River Murray Act Natural Resource Management Act Environment Protection Act)

- it is argued that the Draft EIS and proposed weir should be considered alongside other current and planned interventions in the CLLMM region

Concerns - that the EIS has not given sufficient consideration to

alternative sources of water - that other relevant Government reports are still in

preparation Ms Silver Moon Suggests EIS should and fails to be about the impact of an

action Suggests there is deficient understanding of the environmental processes and interactions in the Coorong and Lower Lakes Suggests climate change needs to be addressed Contributes considerable researchedreferenced information on various fauna and suggests they should be included as matters of NES Indicates the significant impact weir construction will have on wildlife and the system Suggests Australia has agreements it must abide by Suggests Chapter 15 is vague and lacking substance Suggests the weir does not meet principles of environmentally sustainable development and calls for action in addressing water allocation in the Eastern Mount Lofty Ranges including Finniss catchment

Mr Rex Hunter Confidential submission

Mr Tim Drew CEO The Coorong District Council

The Council points out - Tha t muc h of the CLLMM area is within the Counc il s boundary and details the population and main land uses - That the area is of particular significance to the Ngarrindjeri - That the Coorong and Lower Lakes were listed in 1985

as a wetland under the Ramsar Convention and that

Supplementary EIS for the temporary weir near Pomanda Island -167shy

Submission no

Submission from Submission Summary

a req uirement is to manage the a rea in a way tha t mainta ins [its] ec olog ic a l c harac ter

- That the Coorong and Lower Lakes are icon sites under the Living Murray Initiative - That as a response to the situation it has established the Lower Lakes and Coorong Infrastructure Committee (2007) - That it is opposed to the construction of the weir at Pomanda Island and any other new man-made structures in the River Murray

Points on matters of national environmental significance relating to the EIS

- the submission points out that there is a Ramsar wetland just upstream of the expected weir site at Pomanda Island and that this needs to be corrected in the Draft EIS - there is concern that there will be significant algal blooms after weir construction and that this will have a negative impact on native fish stocks

Concerns - that the present situation has been brought about by over-allocation of water resources across the MDB rather than by drought - the economic and social impacts of the situation (low water levels and flows) are very serious - that the weir will intervene in the natural river system and have a negative impact as a result - that the Draft EIS Chapter 26 includes the topic of maintenance of water levels for pumping purposes and that this was not included in the original referral to the Federal Government - that the modelling in Chapter 2 is in error because the forecast figures used for levels of L Alexandrina considerably understate the winter rainfalls of 2008 - that the modelling in Chapter 2 may be unreliable because it relies on estimates - that the triggers for removal of the proposed weir need to be more clearly defined and more realistic (the current conditions for removal are not likely to occur for another decade) - that there is a significant risk of blue-green algal blooms in the weir pool - that there is a risk of heavy metal release and acidic soils if the weir is built and potential impact on wildlife - that the weir will lead to the build-up of water with low oxygen concentration with risk to fish populations - that the significance of wind movement (wind seiche) is underestimated in the Draft EIS

PTW00054 Prof Diane Bell Committee Member River Lakes amp Coorong Action Group Inc

The Draft EIS should be rejected because it is inconsistent with the Guid elines for the Content of a Draft Environmental Impact Statement on the Proposed Temp ora ry Weir a t Pomand a Isla nd The p roposa l

- is not a stand-alone document - should properly be considered as part of a larger plan - lacks detail to support plans for construction operation and removal - has no staged and costed short mid and long-term plans for mitigation of NES - fails to investigate alternatives

The proposal will not achieve its stated goals because the

Supplementary EIS for the temporary weir near Pomanda Island -168shy

Submission no

Submission from Submission Summary

- triggers for removal are unrealistic - construction is problematic - water quality above the weir will be poor

The proposed action is likely to have significant impacts on internationally protected wetlands and species that the Federal and South Australian governments are obliged to protect The proposed weir is not the solution to the crisis in the Lower River Murray and Lakes The SA Government should be required to submit a Referral which takes all proposed actions into account and explores all options Part 1 the status of the EIS procedural points Summary It is their contention that the Draft EIS is significantly flawed and should be rejected by the Minister under Section 133 EPBC or alternatively the Minister should require that new Draft Guidelines ones that accurately reflect the situation and the needs of Adelaide for a secure water supply be prepared by the SA Government A number of points require further consideration

1 There is no longer a crisis of water security Minister Maywald has announced she has bought water for next year Acidification and increased salinity are now significant issues but were not when the Guidelines were published Given that both quantity and quality issues have changed the Guidelines should be varied or a new Referral written

2 Since the proposed temporary weir referral there have been a number of other proposals which impact on the quality of water (a weir rationale) The EIS is (therefore) flawed because it is not a stand-alone action and is in violation of the Guidelines

3 The author asserts that the triggers for removal cannot be achieved and there is no long-term plan that explains how they might be achieved

In other points the writer expresses a desire for access to related documents greater clarity and certainty less repetition in the draft EIS and for supplementary reports to be ava ilab le In a d d ition the EIS outlines c onsulta tion whic h has been inadequate ineffective and non-responsive to pub lic questions Part Two Chapter commentaries substantive questions The a uthor s summary sta tesThe EIS is tentative incomplete lacks detail and refers important matters to further supplementary reports and EIS The author states that the SA Government should be req uired to make d eta ils of the freshwa ter solution available as part of the EIS process She asks for a stronger d efenc e of the weir as the only feasib le op tion Referring to Richards she indicates that over-allocation and poor management continue on the Finniss and other tributaries today and asks who makes decisions about critical human needs and under what conditions On wetlands she states that the EIS cannot be considered competent and on seepage and run off the EIS does not give due consideration and states that the criteria for removal are unrealistic and unlikely to be met The Draft EIS displays little or no understanding of the imp ortanc e of c ultura l flows to the Nga rrind jeri

Supplementary EIS for the temporary weir near Pomanda Island -169shy

Submission no

Submission from Submission Summary

Chapter 2 comments as for submission by K McFarlane Chapter 3 comments this consists of pages 7 and 8 of the EDO submission which sets out reasons for non-approval of the Draft EIS under various legislative and regulatory processes Chapter 4 comments this is a combination of K Mc Farla ne s sub mission with a few c ha nges with the addition of the suggested Government freshwater purchase options (staged over three years) from C Ba g ley s submission Chapter 5 Proposed works to be undertaken The author contributes local knowledge about aspects of the Causeway which indicate that it is a dynamic area and that the development of the Causeway will create new flow patterns during floods Comments included

- there is no staged plan for the period of the weir pool filling to manage water issues and consequences below and above the weir - there is insufficient detail describing weir construction methods - insufficient is known about embankment materials and potential to pollute

Concern is expressed about - the amount of weir material which will sink or be washed downstream - the lack of an Environmental Management Plan - the lack of a fish passage - unrealistic weir decommissioning triggers and lack of detail in decommissioning planning

Relevant aspects of the submission by Liz Yelland are then included Chapter 6 comments replicate those submitted by Silver Moon in her submission Chapter 7 comments replicate those submitted by Silver Moon in her submission Also included is a portion of Anne Hartnetts submission (80409 page 5) The first section asserts Australias seemingly low honouring of Jamba Camba Kowamba and the Ramsar agreement and refers to the effect of the weir on migratory birds and the significance of weir placement at a meeting of waters Further Hartnett references (page 5) are made in relation to water levels and the need for spelling out of the effects of MAJOR interventions to remedy the result of these that

would be felt by all other biota Chapter 8 comments this is essentially taken from the submission by B Allnutt and T Giles with an additional comment expressing concern about the risk of habitat loss which in turn leads to species extinction Chapter 10 comments this section contains almost all of B Allnutt a nd T Giles submission (exc ep t for the summa ry of c omment for EIS p lus a paragrap h referring to C Bag ley s submission (questions about salt mobilization when sufficient ra in fa lls) two c omments from K Walker s sub mission (concerns about algal blooms upstream of the weir and acidification of wetlands upstream of the weir) and pages 3 to 5 of L Yella nd s sub mission a b out wind seic hing Chapter 11 comments this includ es N Shillabeer s submission one page (pa ge 4) of A Ha rtnett s submission (the effect of the weir on upstream water quality) and two

Supplementary EIS for the temporary weir near Pomanda Island -170shy

Submission no

Submission from Submission Summary

paragra p hs from S Ric ha rd s sub mission (wa ter qua lity) Chapter 13 The criteria for removal are unrealistic and unlikely to be met This underlines the lack of a long-term rec overy p lan and c asts d oub t on the tempora ry na ture of the weir Chapter 14 comments raise the absence of the Milang Snipe Sanctuary from the draft EIS Page 67 contains the list of birds also contributed by Silver Moons submission (Moon S un-numbered page re section 77 Summary) Commentary on Chapter 15 Environmental safeguards and mitigation measures raises

- Lack of fish passage - Diminution of freshwa ter hab ita t for two mentioned fish spec ies - c omment tha t a rg uements tha t the impac t of the weir c onstruc tion a nd opera tion a re minima l a re misguid ed and fa ils to rec ognise the p rob lem

Further Chapter 15 inclusion replicates in full questions raised by Liz Yelland (submission PTW 34 pages 1-2)

PTW00055 Mr Tim Milne Scientific Officer Nature Conservation Society of SA

Issue 1 Suggests the weir will exacerbate water level reduction and potential problems increasing need for remedial action Also suggests EIS does not address remedial action required Solution 1 examine the impacts of actions to increase water levels in the Lake as these are a direct consequence of weir construction and operation Issue 2 Risks to species associated with increased salinity and acidity Solution 2 EIS should examine impacts of accelarated incareases in salinity and acidity of the water Issue 3 Shortcomings in the environmenetal assessment of construction in Ramsar wetlands Solution 3 Full range of florafauna species need to be examined Issue 4 Lacking accurate information on period of operation and predictions of removal triggers Solution 4 EIS should assume the weir to be permanent to mitigate matters of NES in case this occurs

PTW00056 Ms Gillian Whiting Project Coordinator Murray-Darling Basin Authority

This submission is in the form of the letter addressed to the Director CLLMM Projects under the signature of the Chief Executive Rob Freeman Murray-Darling Basin Authority The letter notes that the proposed temporary weir must be assessed and approved under the Water Act 2007 (Cth) The MBDA requires more details than already provided in the EPBC Act referrals The MBDA asks for clarification and expansion of a range of issues - flow use control and quality of water The MBDA requires information and data relating to hydrology design flow assumptions water balance (inflows storage outflows) assumed water volumes design flood assumptions Hydraulics design details relating to flood surcharge and Water Quality flow cessation into Lake Alexandrina and seawater introduction and acidification thresholds The authority seeks additional information in order to make an Environmental Assessment on fish passage and disconnected wetlands below Lock 1 Weir plans must be submitted to the Authority for

Supplementary EIS for the temporary weir near Pomanda Island -171shy

Submission no

Submission from Submission Summary

consideration and approval Information is required about the capacity of the weir crest to resist erosion More detail is required in relation to weir removal in relation to definitions of normal time required to remove method of removal if a flood Other issues in relation to increased salinity in Lakes Alexandrina and Albert the effect of potentional increase in heavy metals and salinity and increased acid production It is anticipated that the Authority will require at least six weeks to undertake its approval processes

PTW00057 Mr David Winderlich Member of the Legislative Council Leader of the Australian Democrats

The author suggests that the cost of the weir be put into buying water bioremediation and assisting communities experiencing hardship due to low flows In his opinion the Lakes ecosystem and relevant matters of NES will not tolerate the impacts of the construction of the proposed weir The author advocates a natural freshwater system

PTW00058 Ms Kathryn Rothe Project Manager Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

Background this submission is on behalf of the Mannum to Wellington Local Action Committee and the Mypolonga Highland Land and Water Management Committee This submission relates in some aspects to the submission by Ruth Trigg Points on matters of national environmental significance relating to the EIS - lack of a fish passage across the weir is pointed out - concern about loss of important habitat Concerns - that the weir is only a bandage solution and that a strong integrated plan is needed that encompasses the environmental as well as social and economic survival of the Lower Murray and the CLLMM region - the submission does not support the construction of a weir and argues that alternative measures must be used especially the purchase of freshwater upstream for the CLLMM and Lower Murray region - that over-allocation of water is an important cause of current problems - that alternative water supplies have not been given sufficient consideration - that there have been and are many plans and reports about the situation but there does not seem to be a holistic or integrated plan - tha t g rowth in the Sta te s pop ula tion will put even more pressure on water and other resources - the allocation of water to different users needs to be reassessed by the MDBA in a holistic way and with food production as a priority - that the weir will be unstable Suggestions - that freshwater be brought downstream to SA where evaporation rates are much less than at the Menindee Lakes - that bioremediation of Acid Sulfate Soils is already occurring - that the new MDBA should start emergency actions in the region as soon as possible - that alternative sources of water and water conservation and re-use measures be put in place The author points out that the task of preparing this

Supplementary EIS for the temporary weir near Pomanda Island -172shy

Submission no

Submission from Submission Summary

submission was daunting and that it took a lot of time effort and community spirit to prepare This submission endorses the submissions of approx 18 other individuals and groups

PTW00059 Ms Karyn Bradford The writer highlights long connection with the CLLMM extensive knowledge and a long list of achievements in the region The submission contains additional references The writer is concerned that there has been a lack of effective public consultation and that government ministers and their employees chose to dismiss the knowledge skills and expertise freely offered by members of the community many of whom have intimate and generational knowledge of the Lakes and Coorong environment EIS coverage The writer believes that the EIS should be rewritten to include all proposed action for the CLLMM region Language used EIS la nguage is c ritic ised a s [c asting] d oub t on the qua lity and veracity of the informa tion p rovid ed and a s having very few d efinitive sta tements

Seiching A very strong possibility that un-potable water could travel down the river and be trapped behind the weir is identified as a flow on effect of interruption of wind seiching Fish passage The lac k of a llowa nc e for a fish passage is sta ted as not meet(ing) one of the three key ecological objectives of the Murray-Daring Basin Commission Environmental Management Plan 2007-2007 for the CLLMM Icon Site River and Lakes system complexity not understood The writer states that the EIS shows that the proponent does not understand the complexity of the interactions between the River Murray Lakes Alexandrina and Albert its tributaries and the Coorong Ramsar principles breached The author submits that the Ramsar wise use tenet and the precautionary principle are breached by the weir at a time when over-allocation and drought have already done c onsid erab le ha rm to the environment The writer endorses submissions of other named persons A table is used to identify and address issues applicable to specific sections of the EIS including - Executive Summary Purpose

Questions whether full information is available No discussion of bad water coming down Murray Seawater option outside this EIS Alternatives to EIS proposal named

- Executive Summary Introduction Possibility that weir will contribute to algal growth if mixing is impeded

- The original referral Lack of fish passage contradicts Murray-Darling 2007shy2007 Management Plan objectives

- Draft EIS section 737 References to Angus and Bremer Rivers are omitted d esp ite signific a nt b iod iversity va lues partic ula rly a t their c onfluenc e with La ke Alexa nd rina

- Draft EIS section 7-5 Why were only 9 of the 68 listed threatened species discussed in detail

Supplementary EIS for the temporary weir near Pomanda Island -173shy

Submission no

Submission from Submission Summary

Short and Long necked turtles and the Japanese Snipe are of particular interest to local people

- Appendix 15 Raises concern with levels of confidence in 64Confidence in impact assessment Suggests that further information is required

- Selections from the EIS The uncertainty expressed by the use of qualifiers in the EIS language is raised as a concern Question Is there enough evidenc e for this p rop osa l to proceed without further study of all aspects of the p roposa l

- Section 121 A sta tement is mad e tha t the weir will not may interact with the ecological values of the Lower River and Lakes

- Section 141 An attachment provides a record of migratory birds sighted in the area The definition of regularly sighted birds in the EPBC Act is questioned and a Web address supplied at which a local record of birds sighted is kept httpwwwmilangorgauMilanghtm

PTW00060 Mr Mike South Attachment Brooks B amp South M Discussion Paper 19 August 2008 Applying a localised water balance approach to estimate losses from Lake Alexandrina and Lake Albert for the years 1970 to 2006 The author suggests that the models used for the virtual weir should be used with caution and a range of further scenarios need to be modelled A clarification is offered in relation to weir pool levels and pumping SA Water pumps can access water at minus 30m therefore there is no need to maintain levels at +1m AHD The a uthor d isc usses in d eta il sec tion 452 Red uc ing Evapora tive losses of the d ra ft EIS and d isputes the statement that 70 of evaporative losses occur in the Lower Lakes He concludes that long-term evaporation for the Lower Lakes is an over estimate and that the apportionment of losses inappropriately biases the Lakes

PTW00061 Mr Jonathan McPhail Inland Fisheries Management Officer PIRSA Fisheries

The proposed weir will increase pressure on fish stocks and fish habitats which will have significant environmental impact on commercial and recreational fishing Habitat above the weir water will be more stable than currently The changed flow regime will better support European carp and negatively impact on spawning recruitment and migration of Murray cod Murray hardyhead and Yarrra pygmy perch This will work contrary to the MDBC Native Fish Strategy Water quality Removing saline water above the weir will d iminish na tive fishes c omp etitive a d vantage Potentia l decreases in salinity and increases in nutrients and sedimentation will also favour European carp and Mosquito fish and potentially increase the threat of blue-green algae blooms A fish passage is required to support migration of species upstream and downstream and to support upstream fish movements as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline

Supplementary EIS for the temporary weir near Pomanda Island -174shy

Submission no

Submission from Submission Summary

In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river The proposed temporary weir will have severe negative impacts on the available fish habitat and water quality and affect the environmental sustainability of commercial fishing

PTW00062 Mr Glenn Williams Natural Heritage Manager Natural Heritage Trust

The writer has 4 areas of key concern with the EIS 1 Failure to take an ecosystem approach

- The imp a c t of adding a further 5200 hectares to the tens of thousands of hectares of fringing reed-bed habitat that have already dried out and degraded along with their micro and macro invertebrate populations has been stated but not properly assessed in the EIS

- The EIS tends to b e qua lita tive ra ther tha n quantitative both of the proposed weir construction and the altered water regimes across ecosystems A clearer quantitative estimate of potential impacts upon na tive vegeta tion is need ed An example is given relating to impact of rock acquisition on native vegetation

- The writer states that the impact on wetland vegetation and (specifically) samphire plant communities should be quantified more accurately

- The writer is concerned that the EIS does not address over-allocation of water and states that no water allocation has been made for the Ramsar site Irrigation and upstream allocations are referred to

- It is asserted that the weir will withhold even more flow including 350MLday to flush out salt emanating from upstream water-using activities

- EIS is considered to give insufficient attention to the potential implications for the Coorong and the hydrological links between the Lower Lakes the Goolwa Channel and the Coorong particulalry during the period of filling the weir

- The writer believes that the Draft EIS lacks context and overview of the range of other feasible actions that might have been taken as well as those needed with the construction of the temporary weir

2 Failure to seriously examine pursue and commit to fund ing other rea sona b le a nd p rud ent a lterna tives

- The writer argues that human needs have been given priority with minimising of environmental impact being a secondary objective

- The writer asserts perceived lack of action by the state government to decrease reliance on Murray giving examples of water allocation from the Murray to the Clare Valley the BILL scheme Port Lincoln and a Port Hughes golf course

- The writer sta tes tha t the p roponent s EIS ob liga tion to exa mine p rud ent a nd fea sib le a lterna tives has

not been fulfilled by the failure to seriously address - Harvesting of stormwater and more substantial flows

from the short west-flowing creeks of the Mt Lofty Ranges

- Promoting water tanks - Increasing Adelaides water restrictions - Pricing water more competitively particularly for

Supplementary EIS for the temporary weir near Pomanda Island -175shy

Submission

no Submission from Submission Summary

industry and irrigation - The writer considers that the movement of the

pumping stations to above Lock One is a better alternative to the weir

3 Failure to adequately address impacts on EPBC Act-listed fish and frog species

- The writer sta tes tha t the EIS ignores c ond itions below the weir and only concentrates on higher water levels above the weir

- The writer notes that there is no commitment to building a fishway to address the impact on Murray hardyhead and Murray cod caused by disconnectivity between the Lake and River and further sta tes tha t the EIS seems to g loss over the very serious impacts that the iconic Murray cod will suffer from reduced water levels and wa ter qua lity

4 Failure to address geotechnical structural problems with the weir

- Refer section 55 and Executive Summary and Appendix 6

Specific issues raised refer to - poor foundation conditions except for the eastern

half of Getochnical model 1 - low sheer strength indicating slope instability - continuing movement and settling of clays - seepage and possible development of piping - impact of earthquakes on foundation sands

Other concerns addressed in short are - The temporary weir being left in place for a longer

period - writer s rec ommend a tion tha t a c tive-adaptive

processses be adopted for bio remediation of Acid Sulfate Soils and a need to clearly identify the indigenous plants to be used

- lack of information on impacts of temperature changes in the Lakes water column

- failure to address the oxygenation of the River water through wind seiching

PTW00063

PTW00064

Ms Beryl Belford Writer supports a one river and whole of basin approach to ecological management of the River and Lower Lakes The writer believes that - water is available in the basin to save the River system - the federal government must take responsibility for equitable distribution of water - state government should regulate water held in stock and domestic dams in Eastern Mt Lofty ranges to ensure environmental flows to the Lower Lakes

Ms Elizabeth Hobbs Points on matters of national environmental significance relating to the EIS - the author is alarmed that the potential impacts of the weir on the Coorong are referred to so little - states that the list of endangered species in the EIS is too narrow and argues that as both species and habitats are interconnected they should not be split up for the purpose of the EIS - emphasizes the need to have healthy waterways in the region due to its ecological importance Concerns - the author is concerned at the cost of the weir and other interventions in the CLLMM region and quotes from other

Supplementary EIS for the temporary weir near Pomanda Island -176shy

Submission no

Submission from Submission Summary

submissions on this point - from first hand experience at seeing sediment build up due to low water flows the author is concerned that this will occur at the weir site and there will be an impact of this silting up - that the weir is a technical solution for problems that should be solved by other means - that the proposed weir needs to be considered as part of the larger set of interventions occurring and being planned in the CLLMM region - that over-allocation of water rather than drought is the reason for major problems occurring Suggestions - the author proposes that there are alternative measures that should be put in place and expanded to reduce Ad ela id e s relia nc e on wa ter form the River Murray - an interconnected systems solution needs to be developed to protect the area listed under the Ramsar agreement

PTW00065 Dr Talina Vizard The writer questions Can local springs be channelled into the river (eg from Victor Harbor) Would redirecting storm water into the system help Have views of Ngarrindjeri been considered Can the use of bore water be policed and how can farmers be educated to the effect of taking water from the c ommon store

Writer Comments Time for comment too short Writer supports the submissions of Liz Yelland (PTW00034)

PTW00066 Ms Carlsa Carter The author states that the South Australian Government ignores the serious environmental condition of the Coorong and Lower Lakes and withholds minimum environmental flows The author states that there is a lack of thorough information about EPBC-listed species and species of the freshwater ecosystem and states that the loss of reed beds and habitat during the period of weir construction is trivialised Attention is drawn to a bird survey by Dr Kingsford of Newcastle University (2009) which shows greatly reduced numbers of water and wading birds over a short period

PTW00067 Ms Julie Pettett CEO Conservation Council of South Australia

The CCSA opposes the construction of a weir near Pomanda Island while accepting that the provision of drinking water is critical CCSA states that the impact of the weir will have unacceptable impacts on several matters of NES and the idea that the weir will be temporary is strongly contested CCSA argues that the EIS is seriously deficient and that the EIS for the proposed temporary weir should be reshyconsidered in conjunction with a referral EIS and public consultation about the introduction of seawater into the Coorong and Lower Lakes The CCSA is concerned about the impacts of a weir on Southern bell frogs Murray cod Murray hardyhead and Yarra pygmy perch and may be able to provide a supplement to the submission about these concerns at a later date CCSA states that the construction of a weir will destroy and degrade more than a hectare of Ramsar wetlands flora

Supplementary EIS for the temporary weir near Pomanda Island -177shy

Submission no

Submission from Submission Summary

and reed beds and have consequent impacts on listed threatened species and migratory fauna Construction of a weir is likely to contaminate the Lake and impact on Ramsar wetlands threatened species ecological communities and migratory species Triggers for removal are discussed CCSA states that the weir will exacerbate acidification of the Lower Lakes and thus the weir will need to be permanent In addition CCSA states the Hume and the Dartmouth storages have not been at normal operating levels for ten years and achieving the prescribed salinity level is unrealistic These factors suggest a permanent weir CCSA believes more consideration needs to be given to the Federal government purchasing water and structural adjustments under the Water for the Future Program Stormwater harvesting aquifer storage and recharge and wastewater re-use would be less environmentally harmful options than a weir

PTW00068 Ms Paula Horbelt Secretary Goolwa District Ratepayers amp Residents Association Inc

This submission urges the State Government to consider water alternatives as Salisbury Council has done It is suggested that Cheltenham could be similarly used as a water capture site The Association encourages rainwater tank policy but questions the energy intensity costs of desalination The Association is concerned that a weir will increase salinity levels in Lake Alexandrina and that Ramsar sites of significance will not be protected The Association understands that water quality between Lock One and a weir at Pomanda island would inevitably deteriorate due to inadequate wind seiching In conclusion the submission states We support the purchase of water rather than weirs temporary or otherwise

PTW00069 Mr Keith Scobe The writer is a member of the Ramsar Taskforce His submission expresses a preference for securing water from upstream He refers to submergable floating booms as a method managing water (instead of a weir) He expresses uncertainty about the no flow period over the weir and expects weir construction costs will escalate He expresses hope that the MDBA will manage the Murray Darling Basin well in future

PTW00070 Ms Ruth Russell The writer is opposed to the construction of a weir and argues for a sustainable freshwater long-term management plan for the Murray-Darling Basin overall The author contributes to Adelaide University Frog Census work and has engaged with CLLMM issues in the region She urges a well researched long-term freshwater solution so that there is a postive outcome for future generations The writer urges - better use of a range of water alternatives - accessing water from the temporary water market through the Water for the Future Program - adoption of the precautionary principle - rejection of this EIS in favour of a more holistic and systematic EIS acknowledging complexity and interdependency The writer understands that the weir will be destructive of nationally listed species and suggests a fish passage should be included She fears algal blooms due to ineffective wind seiching as well as acid soils impacts on water qulaity The

Supplementary EIS for the temporary weir near Pomanda Island -178shy

Submission Summary

writer also fears that the weir will not be temporary PTW00071 Mr Ken Jury and

Mr Mike Young The authors are critical of the unrealistic timeline for consultation They propose a permanent weir which prevents loss of freshwater above and allows an esturine environment in the Lakes below This environment would support wader birds and improve tidal access to the north CoorongThe River Lower Lakes and Coorong must now be regarded as a human-altered environment and managed to suitThe authors argue that it is important not to allow the mobilisation of acid from soils into water as this will corrode the barrages They believe the only option is to inundate the Lakes with seawater and query the freshwater science presented A diversion pipeline is suggested from Morgan and questions are raised about loss of River water into aquifers

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -179shy

Government of South Australia

  • Table of Contents
  • Part Two - Community Consultation Report ndash Appendices
Page 5: Supplementary Environmental Impact Statement

Table of Contents

PART ONE SUPPLEMENT TO THE DRAFT EIS 1

1 Introduction to the Supplementary Environmental Impact Statement (EIS) 2

Overview of Supplementary EIS structure 2 Purpose 2 DEWHA issues 2

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region 3

Submissions received and responses 3

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir 5

Submissions received and responses 5 Murray-Darling Basin Authority submission 5 The time required to remove the temporary weir 5 Floods 5 Phytophthora at the temporary weir construction site 6 Weir Causeway 7 Weir Site 7 Weir Construction and Environmental Management Plans 7 Weir Materials 8 Weir Crest 8 Pumping 8 Permanent Weir 8 Triggers for Removal 9 Salinity measuring locations 10 Decommissioning 11 Modelling 11 Virtual Weir 13

4 Supplementary comment on expected impacts of the temporary weir on soils and water 14

Introduction 14 Submissions received and responses 14 Acid Sulfate Soils (ASS) 14 Water quality 16 Wind seiche 16 Impacts upon Coorong and Lake Albert 17 Dredging of Murray Mouth 18 Water quality impacts near Narrung Narrows 18 Algal blooms 20 Summary of water quality impacts 21 Connectivity of Surface and Ground Waters 22 Surface Waters 22 Groundwater 23

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels 24

Introduction 24 Upstream impacts 24 Impacts of altered water regime in weir pool 24 Impacts to Pelican Lagoon and Nalpa Station 25

Weir Footp rint Impac ts 25 Impacts of Habitat LossDegradation 25 Impacts upon fish migration 26 Impacts of noise upon wetland birds 27 Monitoring during constructiondecommissioning 27 Timing of construction and presence of migratory species 28 Downstream impacts 28 Impacts of water level changes upon aquatic vegetation 28 Impacts of temporary increase in salinity upon aquatic biota 28 Impacts upon tributary wetlands 31 Impacts upon the Milang Snipe sanctuary 31 Impacts upon primary determinants of ecological character 32 Impact upon keystone species 32 Impact upon habitat availability 32 Impact upon salinity 33 Impact upon turbidity and sedimentation patterns 33 Impact upon water levels 33 Impact upon water regime 33 Impacts upon migratory shorebirds 34 Impacts upon Australian Painted Snipe 34 Impacts upon Orange-bellied Parrot 34 Impacts upon Great Egret Cattle Egret and Caspian Tern 35 Impacts upon pelagic birds 35 Impacts upon bush birds 35 Impacts upon Mt Lofty Ranges Southern Emu Wren 36 Impacts upon White-bellied Sea Eagle 36 Issues of scope adequacy and definition 36 Adequacy of species and communities examined 36 Current status of waterbirds 37 Adequacy of EPBC Act threatened species and communities lists 37 Adequacy of discussion of EPBC Act-listed species 37 Omitted flora and fauna records 37 Definition of keystone spec ies 38 Spec ies c onsidered of partic ula r signific anc e 38 Adequacy of description of different wetland types 38 Regional importance of the Coorong Lower Lakes and Murray Mouth 38

6 Notes on significant issues outside the scope of the draft EIS For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities 39

Ngarrindjeri People 39 Social and economic issues 39 Climate change 40 Dust and health 40 Other themes 40

7 Suggested text changes errata additions clarifications and references 41

References 53

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA) 54

General comments 54 Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth 54 More specific comments 61 Water supply 68 Removal triggers (pg 1-6) 70 Wetlands 72 Re-wetting of upstream wetlands 75 Threatened and migratory species 77 Fishway 81

PART TWO COMMUNITY CONSULTATION REPORT 85

1 Introduction 86

2 Community Information Sessions 86

3 Targeted Meetings 89

4 Overview of media articles (see Appendix VII) 89

5 Receiving submissions and developing the Supplementary EIS 90

PART TWO COMMUNITY CONSULTATION REPORT - APPENDICES 93

Appendix I - Submissions received Individuals 94

Appendix II - Submissions received Organisations 96

Appendix III - Participants and notes from Targeted Meeting Sessions 97

Appendix IV - Organisations that participated in Community Information Sessions 109

Appendix V - Participants and notes from Community Information Sessions 110

Appendix VI - Advertising copy used in the consultation process 127

Appendix VII - Media generated by the consultation process 146

Appendix VIII -Summary information of enquiries and submissions for provision of the proposed temporary weir 148

Appendix IX - Table of submissions 149

Executive Summary

The purpose of this Supplementary Environmental Impact Statement (EIS) for the temporary weir near Pomanda Island is to address Issues of National Environmental Significance (NES) (as defined in the Environmental Protection and Biodiversity Conservation Act 1999) arising from written public submissions and government comment during the period of public consultation for the Draft EIS

Part One is the Supplement to the Draft EIS provides supplementary comment in the form of overview summaries of key issues raised in public submissions and by government agencies

Part Two is the Community Consultation Report provides an overview and describes the activities undertaken throughout the community consultation process leading to writing the Supplementary EIS

Part One of the Supplementary EIS is divided into 6 key sections

Section 1 contains an overview of the document

Section 2 considers the role of the temporary weir within the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth Region These comments are made in response to a number of submissions that suggested that the temporary weir was being considered in isolation

The sec tion outlines the Government s multi-faceted strategy to combat the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region

This strategy includes both long and short-term plans including worst-case scenario measures that would only be implemented as an option of last resort should a fresh-water solution not be found

Section 3 considers submissions relating principally to Chapter 5 of the Draft EIS Proposed Works to be Undertaken

The Murray-Darling Basin Authority (MDBA) submission outlined the approvals necessary under the Commonwealth Water Act 2007 and in particular under clause 49 50 and 63 of the Murray-Darling Basin Agreement

The South Australian Government submitted a detailed application to the MDBA on 15 May 2009

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process however the Authority sought details on the method of removal of the temporary weir in the event of a flood coming down the River

As the flood scenario was not discussed in the draft EIS it is addressed in the section 3 of the supplementary EIS

Any flood moving down the River is most likely to have originated in the upper reaches of the river system and can take up to six weeks to reach the temporary weir location During this time an assessment will be possible as to the appropriate method of management of the temporary weir structure

A significant cluster of submissions were made regarding triggers for removal or decommissioning of the temporary weir

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria stated in the Draft EIS remain appropriate

Other submissions considered in Section 3 relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the proposed temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir A number of submissions also raised concerns about modelling

By way of response section 3 outlines the environmental management framework for the temporary weir including an Environmental Management Plan which ensures management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Section 4 provides an overview of submissions relating to expected impacts of the temporary weir on soils and water

A number of submissions raised concerns regarding acid acidity and Acid Sulfate Soils (ASS) These submissions support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible

ASS field investigations and modelling will enable key information gaps to be addressed and be fed back into the ongoing planning and measures undertaken

Wind seiche and its impact on water quality also formed the basis of several submissions as did possible increases in algal blooms within the weir pool itself

While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes

Some submissions sought clarification regarding the interaction between surface and ground waters

Section 5 Submissions discussed in Section 5 relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

A process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Another issue of concern raised in many submissions is the potential impact of increased salinity within the Lower Lakes upon aquatic biota By way of response Section 5 adds considerable detail regarding predicted salinity changes and the likely biotic response

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Section 6 briefly overviews issues raised in submissions which lie outside the scope of the Supplementary EIS In some cases ideas were contributed which are worthy of note

There is a suggestion about the importance of consulting with and recognising the Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

Another submission argues for having more than one scenario when drafting the EIS (not only d rought but a lso c limate c hange) and another c ontextua lised the c urrent p red ic ament of

the Coorong Lower Lakes and Murray Mouth in ideologies about unsustainable growth

A number of submissions outlined the current social and economic conditions of the Coorong Lower Lakes and Murray Mouth region indicating that there is considerable social and economic suffering attributable to drought and over-allocation of River water

Many submissions expressed discontent with over allocation of water resources and a significant majority expressed opposition to the temporary weir A minority supported the temporary weir and some indicated a preference for seawater flooding of the Lower Lakes (rather than a limited incursion)

There was almost no comment about water security issues for Adelaide and the majority of South Australian country towns

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part OnE Supplement to the Draft EIS

1

1 Introduction to the Supplementary Environmental Impact Statement (EIS)

Overview of Supplementary EIS structure

Rather than replacing the Draft Environmental Impact Statement (EIS) this Supplementary EIS d iscusses those issues raised in submissions Thus most of the tables and figures from the Draft EIS are not repeated Section 7 of the Supplementary EIS lists a range of text changes (corrections deletions additions and minor clarifications)

Note This Supplementary EIS needs to be read in conjunction with the Draft EIS for the proposed temporary weir near Pomanda Island There is no re-written version of the Draft EIS

Purpose

The purpose of this Supplementary EIS for the temporary weir near Pomanda Island is to address issues relating to Matters of National Environmental Significance (NES) that are within the scope of the guidelines arising from written submissions lodged during the period of public consultation for the Draft EIS

DEWHA issues

The Commonwealth Department of the Environment Water Heritage and the Arts (DEWHA) raised a number of issues with the South Australian Department for Environment and Heritage (DEH) Many of these issues are pertinent to the Supplementary EIS and a copy of the response to these issues is provided in Appendix 1

Supplementary EIS for the temporary weir near Pomanda Island -2shy

2 Temporary weir in the context of short and long-term actions in the Coorong Lower Lakes and Murray Mouth region

Submissions received and responses

A number of submissions suggested that the temporary weir was being considered in isolation and several suggested that there should be one encompassing environmental impact statement for actions being considered in the Coorong Lower Lakes and Murray Mouth (CLLMM)

The scale and complexity of the problems associated with lack of inflows to South Australia suggests that there must be a well coordinated set of solutions The South Australian Government has developed a multi-faceted strategy in response to the worsening impacts of low inflows to the Coorong Lower Lakes and River Murray region This involves development of a short-term strategy to protect the quality and access of major public water supplies to protect the local and regional environment from irreversible damage and to minimise adverse impacts on infrastructure and the regional community It also involves the development of a long-term management p lan Refer to tab le Summary of SA Government Projec ts in the Lower Lakes Coorong and Murray Mouth in Append ix 1 Question 3

Water security involves water quantity and quality to ensure a potable water supply to Adelaide and Regional South Australia The drought and anthropogenic1 uses have drastically reduced inflows to South Australia and water levels have dropped below Lock 1 (near Blanchetown) increasing salinity and exposing Acid Sulfate Soils (ASS) in the Lower Lakes The oxidation of ASS upon drying can result in acidic water and mobilised metals some of which are toxic to humans above certain concentrations The temporary weir aims to ensure adequate weir pool level for operation of the pumps supplying water to Adelaide and regional South Australia in addition to presenting a physical barrier to acidic andor saline water migrating upstream towards the pump stations from the Lower Lakes

The temporary weir is not considered the only solution to issues in this region The South Australian Government is writing a long-term p lan the initia l version entitled The Coorong Lower Lakes and Murray Mouth Directions for a healthy future This was released for pub lic comment during May 2009 Following a period of public consultation community feedback and with scientific input the final version of the long-term plan will be completed in October 2009 and submitted to the Australian Minister for the Environment Heritage and the Arts (MEHA) as required under the Murray Futures Funding Deed

In addition to the long-term plan the South Australian Government has had to take a number of emergency measures which while separate in their own right form part of a strategy of inter-connected short-term actions

The South Australian Government has referred five proposals to the MEHA for consideration under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) These are

A referral to establish a temporary weir near Pomanda Island (EPBC 20073484) which was determined to be a controlled action in July 2007 (the subject of this EIS process) The South Australian Government has stated that this temporary weir would only be constructed as a last resort and that the Government is continuing to pursue options for a freshwater solution The weir if approved and constructed would be a temporary weir aiming to protect the water supply of Adelaide and many country towns The draft EIS was released for public comment on 12 March 2009 This Supplementary EIS is prepared in response to public submissions that closed on 9 April 2009

A referral to upgrade the Pomanda Peninsula causeway to allow access to the temporary weir embankment site on Pomanda Island (EPBC 20084674) was referred to the MEHA on 23 December 2008 The Minister decided on 23 January 2009 that this p roposa l was not a c ontrolled ac tion

1 of relating to or resulting from the influence of human beings on nature

Supplementary EIS for the temporary weir near Pomanda Island -3shy

A referral to open the barrages that separate the Lower Lakes from the Coorong (EPBC 20084618) as a last resort should this prove necessary The aim of this proposal is to allow the controlled entry of a limited amount of seawater to maintain the water level in the Lower Lakes above the critical trigger level of acidification The proposal has been deemed a controlled action The final guidelines for the Content of a Draft Environmental Impact Statement were released on Friday 13 March 2009 (Note that The Murray-Darling Basin Ministerial Council approved a Real time management strategy to avoid acidification in the Lower Lakes (November 2008) involving the introduction of seawater through the Barrages when certain trigger points are reached The Council recognised the threat of acidification and approved this strategy essentially as a last resort)

A referral to construct a below ground pipeline that is capable of delivering 30 GL annually from the River Murray (at Jervois) to the Langhorne Creek and Currency Creek landowners was submitted on 18 February 2009 (EPBC 20094743) The pipeline will deliver irrigation water to communities and industries in the region that are currently reliant on the Lower Lakes for their water supplies This was assessed as not being a controlled action if undertaken in a particular manner and completion is scheduled for late 2009

An emergency first response referral to mitigate the multiple adverse impacts of Acid Sulfate Soil exposure in the Goolwa channel and its tributaries (Finniss River and Currency Creek) was submitted on 6 April 2009 (EPBC Reference No 20094833) This involves the construction (1) a temporary environmental flow regulator within the Goolwa Channel near Clayton (2) a temporary low-level regulator in the mouth of the Finniss River (3) a temporary low-level regulator in the mouth of Currency Creek The referral also involves pumping water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel This was assessed as not being a controlled action if undertaken in a particular manner

If more fresh water could be secured to flow into South Australia and Acid Sulfate Soil managed to mitigate impacts on water quality then the temporary weir would not be needed

Supplementary EIS for the temporary weir near Pomanda Island -4shy

3 Supplementary comment on temporary weir design and related components such as sourcing of raw materials and the criteria for the decommissioning of the weir

Submissions received and responses

Submissions discussed in this section generally relate to the content contained in the Draft EIS Chapter 5 titled Proposed Works to be Undertaken The major sections of that Chapter include weir location design parameters and time constraints construction environmental constraints and site selection alternative design options operation decommissioning and removal

Written comment received on Chapter 5 from the public and government agency respondents raised a wide range of issues A gap relating to the temporary weir and the effect of flood was identified and there was a significant cluster of submissions related to triggers for removal or decommissioning the temporary weir

Other submissions relate to Phytophthora at the temporary weir construction site the causeway approach to the temporary weir and the environmental impacts of temporary weir Written comment was made about the temporary weir site weir materials weir construction the weir crest and the apparent lack of Environmental Management Plans Relocating pumps thus avoiding weir construction was the subject of one submission as was the idea of a virtual weir

Murray-Darling Basin Authority submission

A submission from the Murray-Darling Basin Authority (MDBA) stated that approval for the construction of the temporary weir was required under clause 49 50 and 63 of the Murray-Darling Basin Agreement and detailed exactly what was required as part of the approval process The South Australian Government subsequently wrote to MDBA (15 May 2009) seeking approval for the construction of the temporary weir

The MDBA submission did not provide comment on Matters of National Environmental Significance in response to the EPBC Act process However many of the details requested are relevant to the temporary weir

The MDBA sought details on

Quantifiable triggers for removal

The time required to remove the temporary weir

The method of removal if a flood is travelling down the river when the level of Lake Alexandrina is low

The effect of increased salinity levels

The effect of the potential increase in heavy metals and

The effect of an increased sediment rate of acid production around Pomanda Island

On 30 June 2009 the MDBA approved plans for the proposed weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

The time required to remove the temporary weir

Refer to discussion on floods below

Floods

The MDBA submission has requested information about the removal of a temporary weir during a flood

Response

Given the exceptionally low storage levels in the Murray-Darling Basin system it would take considerable rain over a prolonged period of time and throughout a significant proportion of the Basin to generate a flood of sufficient flow resulting in all the decommissioning triggers

Supplementary EIS for the temporary weir near Pomanda Island -5shy

specified in section 58 the draft EIS being met Should a flood event signal the achievement of the weir decommissioning triggers the decommissioning and removal would only proceed after the flood has passed

Nevertheless advice has been sought from relevant authorities regarding both the specific level of rainfall necessary to create flood conditions in the Murray-Darling Basin catchments and the lead time available to remove the temporary weir in the unlikely event of a flood

Any significant flood moving down the river is most likely to have originated in the upper reaches of the river system and therefore can be expected to take up to six weeks to reach the location of the temporary weir During this time an assessment will be possible as to the appropriate method of management of the structure of the temporary weir

The temporary weir contains a spillway which is designed to pass 15 GL a day with a minimal rise in the upper weir pool level This flow rate was given by the MDBA as a nominal upper flow limit for normal river management and represents a 15 fold increase from the current flow past Wellington of approximate 1 GL per day A design for higher flood events was not included in the draft EIS due to the expected very low probability of occurrence plus the expectation that if flood event were occurring then the river system would have recovered and the temporary weir would not be required

The impact of flood flows over the temporary weir are being reviewed and initial indications are that flows much greater than 50GL per day could be passed without the upper weir pool level rising above the normal full supply level (FSL) of 075m AHD

In the unlikely event of a significant flood two reactions are available Firstly the flood could be allowed to pass over the temporary weir or secondly a breach in the temporary weir could be made to assist passage of the additional flow

The choice of the best option depends on the flood flow size the water level in Lake Alexander and the degree to which it could be flushed by the flood and the likelihood that the temporary weir will still be required after the flood (ie whether the conditions for weir removal have been met)

If the temporary weir is required after the flood then breaching the weir is unlikely to be a preferred option If the flood is allowed to pass over the temporary weir the likelihood of significant damage will depend on both the size of the flood flow and the downstream water level It is expected that flood damage should be low due to the width of the spillway (This is still to be confirmed by additional design analysis)

In a worst case situation a sufficiently large breach in the temporary weir could be done in the available time The method of removal remains the same however the work method will need to control all risks associated with different upstream and downstream water levels that may exist

The South Australian Government will work with the MDBA to develop a weir flood management plan Given the current exceptionally low water levels throughout the Murray-Darling Basin system it would take considerable rain over a prolonged period and over a significant proportion of the Basin to generate a flood of sufficient flow to require removal of the temporary weir The low water levels in storages and the River system also provide the opportunity to regulate a large percentage of high flows

Phytophthora at the temporary weir construction site

One submission claimed that impacts of weeds and pests such as Phytophthora cinnamomi were omitted and that therefore the weir construction could potentially have a significant environmental impact

Response

The Draft EIS (chapter 15) provides details on the environmental management framework for the temporary weir including Environmental Management Plan (EMP) to ensure management measures are in place to avoid mitigate monitor and control the potential impacts on matters of NES during the construction operation and decommissioning of the temporary weir

Supplementary EIS for the temporary weir near Pomanda Island -6shy

Once a contractor has been selected the contractor is expected to manage the temporary weir project in accordance with best practice mitigation measures to effectively reduce the environmental risks and avoid adverse impacts associated with site level impacts during the construction operation and decommissioning of the temporary weir

It is recognised that weeds and pests if not managed appropriately can present a long-term threat and impact on the native plant communities in the area

Consequently weed and pest management in general and the specific management of Phytophthora a re a c ritic a l element of the c ontrac tor s Environmenta l Management Plan (EMP) Selection criteria for contractors also include specific environmental compliance and best practice evidence

As part of this project detailed weed assessments will be conducted as part of the risk assessment in the Construction Environmental Management Plan (CEMP) via desktop studies (especially for Phytophthora) weed surveys and expert advice Project-specific mitigation measures are then included in the EMP and a specific (during and post-construction) weed management plan Specific measures may include but are not limited to

Avoidance of weed-infested areas for land-based construction activities (for example by relocating stockpile areas etc)

Construction activities restricted to approve construction corridors only

Weed management plan endorsed by the South Australian Murray-Darling Basin Natural Resource Management Board (SA MDB NRMB)

Wash-bay areas established according to weed management plan

Record kept of hygiene measures conducted prior to entering the site (for example plant trucks materials working clothes shoes boots etc)

Phytophthora cinnamomi distribution is contained to the wetter areas of the state It is highly unlikely that this fungus would be spread at the temporary weir site

For more information see httpwwwenvironmentsagovaubiodiversityplantsshyanimalsdiebackhtml

Weir Causeway

A submission claimed that as the level of the causeway would be higher than the temporary weir this would form a barrier and create new flow patterns

Response

There is no evidence that a flow path across the causeway exists with normal water level conditions The existing causeway and beach area on the western side contain no wash ways On the contrary there is evidence that only minor amounts of water in storm-driven waves have moved over the causeway

Weir Site

A submission from the SA MDB NRMB requests a better explanation of why this site is the preferred site

Response

This is explained through extensive studies summarised in Section 56 of the Draft EIS which concluded that no other feasible site exists down stream from Murray Bridge

Weir Construction and Environmental Management Plans

Some submissions criticised the lack of an EMP

Response

Specific mitigation measures will be developed in consultation with State environmental agencies to ensure that they are consistent with the relevant Acts and regulations (for example the Environment Protection Act 1993 (SA) the Natural Resources Management Act 2004 (SA))

Supplementary EIS for the temporary weir near Pomanda Island -7shy

The EMP is reviewed and endorsed by a number of agencies before any works can be carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) for the overarching EMP SA Water Corporation and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Weir Materials

One submission states that information about sourcing of material is not complete and raises doubts as to whether materials can be transported Will pollutants be introduced to the water

Response

The draft EIS (section 542) addressed the first two issues raised

The issue of pollutants to the Lake from the embankment material is covered in the requirements for an EMP and CEMP in the Draft EIS

One submission claims that mud waving will create a structure fault where the weir embankment fingers join It also claims that the structure will slip

The possible impact of mud waves on the structure is recognised and is one of the key elements in the c ontrac tor s c onstruc tion method The stab ility of the struc ture is a norma l design issue that is mitigated by using a design review process

The EIS provides all the available knowledge on material sources As the contracting method leaves the material source decisions to the contractor no further information will be available until a contract is awarded

Weir Crest

The MDBA requires confirmation that the temporary weir crest can resist erosion from flow

Response

Specific details for the temporary weir crest design were incorporated in an application sent to MDBA on 15 May 2009 This is not related to the draft EIS or the Supplementary EIS

Pumping

One submission claimed that the option of relocating the pump stations would involve a short timeframe and thus avoid the environmental impacts of constructing a temporary weir

Response

The option of re-locating pump stations is stated in the Draft EIS to involve a risk of continuity of supply The submission has also not recognised that the timeframe for moving a pump station individually upstream of Lock 1 (near Blanchetown) is similar to building a larger pump station upstream of Lock 1 and laying the required connecting pipeline Both options would require feasibility studies and engineering designs as well as the necessary State and Commonwealth approvals and assessments Should an EIS be required for these options it is envisaged that the projects would not be in place to ensure a potable water supply to Adelaide and Regional South Australia within the next two years

Permanent Weir

One submission claimed that impacts of permanent weirs are severe and therefore another weir should not be built on the River Murray

Supplementary EIS for the temporary weir near Pomanda Island -8shy

Response

The impacts have been examined and reported (See for example Draft EIS Section 831) taking into account the temporary nature of the proposed weir The Draft EIS concludes that the impacts of not building the temporary weir when critical trigger points are reached are more signific ant as muc h of South Austra lia s wa ter sec urity is threa tened

Triggers for Removal

A number of submissions claim that triggers are inappropriate because they specify conditions that have not prevailed for more than a decade and that they lack detail and are unlikely to occur within the next decade References are made to water levels in Murray-Darling Basin storages salinity in Lake Alexandrina and general water quality risks in Lake Alexandrina

Response

Triggers

In relation to the decommissioning triggers for removal of the temporary weir the South Australian Government considers that the four criteria as agreed by the Water Security Council and accepted by the MDBA and stated in section 58 of the Draft EIS remain appropriate

Removal of the temporary weir is highly dependant on the seasonal conditions as well as decisions by Murray-Darling Basin Ministerial Council on water sharing water recovery and water allocation policies The South Australian Government has selected a nominal 3 year life for the temporary weir as indicative

Stages

The graph below is available on the MDBA website and shows that storage levels dropped below the long-term average in 2002 and have not exceeded this since that time The time to recover storages to these levels is primarily dependent on inflows and while based on historical data it might take a series of years to recover to average inflows equally it could be much quicker in a single year with high inflow For this reason the life of the temporary weir has been referred to as nominally 3 years

Supplementary EIS for the temporary weir near Pomanda Island -9shy

Salinity in Lake Alexandrina

Similarly the graph below shows historical salinity levels in Lake Alexandrina where the salinity did not increase above 3000 EC (Electrical Conductivity) until 200708 This graph shows salinity averaged at four sites - A4261157 (Milang) A4261158 (West Pomanda Point) A4261133 (Beacon 90) and A4261156 (West Point McLeay)

Water quality in the Lakes is unlikely to improve until additional freshwater flows down the river to either dilute the Lake water or flush it to the sea The third trigger has been purposely expressed as water quality rather than salinity to allow for possible acidification impacts and associated mitigation measures

As fresh water flows eventually increase the salinity level in Lake Alexandrina will initially fall due to dilution and the Lake will fill with freshwater Salinity levels will then fall further as lake water is flushed to the Coorong and the ocean The extent of flushing required to reach the trigger level is dependent on how long the higher flows persist

Salinity measuring locations

One submission suggests that the target of 3000 EC lacks detail on where it is to be measured Another submission suggests that the target on storages should be replaced with a target on-flow to South Australia

Response

The 3000 EC trigger is intended to be a general salinity measurement in Lake Alexandrina Specifying a single measurement location is not appropriate because there can be areas of localised higher salinity and some of the sites where salinity has been measured over many years are now out of the water The intent is to take a rolling 7 day average over the four representative existing sites (Milang Mulgundawa Poltallock and Raukkan) Data from these sites have been collected for many years and existing protocols will be continued As part of these protocols the sampling sites have moved to accommodate the shift in shoreline

The flow to South Australia comprises a combination of ordered water (and South Australias entitlement flow of 1850 GL is in this category) and unregulated flow which is water that cannot be captured in Murray-Darling Basin (MDB) storages normally due to rainfall in the

Supplementary EIS for the temporary weir near Pomanda Island -10shy

lower parts of the catchment It is therefore possible to get high flows in any single year but the MDB storages could still be empty at the end of the year

It is only when the Hume and Dartmouth reservoirs have returned to normal operating levels (and other decommissioning triggers specified in section 58 the draft EIS have been met) that the South Australian Government can have confidence that the temporary weir would no longer be required The MDBA state that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

Decommissioning

A respondent questions how a structure designed for 3 years can be reconciled with a possible continuing drought and the removal triggers

Response

The temporary weir is designed to a nominal three year structural life and is expected to be removed when current drought conditions abate sufficiently with confidence that the improved River Murray flows are sustainable Detailed information on the triggers for decommissioning are specified in section 58 the draft EIS

As indicated in chapter 4 of the draft EIS the Murray-Darling Basin is six years into the worst drought on record It has led to low water River Murray flows over the border No-one knows when the drought is expected to end or how much water is expected to become available so it is necessary to plan for the worst scenario

Modelling

A number of submissions raised concerns about modelling

Water level forecasts may be incorrect due to assumptions about net evaporation There were questions about whether drought is the fundamental cause of the problem considering recent rainfall history in the Murray-Darling Basin

Modelling is only carried out for a period of 3 years despite the unknown length of the proposed operation

That modelling is only reported for an allocation to South Australia of 896 GL

That there is a lack of modelling results for temperature turbidity and acidification

That the temporary weir will cut off low water inflows

That water level modelling is flawed and underestimates local winter inflows

That the temporary weir will stop salts moving into Lake Alexandrina and these salts will be forced back into the River channel and

Further modelling particularly related to a virtual weir was sought

Response

The following graph (Department of Water Land and Biodiversity Conservation 020709) shows the drop in water levels in Lake Alexandrina over recent years The falls are quite uniform and the projections are consistent with recent history The models used have been accurate in projecting water levels to date

Supplementary EIS for the temporary weir near Pomanda Island -11shy

_

Lake Alexandrina Level

-26

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-14

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0100 0600 1100 0401 0901 0202 0702 1202 0503 1003 0304 0804 0105 0605 1105 0406 0906 0207 0707 1207 0508 1008 0309 0809 0110 0610

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rina

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er L

evel

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Modelling projections have only been made for a period of 3 years because of the low probability of a continued period of extended drought and increasing uncertainty about future management responses Modelling using 896 GL flow over the South Australian border was used as it reflected the water sharing agreement for South Australia This figure is considered the worst case flow into South Australia

Flows to the Lower Lakes are currently determined by the minimum River flow needed to ensure that the maximum salinity at Murray Bridge remains within potable limits The temporary weir will not cut off flows to the Lower Lakes and once the pool behind the temporary weir is filled water will flow over the temporary weir into Lake Alexandrina at the rate of at least 350GL per annum

Modelling does not support the contention that the temporary weir will not prevent saline water from moving upstream into the River channel This is fully described in the Draft EIS

The Draft EIS acknowledged limitations with the model used to predict the movement of saline water in the Lakes but also notes that it provides the best information available and was based on numerous model runs (Refer also to section 443 of the Draft EIS) It is considered that running the models for a broader range of scenarios would not substantially alter the advice on impacts of the temporary weir The salinity model cannot be calibrated to a high level of certainty simply because there is no historic reference The current conditions are outside the bounds of normal lake operation

An adaptive approach will be required for managing the filling process for the pool upstream of the temporary weir to ensure that there is an appropriate balance between the various competing interests This will need to take into account issues such as technical constraints related to the construction program potential environmental impacts on Lake Alexandrina during the period of no flow or low flow to the lake flow requirements for the proposed fishway through the temporary weir and possible impacts on wetlands reclaimed swamp areas levee banks and the river bank as the water level rises upstream of the temporary weir Some of these issues will only become clear as the water level rises and the filling process will need to be adjusted in response to these impacts

It is apparent from the early contractor engagement process that the initial construction method adopted for the modelling described in the draft EIS will be slightly modified due to

Supplementary EIS for the temporary weir near Pomanda Island -12shy

technical constraints In addition a fishway will be provided through the temporary structure As a result of these factors the basic refilling process has been modified from that proposed at the time the draft EIS was published

The current proposal (assuming the inclusion of a fishway through the temporary weir) is to have a minimum dilution attraction flow of 200 MLday past the structure at all times during refilling An initial period of refill of some 2 to 3 weeks is proposed when level will be raised from -15m AHD to -12m AHD and the flow past the temporary weir would be limited to the 200 MLday This will be followed by a period of approximately 25 to 3 months when the level is held at -12m AHD and the passing flow will be approximately 1500 MLday Finally there will be a period of approximately 2 to 25 months as the temporary weir is refilled from -12m AHD to the nominal pool level of +01m AHD and the passing flow will be limited to approximately 200 MLday

However it is proposed that this refill strategy will be modified in response to any impacts arising from the refilling process as identified above

Virtual Weir

A submission suggests models need to be used with caution and asks whether models have been run at lower levels and with salinities less than seawater and what flow past Wellington would be needed to make a virtual weir work

Response

It is agreed that the model used to predict the movement of saline water from Lake Alexandrina to the River channel needs to be used with caution There is limited data with which to calibrate the model

The value of the model is to better understand the mechanisms of how saline water moves upstream and how it is dissipated This information is included in section 443 of the Draft EIS

The model indicates that current flow rates are too low to ensure mixing of fresh and saline water and prevent a saline layer making its way up the River Murray The modelling indicates that flows would need to increase by a factor of 5-10 times before this issue could be resolved As indicated in the draft EIS if this volume of water was available then no saline water would enter the river channel

Since the release of the Draft EIS the MDBA engaged WBM-BMT to undertake further hydrodynamic modelling to investigate the potential for and risks associated with a virtual weir Modelling will incorporate several months of new data and involves a number of new scenarios in respect of water levels lake salinities and wind strength direction and duration

It is anticipated that the outcome of this work will be available progressively during July and August 2009 and will further inform the technical feasibility of implementing a virtual weir

Supplementary EIS for the temporary weir near Pomanda Island -13shy

4 Supplementary comment on expected impacts of the temporary weir on soils and water

Introduction

The draft EIS involved discussion of soil and water quality impacts within many sections of most chapters The chapters specifically detailing soil and water quality impacts were

Chapter 8 Potential impacts of the proposed temporary weir

Chapter 10 Changes in water levels and salinity

Chapter 11 Soil and Water quality impacts

A significant number of submissions and government responses to the draft EIS included comments related to soil and water quality Government agencies such as the Environment Protection Authority (EPA) the Department of Water Land and Biodiversity Conservation (DWLBC) MDBA and the SA MDB NRMB have suggested changes in the light of new data or further information DEWHA has requested further clarification

Submissions received and responses

The major points raised by the submissions are detailed below along with responses involving a discussion and conclusion in regard to the points raised

Acid Sulfate Soils (ASS)

Submissions raised the following questions and concerns

Who is completing monitoring for alkalinity in Lake Alexandrina and where is monitoring data being stored Can the public or other agencies access this data

The lack of information about rates of acidification and potential release of metals (and metalloids) the mobilisation and flushing of acidity and associated contaminants (for example metals nutrients) to the water and the impacts of ASS and acidification on the ecology and ecological processes for example risks to species

The need to make more use of the considerable experience from elsewhere when dealing with ASS

The need to study acidity risks and environmental impacts associated with rewetting of wetlands upstream of the temporary weir

The need for information and data on hydraulics relating to flow cessation into Lake Alexandrina and sea water introduction and acidification thresholds

Not enough information on immediate and long-term implications of building the temporary weir (for example medium to low confidence in modelling of tipping point for acidification)

The need for additional modelling of acid and metal release

The need to address remedial actions necessary in the Lakes because of the accelerated decline in water level

Quantification of the risk of acid mobilisation upon re-wetting of River channel wetlands upstream of the weir site in general more consideration is needed to be given to these water bodies and

What are the mitigation measures planned if alkalinity levels reach 25mgL CaCO3

Response

As indicated below independent advice from leading international and Australian ASS scientists has been sought in order to increase knowledge on sulfide oxidation rates generation of contaminants (for example metals and nutrients) transport mechanisms and neutralisation dynamics

In 2008 the South Australian Government commissioned several reports into acidity metal mobilisation and water quality risks for the River Murray and Lower Lakes and it is further

Supplementary EIS for the temporary weir near Pomanda Island -14shy

prioritising investigations to assist with ASS mitigation and management options such as bioremediation

Such investigations can take from several months to years but once more information is available the models underpinning acidity and metal mobilisation impacts for this region can be better refined

Since August 2008 the SA MDB NRMB has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (for example sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (Report 1 March 2009 Available May 2009 wwwepasagovau) The EPA also compiles the raw data in a spreadsheet available to South Australian Government agencies

Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on the potential impact refilling wetlands will have on water quality of the Main River channel and the ecological impact of further acidification of wetlands

The

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes

Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the Murray-Darling Basin Authority Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from a DEH project identifying acidification remediation options for the Lower Lakes

Construction of regulating structures and other on-ground works for remediation at priority wetlands

Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRMB is managing the Wetlands between Loc k 1 and Welling ton Ac id Sulfa te Soils Management Projec t with a steering c ommittee of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRMB DEH DWLBC MDBA SA Water Corporation EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of +01m AHD An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of the wetlands will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island for example wetlands providing important aquatic refuges

Conclusion

In conclusion it is agreed that the impact to River channel wetlands is an important issue that needs to be managed This is true irrespective of whether a temporary weir is constructed or

Supplementary EIS for the temporary weir near Pomanda Island -15shy

not Measures are already in place to minimise the risk to water quality in the River channel Refilling these wetlands will provide important aquatic refuges

The submissions on acid acidity and ASS support the need for continued support of ASS field investigations and modelling so that key information gaps can be addressed as quickly as possible and be fed back into the ongoing planning and measures undertaken

In the meantime it is noted that there is extensive experience in dealing with ASS elsewhere Leading international and Australian ASS scientists with industry specialists have been contacted to provide independent advice and an ASS risk workshop involving many of Austra lia s soil and hyd rology sc ientists was rec ently held for the Lower Lakes If a lka linity levels reach 25mgL CaCO3L immediate mitigation measures such as limestone slurry dosing of the water in affected areas are expected to be undertaken

Recent information on ASS bioremediation and dust issues for the Coorong Lower Lakes and Murray Mouth reg ion is ava ilab le from the South Austra lian Government s Environment web page httpwwwenvironmentsagovaucllmmfaqs-acid-sulfate-soilshtml

Water quality

Wind seiche

There were a number of submissions in regard to wind seiche impacting on water quality at the pump intakes Concerns included

Some suggested that the remaining area of the Lake above the temporary weir (weir pool) would still be large enough to allow significant wind seiching to occur Due to low inflows and a large weir pool surface area salinity would increase in the weir pool and these seiching events would still have the capacity to drive the saline water within the weir pool upstream to the pump intakes

It was suggested that the temporary weir will effectively impede if not completely stop the wind seiche effect across Lake Alexandrina and into the River thus stopping the mixing of the water in the River and substantially increasing the risk of algal blooms

It was suggested that the impact of wind seiche in the weir pool is not fully understood and

Concern was expressed about cutting off seiche events into the lower Murray providing nutrients and oxygenated water from Lake Alexandrina Seiching events also allow transport of pollutants to the Murray Mouth and may build up in the weir pool when there are inadequate seiche effects

Response

Wind seiche is believed to be an important part of the ecosystem within the lower reaches of the River Murray It is a transport mechanism for both up and downstream transporting oxygenated nutrient rich water from Lake Alexandrina into the lower reaches of the River and allowing flushing from the channel of excess nutrients and salt Additionally it provides variability in water levels important for the life cycles and habitat of some native species

If the River system and Lower Lakes were experiencing normal flows and water levels then the temporary weir would reduce the effects of seiche events At the proposed trigger level to install the temporary weir (-15 m AHD) the connection of Lake Alexandrina to the River channel will be minimal reducing the effects of wind seiche As indicated in section 443 of the draft EIS this is partly due to the natural bathymetry of the river channel where it connects to Lake Alexandrina

Modellers have incorporated the effects of winds seiche including those modelling scenarios with a temporary weir in place There are also real world examples The draft EIS made a comparison between seiche effects above and below Lock 1 and noted that the effects were less pronounced above the lock Additionally BMT-WBM modelling indicates that by December 2010 under ongoing low flow conditions both scenarios with and without a temporary weir show a marked drop in the effects of wind seiche and there is little difference between the two scenarios

The draft EIS also stated that the effects of wind seiching are expected to be reduced by approximately 50 with the temporary weir This is because the temporary weir will decrease

Supplementary EIS for the temporary weir near Pomanda Island -16shy

the effects of wind seiche within the River channel by disconnecting it from Lake Alexandrina which supplies a large amount of momentum for water seiching up the lower River Murray

Any water from Lake Alexandrina that did manage to travel up channel will also be highly saline acidic and have high concentrations of metals Currently water does not flow over the barrages and out the Murray Mouth and would not at the trigger level of -15m AHD The shoreline of much of Lake Alexandrina would in fact be kilometres north of the barrages by this stage

With a temporary weir in place flows over Lock 1 will continue supplying a constant source of freshwater in the weir pool helping to keep salinity low within that pool Additionally the temporary weir will prevent the transport of saline acidic water from Lake Alexandrina into the River channel These effects along with the reduction in wind seiche will ensure salinity and contaminants at the pump intakes are minimised However the reduction is unlikely to remove all wind seiche effects creating enough movement to reduce the risk of algal blooms and oxygenate the water

Conclusion

The effects of the temporary weir need to be considered in the context of what the situation will be when it is proposed that the temporary weir will be installed that is at a water level of -15 m AHD in Lake Alexandrina While it is recognised that the effects of wind seiche will be reduced the temporary weir also prevents seiche events from driving water of extremely poor quality from Lake Alexandrina into the River channel towards the pump intakes Some effects such as blue-green algae formation and potential reduction in oxygen levels upstream of the weir pool (due to reduced flow velocities over the temporary weir itself) whilst undesirable can be managed by the treatment plant whereas other poor water quality (such as metal releases due to acid sulphate soil effects potentially created in the Lakes) would be more difficult to treat Oxygen levels may fall within the weir pool due to the reduction in seiche events and a lack of oxygenated water from Lake Alexandrina however some seiching and wind action will still occur within the wide weir pool reducing the likelihood of anoxic conditions from occurring

Impacts upon Coorong and Lake Albert

A number of submissions raised questions about the impacts on the Coorong and Lake Albert from the temporary weir

Response

These submissions are noted however the proponent contends that the Draft EIS contains sufficient evidence that conditions in Lake Albert and the Coorong will be unaffected by construction of the temporary weir The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170 mm only occurs during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD (including Lake Albert and the Coorong) is not a direct impact of the temporary weir It is therefore beyond the scope of the draft EIS

The draft EIS considered that impacts of the temporary weir on the Coorong and Lake Albert were not considered significant This is because at the time of the weir closure the surface water elevation of Lake Alexandrina will be below sea level preventing any movement of water to Lake Albert and through the barrages to the Coorong The introduction of a temporary weir will not change this situation

Since May 2008 water levels in Lake Albert have been maintained artificially at an approximate height of - 05 m AHD by pumping from Lake Alexandrina Continued low River Murray flows have made this practice unsustainable and funding for pumping ceased on 30 June 2009 as noted by the MDB Ministerial Council on 12 June 2009 The cessation of pumping in June 2009 will lead to a gradual lowering of the level of Lake Albert The introduction of a temporary weir will not change this situation

Supplementary EIS for the temporary weir near Pomanda Island -17shy

Conclusion

At the trigger level for the construction of the temporary weir the Coorong and Lake Albert waters will be disconnected from Lake Alexandrina so changes to soil and water quality are not significantly impacted on by the temporary weir

Dredging of Murray Mouth

The issue of whether the dredge at the mouth of the Murray will remain there if the temporary weir is put in was raised

Response

The Murray Mouth is the only site where water contaminants such as silt salt and nutrients can exit the Murray-Darling Basin There has been no significant release of water from the Lower Lakes via the barrages since November 2005 and connection at the Murray Mouth has been dependent on dredging

The dredging program should only be regarded as a temporary measure Increased environmenta l flows a re the Murray s only solution in the long term if we are to keep the mouth open and maintain the health of the Coorong

Water quality impacts near Narrung Narrows

Submissions suggested that conclusions on water quality impacts from the construction of a blocking bank at the Narrung Narrows need revising in the light of additional monitoring data

Response

The construction of the blocking bank took 16 days to closure after commencing on 16 April 2008 Water quality parameters were monitored before during and after construction but revealed little impact with fluctuating turbidity levels likely due to the effects of wind as shown historically in figure 11-5 of the draft EIS There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid once water levels rose Alkalinity concentrations showed little change during and after the construction

Turbidity

The EPA has undertaken monitoring at locations around Lakes Alexandrina and Albert since the commencement of the construction of the Narrung Narrows blocking bank EPA water quality monitoring reports p repared for the b loc king bank p rojec t s steering c ommittee noted tha t some localised turbidity impacts were observed but this did not translate into widespread impacts in Lake Albert Figure 11-7 (below) shows turbidity readings for five locations and demonstrates that there is little correlation between the installation of the blocking bank the subsequent pumping and turbidity in both Lakes The variability in turbidity is principally related to climatic conditions at the Lakes For example the Lakes are shallow and the area experiences wind events which regularly create turbulence which is able to mobilise sediments thus increasing turbidity The spike at Meningie in December 2008 is not likely to be related to the blocking bank as it is nearly six months after construction

Supplementary EIS for the temporary weir near Pomanda Island -18shy

Turbidity at Monitoring Stations near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - Near narrows 3km NE of Reedy point

Lake Albert - Near water level gauge 11km N of Meningie Lake Alexandrina Poltalloch

Lake Alexandrina - Beacon 90

Figure 11-7 Turbidity (NTU) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Acidity

Water column pH has remained relatively constant with readings predominantly between 86 and 89 (Figure 11-8 of the Draft EIS) There was a pH drop in Lake Albert at the time of completion of the blocking bank with the closest monitoring point recording a pH of 79 These lows were recovered to normal levels within the month after pumping commenced

These results show there may be some localised effects to pH through the exposure of sulfidic sediment However the buffering capacity of the water and the quantity of exposed sulfidic sediment reduce the risk to the effects of pH to the Lake as a whole

pH at Monitoring Stations near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-8 pH at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Supplementary EIS for the temporary weir near Pomanda Island -19shy

Alkalinity

All stations with the exception of the Lake Albert station closest to the blocking bank have had relatively constant alkalinity concentrations The largest decrease in pH did not correlate with a reduction in alkalinity however later reductions in pH in August and November 2008 and January 2009 did Due to the continued exposure of sulfidic sediments over this time it is unlikely the effects are due to the blocking bank construction

Alkalinity at Monitoring Stations Near the Narrung Narrows

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Lake Albert - 1km offshore Meningie jetty Lake Albert - near narrows 3km NE of Reedy point

Lake Albert - near water level gauge 11km N of Meningie Lake Alexandrina - Beacon 90

Lake Alexandrina Poltalloch

Figure 11-9 Alkalinity (mgL) at monitoring stations near the Narrung Narrows within both Lakes Alexandrina and Albert during and following the construction of a blocking bank

Conclusion

Water quality parameters were monitored before during and after the construction of the Narrung Narrows blocking bank and monitoring revealed little impact with fluctuating turbidity levels likely due to the effects of wind There was a slight drop in pH levels for Lake Albert in the month following completion of the blocking bank however recovery was rapid Alkalinity concentrations showed little change during and after the construction

Algal blooms

There were many concerns about possible increases in algal blooms within the weir pool through reduction in flows and nutrient fluxes impacting on water quality

Response

The risk of algal blooms in the River is influenced by a number of interacting factors including weather conditions flow and turbulence and nutrient supply It is therefore not possible to precisely predict the extent and intensity of blooms However it is generally accepted that blue-green algae are favoured by waters with reduced turbulence reduced turbidity and increased nutrients A change to turbulence only increases the risk if sufficient nutrients are present to support the bloom The reduced flow in the River as a result of the drought will increase the likelihood of algal blooms The temporary weir will also reduce the flow and turbulence during the weir pool filling period and may therefore also tend to increase the risk of algal blooms Precise prediction of the frequency and intensity of algal blooms is not possible but it could be expected to be similar to the permanent structures upstream

Supplementary EIS for the temporary weir near Pomanda Island -20shy

There is a range of information mainly from studies overseas that lakes and rivers that experience frequent andor prolonged algal blooms display an array of ecosystem properties that may have impacts on water quality biological communities and ecosystem services

Some impacts of algal blooms may be direct including possible effects of toxins on fish invertebrates and other aquatic fauna or indirect including a reduction of submerged plants when plankton biomass becomes very high and changes in fish community structure due to hypolimnetic anoxia In lakes with dense blooms of blue-green algae accumulation of organic material in lake sediments and increased bacterial activity also may lead to anoxic conditions that alter the structure of benthic macro invertebrates Despite numerous case studies and a vast literature on species specific responses community level effects of blue-green algal blooms are not well understood

It must be noted however that these potential changes are associated with highly eutrophic environments that have frequent and persistent and often massive algal blooms These conditions are relatively extreme and unlikely to be encountered for extended periods in the River provided projected flows are maintained

The lower River Murray and other surface water storages within the Murray-Darling Basin regularly experience minor algal blooms due to seasonal stratification and periods of low flow These blooms have not been associated with the types of potential environmental effects that occur in the degraded systems with persistent blooms A case in point is the recent short-lived but highly visible bloom in the River Murray in NSWVictoria downstream of Hume Dam

It is not possible to make a precise prediction of the impact of the temporary weir on the risk of blue-green algal blooms However it is expected that the impacts will not be significant and will be similar to those in the permanent structures up stream

The water treatment plants in South Australia all have the capacity to remove algal cells and the toxins taste and odours that they produce and are able to mitigate any detrimental effects of algal blooms on water supplies

Summary of water quality impacts

One submission highlighted that the summary of water quality impacts in Chapter 11 of the draft EIS did not include all of the impacts to water quality particularly salinity

Response

The construction of the blocking bank at the Narrung Narrows was examined to determine what impacts on water quality if any were identified during and after construction of the blocking bank Using the blocking bank as an example it is expected that the construction of a temporary weir near Pomanda Island may have impacts on water quality both up and down stream

Water quality issues which may result within the weir pool include a reduction in flow velocity an increase in temperature and evaporation and a decrease in dissolved oxygen levels and in the effectiveness of wind seiche events to provide mixing and transport of salt nutrient and contaminants This may lead to temperature and salinity stratification and an increase in blue-green algal blooms in the weir pool It is expected that these impacts will be similar to those relating to the permanent structures that already exist in the River Murray up stream from Lock 1 and that the potential environmental risks will therefore not be significant

The construction of the temporary weir itself will create localised sediment waves as material placed in the River channel displaces sediment This sediment wave is likely to contain sulfidic materials that will oxidise and form acid Based on the experience of the Narrung Narrows blocking bank the provision of mitigation and management measures as outlined in the CEMP is adequate It can be expected that there will be localised impacts to turbidity pH and alkalinity but minimal effect at a distance

Once the weir construction is complete there will be a reduction in inflows to Lake Alexandrina while the weir pool is filled (see page 13 -14) Modelling indicates that during this time there will be a temporary increase in salinity in the waters of Lake Alexandrina However it has indicated that in the long-term the d ifferenc es in sa linity between the weir and no weir op tion under continued low inflows become insignificant

Supplementary EIS for the temporary weir near Pomanda Island -21shy

The reduction of flow during the filling of the weir pool (see page 13-14) predicts the volume of water in the Lake such that a further 5200 ha of sulfidic soils are exposed in Lake Alexandrina under the worst case scenario This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage ASS will need to be implemented across the Lake in this case

When these impacts are compared to the conditions likely to be present when water levels reach triggers for the temporary weir to be installed at viz 15 m AHD it is likely that the impacts of the temporary weir on water quality in Lake Alexandrina will be an increase in salinity for up to 3 months and bringing forward a potentially rapid pH reduction in Lake Alexandrina by 2 to 3 months For a detailed discussion of likelihood of Lake Alexandrina acidifying during the no flow period refer to Appendix 1 Question 7

For a detailed discussion of reasons underlying the 25 to 3 month disconnect of Lake Alexandrina refer to Appendix 1 Question 9

Connectivity of Surface and Ground Waters

Surface Waters

A few submissions questioned what the tributaries of Lake Alexandrina were and when they would disconnect

One submission was received stating that the drop in water level predicted to occur as a result of building the temporary weir should not have been expressed as an average but as a range

Response

There are four tributaries from the Eastern Mount Lofty Ranges (EMLR) to Lake Alexandrina namely

Angas River

Bremer River

Currency Creek

Finniss River

The surface waters of these tributaries will be disconnected at -15m AHD from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into the Lake and were the first to disconnect at a water level between +01 m and + 03 m AHD The Angas and Bremer have been disconnected since 2007

At times of medium to high outflow from these tributaries there is likely to be some reconnection of surface water with or without the temporary weir

The South Australian Government commenced construction of a temporary environmental flow regulator at Clayton in June 2009 The Goolwa Channel (and Currency Creek and the Finniss River tributaries) will be disconnected from Lake Alexandrina during construction of this regulator (EPBC Reference No 20094833)

The figures in Chapter 10 of the draft EIS show a selection of graphs of predicted water level impacts of the temporary weir From these the greatest reduction in water level during the weir pool filling phase in the first year is shown to be approximately 210 mm near the tributaries (points 63 and 64 Figures 10-13 and 10-14)

Conclusion

All tributaries except the Goolwa Channel are now disconnected from Lake Alexandrina and will remain so with or without a temporary weir

The construction of an environmental low flow regulator at Clayton will disconnect Currency Creek and Finniss River from Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -22shy

Reconnection of surface water in Angas and Bremer Rivers with Lake Alexandrina is likely at times of medium to high outflow from these tributaries This situation is unlikely to change with the construction of the temporary weir

Groundwater

A few submissions questioned the detail on surface waters and groundwater interactions

Response

In terms of groundwater connection it is assumed that the sediments in the tributaries and Lake Alexandrina will have some hydration from groundwater even at water levels of less than -28 m AHD

During development of the EIS DWLBC hydrogeologists were consulted on whether the p red ic ted dec rease in Lake Alexandrina s water level of 210 mm near the tributa ries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the drought induced water level drop which has already occurred

Conclusion

Tributaries are likely to remain connected to Lake Alexandrina through groundwater at levels less than -28 m AHD and the 210 mm difference in water level induced by the construction of a temporary weir is unlikely to have a significant impact on groundwater flux

Supplementary EIS for the temporary weir near Pomanda Island -23shy

5 Supplementary comment on interactions of the proposed action with flora and fauna including Ramsar wetlands threatened species and migratory species in the context of low water levels

Introduction

Submissions discussed in this Section relate primarily to the content contained in the Draft EIS Chapter 6 (Environmental Processes and Interactions in the Coorong and Lower Lakes) Chapter 7 (Matters of National Environmental Significance) Chapter 8 (Potential Impacts of the Proposed Temporary Weir) Chapter 12 (Interactions With Ramsar Wetlands) Chapter 13 (Interactions with Threatened Species and Communities) and Chapter 14 (Interactions with Migratory Birds) with occasional reference to other chapters

The most significant impact mitigation measure introduced in response to submissions received is the incorporation of a fishway (fish passage) into the design of the temporary weir as outlined below The fishway will address the issue of fish migration between the Coorong Lower Lakes and Murray Mouth and the River Murray an issue which was raised by a significant number of public submissions and government agency respondents

Another issue of concern raised by many submissions and respondents is the potential impact of increased salinity within the Lower Lakes upon aquatic biota The following discussion adds considerable detail relating to predicted salinity changes and the likely biotic response endeavouring to provide greater breadth and clarity around this issue

A range of other concerns regarding potential impacts upon flora and fauna are also addressed in this section

Upstream impacts

Impacts of altered water regime in weir pool

Several submissions argued that conditions in the weir pool created upstream of the temporary weir would favour exotic species such as Common Carp and disadvantage native species including EPBC Act-listed species such as Murray Cod Such an impact would be contrary to the goa ls of the MDBA s Native Fish Stra tegy

There was also a concern that flora species such as the common reed cumbungi and willows (an introduced species) in the riparianlittoral zones might respond in a way that could impact on matters of NES

Response

aspec ts of the p roposed temporary weir tha t interac t with ray-finned fishes of NES (page 15-13) should be expanded to include The list of

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

The list of potential impacts of the temporary weir upon aquatic fauna (Section 15415 pages 15-24) should be expanded to include

Altered hydrology between the temporary weir and Lock 1 and

Increased abundance of exotic fish species (eg Common Carp Gambusia) between the temporary weir and Lock 1

Advice from the South Australian Research and Development Institute (SARDI) Aquatic Sciences is that mitigation of improved spawning conditions for Common Carp in the Pomanda Island weir pool is not practical due to the scale of the issue Similarly measures to promote spawning of Murray Cod in the weir pool are not practical The potential impacts of the temporary weir upon EPBC Act-listed fishes in the River Murray channel upstream of the

Supplementary EIS for the temporary weir near Pomanda Island -24shy

temporary weir due to altered hydrology and increased exotic fish abundance appear to be unavoidable

The following aspec ts of the temporary weir tha t interac t with ripa rian flora such as Phragmites (common reed) Typha (cumbungi) and willow (introduced species) in the upstream wetlands and consequent effects on matters of NES (fauna) should be taken into consideration

The vegetation type and distribution in the upstream wetlands is expected to change due to the change in water level from (historic) +05m AHD - +08m AHD to a new level of +01m AHD and reduced wind seiche noting that current water levels are substantially lower than this

The change to a shallower wetland regime is expected to favour Phragmites and Typha which are invasive

The impact of changed vegetation pattern on matters of NES (EPBC-listed fish and birds) is expected to be negligible considering their preferred habitat

The impact of changed vegetation pattern on the EPBC-listed Southern Bell Frog is expected to be either to maintain or improve the preferred habitat for breeding

Impacts to Pelican Lagoon and Nalpa Station

Several submissions raised concerns regarding Pelican Lagoon and wetland habitats on Nalpa Station Pelican Lagoon is a large fringing wetland located directly upstream from the temporary weir site Previous surveys at the wetland and the Nalpa property have determined the area to be a biodiversity hot-spot hosting significant species such as the southern bell frog southern pygmy perch white-bellied sea eagle golden-headed c istic ola Lewin s ra il Australasian shoveler and various aquatic plant species As the wetland has been dry since early 2007 there is an inherent assumption that these species are lost therefore the impact of the temporary weir can be negated However further impacts upon these species are possible

Response

It would be desirable to resurvey the area particularly the small inundated area from which stock and domestic water are accessed to determine which species of significance remain and what measures can be taken to protect them

The local landholders have also shown an interest in undertaking management actions for the betterment of the wetland environment Support could be provided in the form of a wetland management plan for the site to determine the most effective way to manage the wetland

Weir Footprint Impacts

Impacts of Habitat LossDegradation

Several submissions argued that potential impacts to flora and fauna due to the clearance or disturbance of vegetation at the weir construction site were understated or unclear These flora and fauna included EPBC Act-listed species Among the fauna of concern were the Southern Bell Frog Orange-bellied Parrot La tham s Snipe (Gallinago hardwickii) White Bellied Sea Eagle and Great Egret Flora of concern included Phragmites australis Typha domingensis Senecio longicollaris Shrubby Groundsel (Senecio cunninghamii var cunninghamii) purple Loosestrife (Lythrum salicaria) and a range of samphire species

Response

A native fauna and flora survey of the approach works footprint and the subaqueous weir footprint was conducted by ecological consultants in SeptemberOctober 2008 (Ecological Associates 2008) Habitat impacts in the immediate weir footprint area were identified to be minimal

It is highly likely that the temporary weir will cause the loss of some of the reed beds at or near the construction site through physical disturbance

Supplementary EIS for the temporary weir near Pomanda Island -25shy

Impacts of mud disturbance upon salinity

One submission claimed that mud disturbance around the temporary weir site during construction would turn the water saline and impact on all fish species

Response

There is no available data which suggest that disturbance of submerged sediments can lead to an increase in the salinity of surface water

Impacts upon fish migration

A significant number of submissions argued that the temporary weir may impede upstream and downstream movement of juvenile and adult fish including EPBC Act - listed species and that this is an unacceptable impact upon upstream and downstream ecosystems and commercial fishing activities

Response

Due to concerns raised in submissions about the lack of a fishway (fish passage) a process has been initiated to determine a suitable design concept that would allow passage of both the nationally listed and other fish species

SARDI has indicated that it has sufficient knowledge to be able to design a fishway without the need for further site survey work SA Water Corporation is working with SARDI to design a suitable fishway into the temporary weir

SA Water Corporation is progressing a concept design for a fishway in the temporary weir with URS Australia

The concept design for the fishway is expected to be completed in July 2009 and a draft Concept Design Report should be available before the end July 2009 The report will include sketches of the concept and will also show the impact on the temporary weir design

The concept (although still to be finalised and confirmed) is for a rock ramp fishway in the centre of the temporary weir at the western end of the spillway This position places the fishway as close as possible to the deep channel to the west near Pomanda Island The rock ramp would be around 50 metres wide and slope downstream on a 130 gradient The deep centre section would be a metre deep (at full pool level) and the sides of the ramp would slope upwards to provide shallower and slower paths for smaller fish Stop logs at the top of the ramp will allow dewatering of the fish passage

Although the impacts on the temporary weir design will not be certain until the concept design is finalised the indicative impacts of such a concept include the following

The fishway hydraulic design will maintain an upper weir pool water level of 00m AHD with a flow of 600 MLday

A small auxiliary spillway is needed adjacent to the fishway to provide an attraction flow and this will pass 360 MLday the remainder of the average daily flow of 960 MLday (350 GLyear)

At a flow of 960 MLday the upper weir pool will be +01 m AHD with the fishway open (ie identical to the no fish passage design)

At a flow of 1200 MLday the upper weir pool will be +017 m AHD with the fishway open

For automatic operation the bottom of the auxiliary spillway will be inclined from +01 m AHD to +02 m AHD between the fishway and the main spillway

The main spillway crest will be raised to +02 m AHD to ensure that average daily flows remain confined to the fishway and auxiliary spillway Initially a spillway level of +01 m AHD had been established as the upper pool level to be retained by the weir

Supplementary EIS for the temporary weir near Pomanda Island -26shy

However the desire to have a ll flow pass through the fishway during norma l river flow that is 960 Mlday with the upper pool level maintained at +01 m AHD necessitates a reconfiguration of the main spillway of the temporary weir

The main spillway will be slightly shorter (around 1150m wide instead of 1200m wide) so that the fishway can be constructed on the western edge of the better foundation material

To ensure that water entering the downstream pool from either the fishway auxiliary spillway or main spillway remains continuous and provides an attraction path to the fishway the centreline of the auxiliary spillway and main spillway will be moved slightly downstream between the fishway and the eastern abutment

The introduction of a fishway will overcome the possible impacts of the temporary weir discussed in Section 135 of the Draft EIS

Impacts of noise upon wetland birds

One respondent sought clarification on the level of noise the weir construction is anticipated to create given that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB as stated in the Draft EIS

Response

There are no wetlands on the eastern side near the abutment It is anticipated that any areas around Low Point populated by birds will receive noise levels similar to that from a busy highway The same will apply to the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels which would presumably cause them to move further north into the wetland area

Monitoring during constructiondecommissioning

A number of submissions questioned how the Monitoring of EPBC-listed spec ies referred to on page 15-24 of the Draft EIS will ensure that construction operation and decommissioning activities do not impact on EPBC-listed species More information was sought on the fauna inspection to be carried out in the construction area before any vegetation clearance (Table 15-9 on pp 15-2526 of the Draft EIS)

Response

Monitoring during operation of the temporary weir will be coordinated as part of the SA MDB NRMB s na tura l resource condition monitoring program It will include additional monitoring efforts as per expert advice

of the EPBC-listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life and breeding cycles The monitoring focus will be of an observational nature in regards to compliance monitoring This is to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by the Commonwealth and the South Australian Native Vegetation Council) and that the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora and fauna expert advice if warranted In addition the Contrac tor s EMP will identify based on a risk assessment whic h spec ific mitiga tion and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations needs to be recorded

It is rec ognised tha t the monitoring

A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water Corporation and DEH (Ecological Associates 2008) This knowledge has been considered by the Commonwealth More specific instructions on how this can be used will be included in the CEMP The project will ensure that expert advice is available throughout the duration of the construction phase

Supplementary EIS for the temporary weir near Pomanda Island -27shy

Timing of construction and presence of migratory species

One respondent commented that the Draft EIS did not appear to consider the interaction between the timing of construction and the presence of migratory species eg Orange-bellied Parrot potentially present from March to early November

Response

The Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to help protect Orange-bellied Parrots might however impact on other species Migratory shorebirds for example return in late August and spend the entire summer at the site

Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coorong_S urvey_lowpdf

Downstream impacts

Impacts of water level changes upon aquatic vegetation

A respondent noted that in Section 1246 on page 12-11 of the Draft EIS under the heading Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion are

considered insignificant as many of these species reproduce sexually and through wind or bird-d riven seed d ispersa l This is only a c onsidera tion of impac ts upon rep roduc tion not a consideration of whether the plants will even survive to reproduce

Response

Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately +035 m AHD At a water level of -15 m AHD (when the temporary weir would close) this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the water body and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long-term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the Lake be refilled with freshwater to its pre-drought level (+05 to +08 m AHD) while the below-ground storage organs remain viable

Impacts of temporary increase in salinity upon aquatic biota

A significant number of submissions raised concerns regarding the impact of the temporary weir upon salinity in the Lower Lakes and consequent impacts upon biota There were also concerns that not all Matters of NES potentially impacted by the temporary salinity increase caused by the temporary weir had been adequately addressed One submission predicted the salinity increase would cause a mass die-off of Common Carp which would lead to poor water quality in Lake Alexandrina

Response

The scope of the EIS dictates that it consider the impacts of the temporary weir upon biota that are listed as threatened under the EPBC Act or that contribute to the ecological character of the Coorong Lakes Alexandrina and Albert Ramsar site These include all of the freshwater diadromous and estuarine fish species of the freshwater units (Lower Lakes) as well as a large number of bird taxa many of which are piscivorous (Phillips and Muller 2006) Taxa other than fish and birds need only be considered by the EIS if impacts upon them are likely to be transferred into a significant impact upon fish or bird communities

Supplementary EIS for the temporary weir near Pomanda Island -28shy

The impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake (Fig 10-5 in the Draft EIS) The salinity of Lake Alexandrina is predicted to be higher than both the limits of acceptable change (700 EC (Phillips and Muller 2006)) and the typical seasonal maximum (1500 EC) from January 2010 onwards at all loc a tions under both the weir and no weir sc enarios Modelling shows tha t the d ifferenc e in salinity in Lake Alexandrina (modelling assuming continued pumping to Lake Albert however on 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009) under the weir and no weir sc enarios va ries with location At all sites modelled salinity is similar in early 2011 one year after weir construction under both the weir and no weir sc enarios (Sec tion 10) However immediately following weir construction a temporary increase in salinity three to five months in duration is predicted at most sites The magnitude of the salinity increase varies between sites but is pronounced at several sites

A salinity threshold that is important in terms of the maintenance of ecological character is the salinity tolerance of the resident native freshwater fish species of the Lower Lakes Salinity tolerance varies between species but for the temporary weir to have no significant impact upon native fish species its construction should not cause salinity to exceed the tolerance of the most salinity-sensitive species

Several species of rare or threatened small-bodied native freshwater fish that are resident in the Lower Lakes under pre-drought water levels (+04 to +08 m AHD) are unlikely to be present in Lake Alexandrina at a water level of 15 m AHD Yarra Pygmy Perch have probably become locally extinct in the CLLMM as a consequence of the current low water levels (Bice and Ye 2009) Mountain Galaxias Murray Rainbowfish and Southern Purple-spotted Gudgeon are all very rare possibly extinct from the CLLMM with no records for a number of years (Bice and Ye 2009) All of these small-bodied species are associated with fringing aquatic vegetation They are unlikely to be present in Lake Alexandrina when water levels have declined to the extent that all fringing aquatic vegetation has become disconnected from the water body

Prior to the drought the only part of the Coorong Lower Lakes and Murray Mouth where River Blackfish had been recorded were the upper reaches of the Eastern Mt Lofty Ranges tributaries that enter Lake Alexandrina (Bice and Ye 2009) The species prefers permanently flowing freshwater streams with cool clear water where it is strongly associated with the in-stream cover habitats provided by undercut banks and boulders (Khan et al 2004) It is unlikely to be present in the open water habitat of Lake Alexandrina that is disconnected from fringing aquatic vegetation and other forms of cover

A number of short-lived (lifespan generally 3 years or less) small-bodied native freshwater fish species could potentially be present in Lake Alexandrina when the water level reaches

15 m AHD These species are dependent upon fringing or benthic aquatic vegetation during part of their lifecycle particularly egg and larval stages (Lintermans 2007) with the exception of Australian Smelt which is a more pelagic species Therefore conditions in Lake Alexandrina are likely to be unfavourable for their persistence due to the disconnection of fringing vegetation and the water body Although unlikely it is possible that these species may persist providing important remnant populations that could potentially increase in abundance and repopulate the Lake when water levels return to pre-drought levels Due to their brief lifespans the salinity tolerances of all stages of the life cycle are relevant to the potential impacts of the temporary weir upon them Egg and larval stages typically have the lowest salinity tolerance (Bice and Ye 2009) Because breeding occurs in spring and summer for most of these species (Lintermans 2007) the summer-autumn timing of the short-term increase in salinity levels caused by weir construction could have implications for breeding success and thus persistence of these short-lived species in the Lower Lakes The species and salinity tolerances of their most salinity-sensitive lifestage are Southern Pygmy Perch (15500 EC (adult tolerance - egg and larval tolerance not known)) Murray Hardyhead (80000 EC (low confidence)) Carp Gudgeon complex (9800 EC) Flat-headed Gudgeon (19200 EC) Dwarf Flat-headed Gudgeon (10800 EC) Australian Smelt (92200 EC (adult tolerance - egg and larval tolerance not known)) and Unspecked Hardyhead (68300 EC (adult tolerance - egg and larval tolerance not known)) (Bice and Ye 2009)

The large-bodied native freshwater fish of Lake Alexandrina all have a lifespan of at least several years Thus a short-term (three to five month) increase in salinity that exceeds the tolerance of eggs or larvae does not represent a significant impact to the species if adults are unaffected and can subsequently successfully reproduce when salinities return to tolerable

Supplementary EIS for the temporary weir near Pomanda Island -29shy

levels for sub-adult life stages Large-bodied native freshwater fish species potentially present in the Lake Alexandrina at a water level of 15 m AHD and their respective adult salinity tolerances are Murray Cod (24 500 EC) Silver Perch (25 000 EC) Eel-tailed Catfish (28 000 EC) Golden Perch (Callop) (51 500 EC) and Bony Herring (54 500 EC) (Bice and Ye 2009)

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9) Thus construction of the temporary weir causes salinity to shift from tolerable to intolerable for the eggs or larvae of Carp Gudgeon complex Dwarf Flat-headed Gudgeon and possibly Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead Although the period of intolerable salinity is temporary it will lead to declines in their abundance in the Lower Lakes There are no modelled sites at which salinities will shift from tolerable to intolerable for large-bodied species

Carp Gudgeon complex Dwarf Flat-headed Gudgeon Southern Pygmy Perch Australian Smelt and Unspecked Hardyhead

Declines or complete loss of small-bodied native freshwater fish

from Lake Alexandrina if this occurs is anticipated to be temporary All of these species occur in the River Murray channel and their downstream migration past the temporary weir (which is to feature a fishway) into the Lower Lakes is anticipated to recommence following the period of reduced flow (see page 13) during weir construction Therefore any declines in abundance due to the short-term increase in salinity levels associated with weir construction are likely to be temporary

Adult Common Carp have a salinity tolerance of ~23 500 EC (Bice and Ye 2009) Modelling indicates that the temporary increase in salinity levels caused by weir construction will not cause salinity to increase from tolerable to intolerable for adult Common Carp at any site Most of Lake Alexandrina will remain below the salinity threshold for this species Therefore the temporary increase in salinity caused by the temporary weir is not anticipated to cause a mass die-off of Common Carp or associated water pollution

Recently collected data puts the above discussion into context Fish surveys conducted during weeks 13 17 April 2009 in the Goolwa channel (between Clayton and Goolwa barrages) indicated the obligate freshwater fish community of this area of the Lower Lakes was composed primarily of three species Australian Smelt Flat-headed Gudgeon and Bony Herring (SARDI unpublished data) Salinities at Clayton during the same period ranged from ~18000 to ~24000 EC (DWLBC 2009) These three species are clearly able to persist in the Lower Lakes despite loss of connectivity with fringing aquatic vegetation and elevated salinity Their persistence indicates that both their habitat and feeding requirements are met When the water level in the main body of Lake Alexandrina falls to 15 m AHD triggering weir construction it is likely that the obligate freshwater fish community will be comprised primarily of these three species The temporary increase in salinity levels anticipated will not lead to salinities in excess of those that these species are currently experiencing in the Goolwa channel

The above discussion illustrates that the temporary increase in salinity levels caused by the construction of a temporary weir near Pomanda Island is unlikely to have a significant impact upon the resident native freshwater fish species of the Lower Lakes The temporary increase in salinity levels will cause salinity in Lake Alexandrina to shift from tolerable to intolerable for a small number of short-lived small-bodied native freshwater fish species However at the time of weir construction these species are likely to be in decline or absent due to other factors primarily the loss of fringing aquatic vegetation habitat unrelated to weir construction Additionally the unfavourable salinities caused by weir construction are predicted to be temporary and repopulation of the Lower Lakes via downstream migration from the River Murray channel is anticipated to occur following weir construction Ongoing fish monitoring of the lower lakes will provide further information regarding impacts to native freshwater fish

The above discussion has focussed primarily upon obligate freshwater fish of the Lower Lakes However a number of diadromous and estuarine species are also common in the Lower Lakes (Phillips and Muller 2006) The salinity tolerances of these species are much higher than those for obligate freshwater fish species (Bice and Ye 2009) and the temporary increase in salinity levels due to weir construction is not anticipated to have a significant impact upon diadromous or estuarine species

Supplementary EIS for the temporary weir near Pomanda Island -30shy

It is likely that the impacts of the temporary weir upon fish in the Lower Lakes will be transferred to piscivorous birds Given that the temporary weir is unlikely to have a significant impact upon obligate freshwater diadromous or estuarine native fish species a significant impact upon piscivorous birds due to declines in native fish abundance is also unlikely Therefore piscivorous birds are not anticipated to be significantly impacted by weir construction

The impact of the temporary increase in salinity levels upon the invasive polychaete tubeworm Ficopomatus enigmaticus should be examined in the light of the research being undertaken by Dr Sabine Dittmann for the SA MDB NRMB The tubeworm itself has not been identified as a Matter of NES however changes to its abundance may impact upon Matters of NES

The Long-necked Tortoise is not listed as threatened under the EPBC Act nor is it considered a Ramsar-significant species or a primary determinant of ecological character for the CLLMM (Phillips and Muller 2006) The Long-necked Tortoise population of the CLLMM is therefore not a matter of national environmental significance and the impact of the temporary weir upon it is outside the scope of the EIS

Impacts upon tributary wetlands

A number of submissions were received regarding the impacts upon the ecosystems of the tributary wetlands of disconnection of surface waters and groundwater interactions caused by construction of the temporary weir

Response

The Swamps of the Fleurieu Peninsulas geographic distribution include swamps fringing Currency Creek Finniss River Goolwa Channel and Lake Alexandrina near Milang These swamps have already disconnected from the surface water of Lake Alexandrina

The Angas and Bremer Rivers discharge directly into Lake Alexandrina and were the first to disconnect at a water level of approximately +03 m AHD

The Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton (EPBC Reference No 20094833) The South Australian Government commenced construction of the regulator in June 2009 This regulator is expected to be completed in August 2009 and will result in the Goolwa Channel Currency Creek and Finniss River being disconnected from Lake Alexandrina

The Hindmarsh Island channels disconnected at approximately +01 m AHD These well-vegetated water bodies were significant habitat for the EPBC-listed Yarra Pygmy Perch and thus a captured breeding and recovery program has been implemented to ensure that the populations survive the current drawdown and can be released once water levels and habitat conditions improve

In terms of groundwater connection it is assumed that the tributaries and Lake Alexandrina will remain connected through groundwater at water levels less than -28 m AHD and thus could potentially be impacted upon by construction of the temporary weir During development of the EIS DWLBC staff were consulted on whether the predicted decrease in the Lake Alexandrina level of 210 mm near the tributaries as a result of constructing the temporary weir would have a significant impact on groundwater flux The conclusion was that the additional increase in head would not be significant compared to the water level drop caused by drought and over-allocation already experienced

Impacts upon the Milang Snipe sanctuary

One submission argued that the Draft EIS had not adequately addressed impacts upon the Milang Snipe Sanctuary

Response

The Milang Snipe sanc tuary is a very signific ant refuge for Japanese (La tham s) Snipe a recognised migratory species under the EPBC legislation and a listed species under the China Australia Migratory Bird Agreement (CAMBA) Japan Australia Migratory Bird Agreement (JAMBA) and the Republic of Korea Australia Migratory Bird Agreement (ROKAMBA) In

Supplementary EIS for the temporary weir near Pomanda Island -31shy

addition the presence of mature aquatic vegetation and the mosaic of ponds have provided excellent habitat for a suite of other waterbird species

The Japanese Snipe requires freshwater wetlands and vegetated meadows and preferably seasonal or semi permanent freshwater swamps Under a different hydrological regime the inundation frequency of the wetlands will change and the habitat will no longer remain optimal This site is a very good example of a wetland that may become compromised by altered hydrology

The Milang Snipe sanctuary is inundated when water levels in the Lower Lakes are high The site is currently dry The temporary weir is not anticipated to impact upon the water regime at the Milang Snipe sanctuary and therefore no significant impact upon the ecosystem of this site is predicted as a consequence of weir construction and operation

Impacts upon primary determinants of ecological character

One respondent noted that the summary of ecological impacts upon the primary determinants of ecological character (pg 12-20 section 126) appears to relate more to current drought-related ecological impacts and not specifically to the additional (likely to be small in comparison) ecological impacts of temporarily reducing flow to Lake Alexandrina

Response

This is agreed Additional comment is as follows Section 12-6 of the Draft EIS summarises the predicted impacts of the temporary weir upon the primary determinants of ecological character of the CLLMM Ramsar site It covers impacts to two primary determinants keystone aquatic plant species and habitat availability However it does not address the other four primary determinants outlined in the ECD It also fails to clarify the difference between drought impacts and weir impacts upon the primary determinants The following changes are proposed

In Section 12-6 pages 12-20 under the dot point Hab ita t ava ilab ility add the following four dot points

Salinity assigned a red light highlighting that conditions in 2006 were leading to loss of species (including keystones) and that salinities in the saline-estuarine units needed to be reduced urgently in order to maintain ecological character

Turbidity and sedimentation patterns assigned an orange light assessment highlighting that knowledge was poor and improved flows were required in 2006

Water levels assigned an orange light assessment highlighting that the regime in 2006 was counter-seasonal to the natural one and too static to support the full complement of the Lakes b iota and

Water regime particularly flow patterns in relation to inflows from the River Murray assigned a red light assessment highlighting that change to the ecological character of the site is largely a consequence of reduced flows from the River Murray

Additionally the first paragraph on page 1221 of the Draft EIS should be replaced by the expanded discussion under the six sub-headings which follow

Impact upon keystone species

Keystone aquatic plant species and assemblages in the Lower Lakes and tributary wetlands have become disconnected from the water body threatening their ongoing persistence Disconnection occurs at water levels below approximately +035 m AHD and is a consequence of the drought and upstream diversions Modelling indicates that disconnection will continue indefinitely under anticipated low flow conditions (see Section 10) with or without the weir in place The temporary weir will not alter the duration of disconnection between the keystone aquatic plant species and the water body The impact of the temporary weir upon this primary determinant of ecological character is therefore considered insignificant

Impact upon habitat availability

Habitat availability (particularly spatial and temporal connectivity) has been dramatically reduced by the drought due to the disconnection between the various parts of the system Key water levels for disconnection include

Supplementary EIS for the temporary weir near Pomanda Island -32shy

+05 m AHD disconnection between the freshwater and saline-estuarine units occurs (permanent barrage closure is required to prevent seawater incursion into the Lower Lakes)

+035 m AHD disconnection between fringing aquatic vegetation of the Lower Lakes and the water body

03 m AHD disconnection between Lake Alexandrina and Lake Albert occurs and

12 m AHD disconnection between the Goolwa channel (and associated tributary wetlands) and Lake Alexandrina occurs

Water levels of lt 15 m AHD will persist for the 2010-2012 period (the nominal lifespan of the temporary weir) should low flows continue (896 GLyr at the SAVic border) whether the temporary weir is built or not (Section 10) Thus the temporary weir will have no impact upon connectivity within the Ramsar site connectivity having already been lost due to the drought However the temporary weir will have an impact upon connectivity between the River Murray channel upstream and the Coorong Lakes Alexandrina and Albert Ramsar site downstream The impact upon this loss of connectivity upon fish and potential mitigation measures is discussed in Section 1353 of the draft EIS

Impact upon salinity

As discussed on page 31 the impact of the temporary weir upon salinity in Lake Alexandrina has been modelled for a number of locations within the Lake

Modelling indicates that the temporary increase in salinity levels caused by the temporary weir increases peak salinity from 4680 EC to 12430 EC at Site 28 from 7420 EC to 11880 EC at Site 29 from 10650 EC to 14990 EC at Site 41 from 13890 EC to 15920 EC at Site 65 from 14160 EC to 16170 EC at Site 66 from 12520 EC to 15340 at Site 67 from 29500 EC to 33200 EC at Site 63 and from 18200 EC to 20400 EC at Site 64 (Table 10-9)

Impact upon turbidity and sedimentation patterns

The turbidity and sedimentation patterns in the Ramsar site are not predicted to be significantly impacted by the temporary weir The impact of current and ongoing low water levels upon this primary determinant of ecological character is anticipated to overwhelm any additional impact caused by the temporary weir The potential for temporary increases in turbidity during the construction phase of the temporary weir will be addressed by mitigation measures discussed in Sections 114 and 115 of the draft EIS

Impact upon water levels

The impact of the temporary weir upon water levels is discussed extensively in Section 10 of the d ra ft EIS Under both weir and no weir sc enarios wa ter levels in the Lower Lakes will be well outside those recommended by Phillips and Muller (2006) ie +01 to +08 m AHD Modelling shows that the temporary weir leads to lower water levels in Lake Alexandrina than would occur if it were not constructed but that the effect is reduced as time post construction increases (Table 10-7) Of particular note is the impact of weir construction upon the timing of exposure of sulfidic sediments in Lake Alexandrina Construction of the temporary weir is anticipated to lead to the critical water level of 15 m AHD which is expected to lead to acidification of the Lake being reached earlier than would occur if it were not constructed However modelling indicates that such water levels will be reached irrespective of a temporary weir being constructed should low flows continue Measures to avoid acidification are discussed in Sections 1126 and 15412 of the draft EIS

Impact upon water regime

The impact of the temporary weir upon water regime particularly flow patterns is considered insignificant

As indicated on page 32 the Angas and Bremer have been disconnected since 2007 and the Goolwa Channel will be disconnected from Lake Alexandrina during construction of the temporary environmental flow regulator at Clayton

Lake Albert was disconnected with the cessation of pumping from Lake Alexandrina on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -33shy

By mid to late 2010 the water level in Lake Alexandrina will be at approximately 15 m AHD Thus the Lake will be disconnected from all other parts of the Ramsar site (ie the Coorong)

Thus any impact of the temporary weir upon water regime affects only Lake Alexandrina and the small area of the Ramsar site located upstream of the weir site The impact upon Lake Alexandrina is a temporarily increased rate of water level decline with various consequences discussed above The impact of increased water level upon the area of the Ramsar site upstream of the temporary weir and upon the River Murray channel upstream of the Ramsar site is considered to be positive provided acidification can be avoided or mitigated

Impacts upon migratory shorebirds

A number of submissions argued that the potential impacts of the temporary weir upon migratory shorebirds had not been adequately addressed Additionally several submissions expressed concern that by limiting the discussion of impacts to regularly recorded migratory shorebirds important impacts could be overlooked It was argued that species recorded infrequently and in low numbers should be a priority for protection as it is likely that they are more susceptible to localised impacts

Response

The temporary weir is unlikely to impact negatively upon the abundance of migratory shorebirds using Lake Alexandrina Under previous management arrangements the Lake was surcharged with water each year and only small areas of exposed mudflat were useable by shorebirds Over the past 18 months the wa ter line has rec eded and the Lake s edges have a t times been used preferentially (compared with the Coorong) for foraging purposes (Wainwright and Christie (in press))

Section 14 of the Draft EIS examines the likely interactions should the temporary weir proceed All migratory shorebirds are listed as matters of NES under the EPBC legislation The separation of seven spec ies into a group desc ribed as regula rly rec orded rela tes to the abundanc e of these species in comparison with any other migratory shorebird and tern species that have been observed a t Lake Alexandrina The regula rly rec orded group a re a t least two orders of magnitude more common Waterbird data collected monthly from 16 sites (2003 to current) around Lake Alexandrina informs this thinking

Impacts upon Australian Painted Snipe

A number of submissions argued that the Draft EIS should have addressed impacts upon the Australian Painted Snipe

Response

The Australian Painted Snipe is nomadic and adopts wetlands opportunistically It requires freshwater and well vegetated wetlands with internal complexity Recent records from Lake Alexandrina are scarce (Letch 2007) presumably because the recent drought has eliminated all suitable habitats However historic records suggest that the fringing habitats around Lake Alexandrina when intermittently favourable have been frequented by the species Recent information suggests that the Australian Painted Snipe may be present close to the site of the temporary weir

Low water levels in the Lower Lakes appear to have led to a significant loss of habitat for the Australian Painted Snipe However given the suggestion that it may be present in the vicinity of the temporary weir construction area it should be considered in the EMP to be prepared for weir construction

Impacts upon Orange-bellied Parrot

One respondent noted that discussion of the Orange-bellied Parrot did not mention the importance of samphire habitat to this species One submission argued that potential impacts upon the Orange-bellied Parrot had not been properly addressed in the Draft EIS

Response

Within South Australia the Orange-bellied Parrot appears to be less dependent than previously suspected on samphire vegetation Recent observations in South Australia suggest that the

Supplementary EIS for the temporary weir near Pomanda Island -34shy

species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

The Orange-bellied Parrot is critically endangered and interactions with proposed weir operations are considered possible The species is known to use a range of habitats including highly disturbed areas Accordingly it is a subject discussed in Chapter 13 of the draft EIS

Impacts upon Great Egret Cattle Egret and Caspian Tern

One respondent expressed concern that the Great Egret Cattle Egret and Caspian Tern are not dealt with satisfactorily One submission noted problems with the nomenclature concerning egrets

Response

The two Egret species being discussed in Section 761 are the Great Egret Egretta (Ardea) Alba and the Cattle Egret Ardea ibis Both species are listed migratory species under the EPBC legislation The Cattle Egret is listed as a migratory species using the binomial Ardeola ibis The reference in Section 77 to the White Egret for consistency should read Great Egret Both are recognised English names for the species Egretta (Ardea) Alba

The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in south-eastern Queensland and north-eastern New South Wales (Marchant and Higgins 1993)

The movements of Caspian Tern are poorly understood they are partly resident partly dispersive and possibly partly migratory (Marchant and Higgins 1993) The species is commonly observed on fresh and marine waters foraging on the wing for fish

Impacts upon pelagic birds

One submission argued that potential impacts upon pelagic bird species had not been properly addressed in the Draft EIS

Response

Pelagic bird species listed in the draft EIS (including all listed Albatross species Blue Petrel Giant Petrels and the Soft-plumaged Petrel) are all oceanic species that have no dependence on Lake Alexandrina for food or habitat Their presence at the site is fortuitous Records are mostly of ocean beach-washed specimens or live animals temporarily blown inland during storm events The weir construction has no effect on their endurance

Impacts upon bush birds

One submission argued that potential impacts upon bush bird species had not been properly addressed in the Draft EIS

Response

The Black-eared Miner Red-Lored Whistler Malleefowl and Regent Parrot are all species that require mallee or woodland habitats that are now largely absent from the edges of Lake Alexandrina These bird species are now locally extinct from the Lakes area because of landscape scale changes to adjacent woodland and mallee habitats Recent observations of these spec ies in the reg ion (as c ited in The Natura l History of Stra tha lbyn and Goolwa Distric ts 2000) are from locations that support very different habitats to those immediately adjacent to

Supplementary EIS for the temporary weir near Pomanda Island -35shy

the Lakes It is highly unlikely that any of these species would be affected by the temporary weir

The Spotted Quail-Thrush is now considered extinct in the Mount Lofty Ranges and Fleurieu Peninsula

Impacts upon Mt Lofty Ranges Southern Emu Wren

Several submissions argued that potential impacts upon the Mt Lofty Ranges Southern Emu Wren had not been adequately addressed in the Draft EIS

Response

The Mount Lofty Ranges Southern Emu-Wren is recognised as an endangered species that inhabits fragmented wet and dry heath in the vicinity of the proposed weir site The nearest known rec ords of the spec ies (sourc e Biolog ic a l Da tabases of SA ) determined by extensive surveys are 35 kilometres from the temporary weir site at the top of the Finniss estuary It most unlikely that the temporary weir proposal would impact negatively on the species however it has been considered in the discussion about impacts in Chapter 13 of the Draft EIS

Impacts upon White-bellied Sea Eagle

One submission argued that potential impacts upon the White-bellied Sea Eagle had not been properly addressed in the Draft EIS

Response

The White-bellied Sea Eagle is regularly observed but not so commonly recorded in the Lower Lakes and Coorong area The species exploits the protected waters at both sites for fishing A recent sighting of a juvenile bird suggests that local breeding also occurs The implications of the temporary weir on this species are outlined in Chapter 14 of the draft EIS

Issues of scope adequacy and definition

Adequacy of species and communities examined

There were a significant number of submissions on this issue and one respondent who argued that the Draft EIS was inadequate in its assessment of ecological impact because the range of species and communities examined was too limited The Draft EIS assessment was constrained to the Matters of NES listed in the EPBC referral documents Submissions raise the criticism that all components of the Ramsar site should be assessed not just nominated Matters of NES because they are interconnected and interdependent

Response

This statement is true in terms of defining changes to ecological character of the Ramsar site And if the temporary weir were to be built under normal operating conditions all ecological components would have been assessed However the impacts of the temporary weir per se were restricted to those ecological components that would occupy the Ramsar Type O (permanent freshwater lakes) wetlands at a water level of -15 m AHD because this will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir

It is also assumed that at -15 m AHD there will be little or no aquatic vegetation in the Type O wetland because historical high turbidity and static water levels have precluded growth of plants that far out into the Lakes The water body that remains would generally be several kilometres from the existing aquatic plant seedbank and would remain very high in turbidity and experience high energy water movement Thus it is not predicted that keystone aquatic plant species will colonise this area before construction of the temporary weir The benthos was not assessed specifically and further research into the species and distribution of benthic fauna at very low lake levels would improve this draft EIS particularly given the dependence of EPBC-listed fish and bird species on benthic fauna

Impacts on other Ramsar Wetland Types (that is the rest of the Ramsar site) were not considered because the impacts of the drought and over allocation were considered to be the primary determinants of change in ecological character for those wetlands

Supplementary EIS for the temporary weir near Pomanda Island -36shy

Current status of waterbirds

One submission noted that the current status of waterbirds and migratory shorebirds at the CLLMM had not been adequately stated and that recent research (Kingsford 2009) had not been referred to

Response

Most waterbird species are migratory to some degree Some species have predictable movements but most species respond opportunistically to climatic events that bring about favourable changes in habitat quality or food resources Local and continental rainfall patterns have a strong influence on the abundance of waterbirds using the Lower Lakes At the continental scale there were significant changes in the amount of rainfall (and subsequent change in area of wetland habitat) between November 2007 and early 2009 In late 2007 the Murray-Darling and Lake Eyre Basins were both drought affected During 2008 South-eastern Queensland and northern New South Wales received record rainfall and a 1-10 year flood occurred in the Lake Eyre Basin The entire populations of some species (Pink-eared Duck for example) respond to these events adopting the most favourable habitat available The large amount of variability in waterbird numbers is expected and it is a strategy waterbirds use to survive the natural variability in the Australian climate

Regular bird survey work at 23 sites around Lake Alexandrina during the last 12 months suggests that there are no detectable changes in the species richness of waterbirds using the Lower Lakes There are more obvious changes in abundance and as a generalisation waterfowl numbers have decreased while shorebird abundance has increased

Adequacy of EPBC Act threatened species and communities lists

One submission argued that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the Murray-Darling Basin including the CLLMM region are currently being evaluated for EPBC listing

Response

The scope of the EIS is confined to Matters of NES Only nationally listed threatened species or nationally listed migratory species or those that contribute to the ecological character of a Ramsar site are matters of NES Species and communities that are under evaluation for listing as threatened but not yet listed are not matters of NES

Adequacy of discussion of EPBC Act-listed species

One submission argued that the discussion of EPBC Act-listed species in the EIS is incomplete and superficial

Response

Additional detail regarding potential impacts to EPBC Act-listed species is provided in several chapters of this supplementary EIS

Omitted flora and fauna records

Natura l History of Stra tha lbyn and Goolwa Distric ts (2000) (Stra tha lbyn Natura lists Club Inc ) and the Tolderol Wetland Management Plan Severa l submissions mentioned tha t the

c onta in information on a number of EPBC Act-listed species that have been recorded in fringing wetlands of the Lower Lakes but were not discussed in the EIS

Response

Natural History of Strathalbyn and Goolwa Distric ts (2000) and the Tolderol Wetland Management Plan may revea l EPBC Act-listed species that have been recorded in the CLLMM in addition to those mentioned in the draft EIS However given the current disconnection of the wetland habitats of the area and the predicted absence of any impact of the temporary weir upon their water regime the temporary weir is not anticipated to cause a significant impact upon the wetland-dependent species of the fringing wetlands of the Lower Lakes

A more thorough examina tion of the litera ture foc ussing on the

Supplementary EIS for the temporary weir near Pomanda Island -37shy

Definition of keystone species

Severa l submissions a rgued tha t the term keystone spec ies had been misused in the Dra ft EIS It was argued that all species that are critical to food chain processes in the Lower Lakes (ie keystone species) should be identified and discussed and that conceptual models detailing the importance of these key biota would help the reader to understand the processes

Response

The Ecological Character Description (ECD) for the site (Phillips and Muller 2006) describes the keystone species of the CLLMM The draft EIS uses the same language and examples of keystone species as does the ECD Correcting an incorrect ECD is beyond the scope of the EIS

Species considered of particular significance

One submission argued that Murray Hardyhead Yarra Pygmy Perch and Murray Cod should be on the partic ula r signific anc e list

Response

list (Section 7-5 of the Draft EIS) The impact of the temporary weir upon these species is examined in Chapter 13 of the Draft EIS

Murray Hardyhead Yarra Pygmy Perc h and Murray Cod a re on the partic ula r signific anc e

Adequacy of description of different wetland types

A number of submissions argued that the ecological information regarding each of the 15 wetland types of the CLLMM was inadequate to assess impacts of the temporary weir upon them

Response

The modelled water level response in Lake Alexandrina shows that the reduction in water level of an average of 170mm occurs only during the weir fill stage and that there is limited persistent impact on Lake levels Therefore an assessment of the timing for reconnecting those wetland types that already are or will be disconnected by the drought conditions at a water level of -15 m AHD is not a direct impact of the temporary weir and thus is beyond the scope of the draft EIS

Regional importance of the Coorong Lower Lakes and Murray Mouth

It was noted in several submissions that the Chowilla Ramsar wetland has been disregarded as it is greater than 200km from the Lower Lakes and Coorong The EIS needs to consider the regional implications of a degraded Lakes and Coorong and the use of aquatic habitats by migratory bird species If environmental water is not being delivered to the Lower Lakes and Coorong provision for suitable aquatic habitat needs to be made in other areas of the state as a minimum

Response

The proponent notes that both the CLLMM and Chowilla Ramsar sites are regionally significant and that adequate inflows to maintain the ecological character of both are required This issue is outside the scope of the Draft EIS

Australia s Ramsar obligations

A number of submissions raised the issue that Australia does not appear to be committed to wise use of the Coorong and Lakes Alexandrina and Albert Ramsar site and its obligations

under the Ramsar Convention in terms of proposing that this temporary weir be built

Response

The principal factor impacting on the Ramsar site is the low flow of freshwater to the site particularly over the last few years of drought and over-allocation across the Murray-Darling Basin ra ther than a lac k of c ommitment to wise use

Supplementary EIS for the temporary weir near Pomanda Island -38shy

6 Notes on significant issues outside the scope of the draft EIS

For example overview of submissions about over allocations a permanent lock sea water incursions and other CLLMM possibilities

Notes on social and economic issues raised in submissions

In this section a number of significant concerns and ideas detailed in submissions by individuals organizations and local government are canvassed

These concerns and ideas do not focus on Matters of NES protected under Part 3 of the EPBC Ac t and as suc h a re outside the sc ope of Guidelines for the Content of a Dra ft Environmenta l Impact Statement on the Proposed Temporary Weir at Pomanda Island near Wellington South Australia Environment Protection and Biodiversity Conservation Act 1999 (Reference Number 2007 3484) da ted 30 August 2007

However they are registered here because they reflect strong community positions

These concerns and ideas will be taken into consideration during the development of the long term plan for the Coorong Lower Lakes and Murray Mouth region The first step in developing the long-term plan was the release of the Directions for a healthy future document for public c omment during May 2009

Ngarrindjeri People

The Ngarrindjeri People provided a comprehensive submission in relation to the draft EIS A separate response will be provided to the Ngarrindjeri People in relation to those matters outside the scope of the EIS

One submission raised concern that Ngarrindjeri People has to compete for attention in the consultation process

An additional concern is that the Ngarrindjeri People is not recognised as Traditional Owners

The Coorong District Council emphasized that the Coorong and Lower Lakes have particular significance to the Ngarrindjeri and

Another submission (supported by the River Lakes and Coorong Action Group) stated tha t the Dra ft EIS d isp lays little or no understand ing of the importanc e of c ultura l flows to the Ngarrindjeri

Social and economic issues

A number of submissions noted the lack of content in the Draft EIS on social and economic measures associated with the temporary weir

Generally submissions from individuals organizations and local government indicate that the current social and economic conditions in the Coorong Lower Lakes and Murray Mouth area (as a result of drought lack of fresh water River flows and over allocation of water resources across the Murray-Darling Basin) are very negative When putting forward these concerns submission writers did not usually make clear how the construction of the temporary weir will further contribute to enhancing negative social or economic trends

A submission from the Southern Alexandrina Business Association Inc claims that the boating industry in the region under current conditions is losing $200 million per annum

A detailed submission from the Boating Industry Association of SA Inc claims that business of the leisure tourism and recreational sector and those that support them are suffering enormously from the existing droughtover allocation conditions The

Supplementary EIS for the temporary weir near Pomanda Island -39shy

submission proposes that we need to replenish water stocks including water for the environment Water for the Community and water for the EconomyTertiary Sector

The Rural City of Murray Bridge is concerned that professional fishermen can move up and down the River

The Coorong District Council notes that the dairy industry irrigated horticulture fodder production and beef cattle production have been negatively impacted by lack of access to water Property values have declined by 50 per cent in some cases and most of the 17 dairies in the Coorong District have closed or relocated Council rate revenue is down and

One submission (endorsed by other submission writers) provides a researched and extensive argument about the predominance of contemporary social and economic ideas which favour growth for example of expansionary plantings of a variety of unsustainable crops and growth of human populations and notes the South Australian population expansion in the South Australia Strategic Plan The writer suggests that new ideas about limitations and replenishments are required as well as a move towards adoption of tools like the Genuine Progress Indicator rather than reliance on indicators like Gross Domestic Product

Climate change

One submission asked for a rethink of the Draft EIS based on additional scenarios to the d rought sc enario whic h preva ils in the d ra ft EIS This sc enario is based is the worst

case climate scenario to date

Dust and health

A number of submissions raise concerns about current health problems caused by excess dust being blown from the dry lake bed

Other themes

A number of submissions a rgued tha t the temporary would nec essarily bec ome permanent and some of these argued that a navigable Lock with fish passages would therefore be preferable

A number of submissions argued for a seawater solution rather than a limited inflow to control the possible risks associated with ASS

Some submissions especially from government agencies or Non Government Organisa tions (NGO s) pointed out tha t further approva ls will be required in add ition to those cited in the Draft EIS The MDBA advised that it will require at least six weeks to undertake its approval processes from the time that the additional details are provided On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure

Supplementary EIS for the temporary weir near Pomanda Island -40shy

7 Suggested text changes errata additions clarifications and

references

Page Issue raised by submission(s)respondent(s)

Recommended changes

vi Page vi acid sulfate soils box last sentence should read See Chap ters 6 8 11 and 15 for d eta ils

Make suggested changes

115 Pg 1-16 section 152 Environment Protection Act 1993 The Environment Protection (Air quality) Policy could also be included in this section as it applies to potential dust and noise impacts

Reword sentence 1 paragraph 1 section 152 page 115 to read

The Environment Protection Act 1993 (the Environment Protection Act) and the Environment Protection (Air quality) Policy provide legislation for the protection of the environment and the establishment and definition of the powers and functions of the Environment Protec tion Authority (EPA) in South Austra lia

116

12

27

Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

Apparent inconsistency in water usage figures between Table 1-1 and pages 2-4 and 2-12

Pg 2-7 section 24 Red uc ed ra infa ll and

dec rea sed evapora tion should be increased evaporation (many of these inconsistencies throughout document)

Reference to Section 1554 should be changed to Section 15412 Acid Sulphate Soils Safeguards and Mitigation Measures and Table 15-6 titled Potential mitigation measures to manage acid sulphate soils

Appendix 1 question 91 provides clarification

Page 27 rep lac e text Red uc ed ra infa ll and d ec rea sed evapora tion with text Red uc ed ra infa ll and inc reased eva p ora tion

Supplementary EIS for the temporary weir near Pomanda Island -41shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

27 Issues raised concerning the accuracy of the data in Table 23 page 27

Update Table 2-3 to include the following

200607 Inflows

Total flow at the SA Border 1436 GL

Eastern Mount Lofty Ranges estimated inflow 39 GL

200607 Use and Loss

Net Loss(1) 1262 GL

SA Water pumped extraction(2) 245 GL

Irrigation Extraction(3) 377 GL

Total System Deficit -448 GL (4)

(1) Net loss is inclusive of evaporation seepage rainfall EMLR inflows unmetered diversions

(2) SA Water pumping from the River Murray includes 60 GL of water pumped to the MLR reservoirs for use in 200708

(3) note as in document

(4) Deficit is defined as Inflow at SA Border - losses - SA Water pumping - irrigation extraction and corresponds with the fall in water level in Lakes Alexandrina and Albert

2-13

213 219

215

References to 696 GLyr of dilution flow should be clarified

2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Pg 2-15 section 26 Current water level statement (-05m AHD) was incorrect at the time of EIS publication and should be updated and referenced

Appendix 1 questions 9 and 88 provide clarification

Reference to 940 GL on pages 213 and 219 should be changed to 896 GL

The water level in Lake Alexandrina is now at a new record low of -095 m AHD (reference Murray Darling Basin Authority Murray River System Drought update issue 18 APRIL 2009)

The MDBA drought upd a te sta tes tha t During winter in the absence of significant inflows reduced evaporative losses should allow the water level to remain fairly steady and even under a worst case scenario Lake Alexandrina is unlikely to reach the estimated acidification trigger of -15 m AHD prior to February 2010

Supplementary EIS for the temporary weir near Pomanda Island -42shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

215 The salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences

Delete Table 2-4 from the document It is not referred to in the text and therefore serves no purpose Add following text to section 26 para 3

Historic a lly Lake Alexand rina wa s a p red omina tely freshwater system with only brief periods of seawater intrusion during low outflow periods that did not extend beyond Point Sturt (Sim and Muller 2004) DEH is in process of contracting more work to The University of Adelaide to verify this understanding of the pre-European salinity regime of both Lakes Alexandrina and Albert by studying diatom species distribution in dated cores It is predicted that by May 2009 water in the Lake is expected to be at ~6000 EC (Figure 2-11) which is considered to be saline in terms of ecological func tiona lity (Williams 1986)

2-16 11-9 Section 1554 does not exist

The reference to section 1554 should read section 15412 Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant

334 Pg 3-34 Environment Protection (Water Quality) Policy 2003 The Environment Protection (Water Quality) Policy 2003 should be listed under legislation rather than policy section of this table

337 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

337 Pg 3-37 Table 3-5 The National Water Quality Management Strategy should be included in Table 3-5 as this is tool that is being utilised in this region for integrated catchment management to achieve improved water quality outcomes

349 Pg 3-49 Table 3-9 ASS and water quality the Centre for Water Research model should be grouped under this section together with EPACSIRO

4-4 Details and status of SA Water Corporation pump station upgrades

Update Table 3-4 beginning page 331 such that Environment Protection (Water Quality) Policy 2003 is listed under South Austra lian Leg isla tion instea d of und er Sta te Polic y and Pla nning Frameworks

In Table 3-5 Page 337 and anywhere else in the doc ument it is mentioned d elete referenc e to Na tiona l Ac tion Plan (NAP) and rep lac e with Caring for our Country (CFC)

Include National Water Quality Management Strategy in Table 3-5

In Table 3-9 inc lud e Centre for Wa ter Researc h a long with EPA CSIRO in row 3 c olumn 3

Upd a ted sta tus d eta ils of SA Wa ter Corp ora tion s pump station upgrades are provided in Appendix 1 question 14

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Page Issue raised by

submission(s)respondent(s) Recommended changes

442

5-8

510

517

61

Page 4-8 sta tes Costs for undertaking a similar ac tion for Ad ela id e s off takes from the Lower Murray are expected to be very significant (see table 4 3) and the implementation period would be approximately 3 yea rs from initia tion

58 states that once the water level exceeds +01m AHD the temporary weir will cease to serve any useful function

The last paragraph in section 542 should be rep la c ed with The fina l most viable solution may involve multiple rock types from multiple sources to achieve the optimum construction cost within the limited time frame Rock sources with clays fine silts and sands while suitably geotechnically may not be utilised to reduce the potential for environmental impact through turbidity and sedimentation

Insert the following for Section 563 Section 563 of the draft EIS only partially refers to the environmental safeguards and mitigation measures Section 563 should be ignored and Chapter 15 be referred to for safeguards and mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Management Plan (EMP)

Paragraph 1 page 6-1 needs to include rainfall on the Lakes as an input to the system

Delete reference to Table 4 3 from the document

Appendix 1 question 52 provides clarification

Page 510 make suggested changes

At the end of section 563 page 517 add the sentence

Chap ter 15 should b e referred to for sa feguard s a nd mitigation measures which includes the Environmental Management Framework (EMF) and Environmental Ma nagement Pla n (EMP)

Reword sentence 2 paragraph 1 page 61 to read

Freshwa ter from the River Murray the Eastern Mount Lofty Ranges (EMLR) catchments Upper South East (USE) drainage scheme direct rainfall onto the lakes and from groundwater as well as salt water from the Southern Oc ea n a ll input to the Coorong a nd Lower Lakes site

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Page Issue raised by

submission(s)respondent(s) Recommended changes

61 Last paragraph of 61 needs to include a further condition in the list - that of the MDB before the advent of white people as that is the condition that has determined which species live amp belong here

For the sc ope of the d ra ft EIS the baseline c ond itions of the CLLMM are those that existed when the site was listed as a wetland of international significance under the Ramsar convention These conditions are discussed in the Ecological Character Description (ECD) for the site (Phillips and Muller 2006) The draft EIS correctly uses the ECD as a baseline regarding condition It should be noted that many parameters that describe the conditions of the CLLMM are currently beyond the acceptable limits of change as outlined by the ECD due to drought and over-allocation of water

63 Issue raised concerning wording of paragraph 4 page 63

63

65

Issue raised concerning impact of static water levels page 63

Issue raised concerning Barra ge Opera tion Page

65

Change text in paragraph 4 p 6-3 to read

Aquatic vegeta tion has sinc e declined due to static water levels such that only a fringing band of vegetation around the +03 to +06 m AHD water marks remains of the extensive submerged and emergent beds that extended several kilometres into the Lakes pre-European settlement (Sim and Muller 2004)

Remove first bullet point under Figure 6-1 d egra d ed shorelines in sheltered a rea s

Add text below as a new fourth and fifth paragraph under barrage operation (p 6-5)

The b a rrages impede ec o log ic a l c onnec tivity between the fresh estuarine and more saline parts of the Ramsar Of particular concern are the adverse impacts on fish migration and transfer of recruits from one part of the system to another Fish passages have been installed on some gates to facilitate fish movement during periods of barrage opening and the Barrage Operating Strategy seeks to optimise ecological outcomes with each barrage release

The Lower Lakes barrages have not been opened since October 2006 thus there has been no hydrological connectivity between the fresh and estuarinesaline a rea s of the Ramsar site sinc e then

66 Issue raised concerning Ripa ria n La nd

Ma nagement page 66

Add text below as second paragraph under Riparian land management (p6-6)

Inva sion of pest p la nts a nd a nima ls into the wetland s is also a major issue particularly given the close proximity of the agricultural land and the large expanses for wind and water borne weed s to b e d ispersed

69 Issue raised concerning keystone species listed on page 69

Change text in second bullet point under the keystone species for freshwater lakes include (p 6-9) to read

Assemb lages of emergent p la nts (eg Sc hoenop lec tus sp Baumea sp Phragmites australis) along the fringes of the lake and EMLR tributa ries

Supplementary EIS for the temporary weir near Pomanda Island -45shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

610 Issue raised concerning list of factors that influence aquatic plants bottom of page 610

Reword the statement at the bottom of page 6-10 of the Draft EIS with the following

Ganf (2000) identified four issues influenc ing the productivity distribution and community composition of macrophytes

salinity

turbidity

water regime and

wind and wave action

These factors combined mean that submerged aquatic plant growth is restricted to the littoral zone of the mod ern lake environment (Phillip s and Muller 2006)

612 Issue raised concerning wording of caption for Figure 66 page 612

612 Issue raised concerning section 63 page 612

614 A Respondent questioned page 6-14 section 65 of the Draft EIS determinants or drivers

72 73 Bool amp Hacks Lagoons are not upstream of this temporary weir as is implied in the text

74 Page 7-4 section 733 An error messages appears

75 736 Type M permanent rivers streams amp creeks -Lake Alexandrina also takes the flow from the Rivers Angas amp Bremer amp Mosquito Creek between Milang amp Langhorne Creek

Pg 6-12 Figure 66 c ap tion should rea d d rivers a nd levers (not d rivers and levels )

Section 63 shy Pg 6-12 Include the following text as sentence 2 of paragraph 3

Direc t ra infa ll on the lakes a nd evapora tive losses a re key components of local climate that have the potential to impact greatly on the resultant water reg ime of the site

Sec tion 65 first p a ra graph rep lac e The p rima ry d rivers for ecological character includ e with The p rima ry determinants of ecological character are (Phillips and Muller 2006)

Reword sentence 1 paragraph 2 section 73 page 72 as follows

Banroc k Sta tion Wetla nd Complex Riverland wetla nd s and Hattah-Kulkyne Lakes are located more than 200 km (minimum) upstream of Pomanda Island and are unlikely to be a ffec ted by the temporary weir

Following sentence 1 add additional sentence

Bool and Hacks Lagoons are located outside of the MDB and over 200 km from Pomanda Island and will therefore b e una ffec ted b y the temp ora ry weir

Rep la c e text Error Referenc e sourc e not found With text Figure 7-2

The Rivers Angus and Bremer and Mosquito Creek are classified as wetland Type N -seasonalintermittentirregular riversstreams and creeks These tributaries should be referred to in Section 737 of the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -46shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

731 756 Plant associations in close proximity to the temporary weir Only one of the 11 dot points is actually a plant association

Reword the sentenc e The p lant a ssoc ia tions in c lose p roximity to the temp ora ry weir site inc lud e to read

The d ominant or c o-dominant plant species in close proximity to the temp ora ry weir site inc lud e

Replace dot point Muehlenbeckia florulenta tall open shrub land with Phra gmites a ustra lis with two d ot points

Muehlenbec kia florulenta

Phra gmites austra lis

732 Page 205 - Table 7-6 should be checked for accuracy Cattle Egret is not EPBC listed migratory species

According to the EPBC Act website Cattle Egret is a listed migratory species therefore its listing in Table 7-6 is correct See

httpwwwenvironmentgovaucgishybinspratpublicpublicspeciespltaxon_id=59542`

Chapters 4 and 9

101

102

102

Text in the executive summary chapters 4 and 9 erroneously includes the use of toxins when the intended meaning is in fact toxicants Toxins are substances produced by living cells such as algal toxins etc whereas toxicants are a broader range of chemicals that produce a toxic response in living organisms

Correct the assertion in 102 Existing drought conditions that the dropping of Mungkuli (Lake Alexandrina) to below sea level for the first time in 7500 years is due to drought

Chapter 10 - Figure 10-1 -Lake Alexandrina water level 1962-2008 Full supply level = +075m AHD - EIS is incorrect

Tookayerta Creek is a tributary of the Finniss River and not Lake Alexandrina as stated Further the Finniss River and Currency Creek flow into the Lower Murray not into Lake Alexandrina

Delete the word toxins from c ha p ters 4 a nd 9 and rep la c e with the word toxic a nts

Change sentence to read

In rec ent times the wa ter level in the River Murray Coorong and Lower Lakes has been significantly lowered by the existing drought conditions and over-allocation of water associated with the entire MDB (Table 10 1)

It is the proponents understanding that +075 m AHD is referred to as full sup p ly level and tha t wa ter levels above this a re referred to as a surc ha rge

Reword sentenc e The EMLR tributa ries tha t d isc harge into Lake Alexand rina a re to read The EMLR tributaries that discharge into Lake Alexandrina and the Lower Murray a re

Delete d ot point Tooka yerta Creek from the bottom of page 10-2

Reword d ot point Finniss River to rea d Finniss River (inc lud ing Tookayerta Creek)

Supplementary EIS for the temporary weir near Pomanda Island -47shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

104

1013

1030

1030

Figure 10-3 Goolwa amp Lake Alexandrina Salinity Survey results - September 2008 EIS in error re the salinity level of Lake Albert This figure 10-3 states that 7300EC (which is approx

sea wa ter) is semi-saline

1035 - Predicted water level in Lake Alexandrina -water levels are also affected by rainfall which is not mentioned

To say that potable water supply is less than 2500EC is pushing the boundaries PIRSA documents state a salinity of 1000mgL (1666EC) is generally palatable to most tastes but up to 1500mgL (2500EC) can be acceptable in areas where better quality water is not available

The tolerable salinity limits for freshwater species needs to take into account peak levels not average levels

The d efinition of semi-sa line is p rovid ed in Tab le 2-4 of the draft EIS and refers to salinities between 5001 and 11666 EC Thus the document is consistent

Reword first sentence of Section 1035 as follows

Historic a lly wa ter levels in La ke Alexand rina have varied on a seasonal basis with water rising in winter through increased winter inflows direct rainfall and decreased evaporation and falling in summer through red uc ed inflows a nd inc reased eva p ora tion

This point is noted however it has no bearing upon the temporary weir since salinities in Lake Alexandrina are predicted to reach gt2500 EC throughout the lake during 2009 with or without the temporary weir

In Section 1043 (page 10-30) delete paragraph 3 since it has no biological or ecological relevance Revise paragraph 4 to read

Pea k or maximum sa linities a re most important ecologically because all aquatic species have salinity tolerances that if exceeded even briefly can be fatal Table 10-9 presents modelled peak salinities at points in Lake Alexand rina und er without weir and with weir scenarios during the first year of weir operation For all points modelled peak salinity in the first year is higher und er the with weir sc ena rio

10-32 Reference to 685 GL as extra water available is misleading

Agreed Clarified in Appendix 1 question 32

Supplementary EIS for the temporary weir near Pomanda Island -48shy

a ns

Page Issue raised by

submission(s)respondent(s) Recommended changes

1113 Pg 11-13 Figure 11-5 This graph could be updated to 2009 using current EPA data

Update Figure 11-5 on page 11-13 with the following which includes the most recent data

Turbidity Lake Alexandrina - Poltalloch Plains

20

40

60

80

100

120

140

160

180

200

24-Jul-98 6-Dec-99 19-Apr-01 1-Sep-02 14-Jan-04 28-May-05 10-Oct-06 22-Feb-08 6-Jul-09

Date T

u rb

id it

y (N

T U

)

Lake Alexandrina - Poltalloch pl i Ecosystem protection guideline (ANZECC)

0

121 Section 121 It is certain that the temporary weir will interact with ecological values of lower river amp lakes

121 Pg 12-1 section 122 Bottom of page 12-1 In general temporary wetlands have few animal species than permanent ones is this referring to abundance or richness or what Too general and incorrect in some circumstances

122 Chapter 123 - Ramsar listed wetland upstream of expected weir site near Pomanda Island - EIS incorrect amp needs amendment

Delete the word may from sentenc e 1 p a ra grap h 3 section 121 page 121

Bottom of page 12-1 delete the following sentenc e In general temporary wetlands have fewer animal species than p ermanent ones

On pg 12-2 rep lac e the text There a re no Ra msar-listed wetla nd s between Loc k 1 a nd the temp ora ry weir site with the following There a re no Ramsa r-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ra msar site

Supplementary EIS for the temporary weir near Pomanda Island -49shy

Page Issue raised by submission(s)respondent(s)

Recommended changes

125 Issues raised concerning wording of Table 123 commencing page 125

In Table 12-3 make the following changes

For Cla ss M ad d text to sixth c olumn Inc reased hea d pressure may result in increased drainage to the lakes and reduced groundwater baseflow in groundwater depend ent ec osystems

For Class M seventh column change existing sentence to read there is no interac tion of the weir with the surfa c e wa ter in these wetlands

For Class M add sentence to third column that reads Inc reased head p ressure of up to 21 c m may result in

c hang e in ground wa ter b a seflow

For Cla ss 4 und er Imp a c t of p roposed tempora ry weir within Ramsar wetla nd s to existing text ad d whic h oc c urs a t wa ter levels gt 087 m AHD

For Cla ss Xf und er Existing c ond ition (a p p roxima tely shy05 m AHD) rep la c e No rec ord ed c ha nge with Not connected to the main body of the lake Will only be a ffec ted b y ongoing d rought

For Cla ss Tp c hange text in sixth c olumn to read Most disconnected but some reconnection and marginal improvement from winter ra infa ll and tributa ry inflows

Formatting issue in title of sixth column the negative is there in the column heading but there has been line split between it and 15 so it looks like +15 m AHD not -15 m AHD (should be latter)

1215 Issue raised concerning wording of Section 125 page 1215

Reword Section 125 (pg 12-15) in its entirety to read

As d eta iled in Sec tion 1241 a ll wetland hab ita ts downstream of the proposed temporary weir location are expected to be affected by the drought and by 2012 only Ramsar-wetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flows as described on page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

1216 Issue raised concerning potential positive impact of rewetting of acid sulphate soils

Section 1251 page 1216 remove reference to re-wetting of acid sulfate soils and pH drop to 2 (last dot point) from positive impacts list

Supplementary EIS for the temporary weir near Pomanda Island -50shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

12-20 Table 12-4 only lists predicted changes for 2 out of 6 primary determinants of ecological character

Update Table 12-4 to include the following

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts

(2010 2012)

Salinity Discussed extensively in Section 10

Water Level Discussed extensively in Section 10

Water Regime Discussed extensively in Section 10

Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

1310 Issue raised concerning comprehensiveness of Table 133 page 1310

To Table 13-3 insert two additional rows

1st c olumn Intera c tion 2nd c olumn Disrup t d ispersa l of tadp oles

1st c olumn Spec ies p referenc e 2nd c olumn Present upstream and downstream of site but dispersal requirements of d ifferent p op ula tions a re unknown

141 Section 141 What is the definition of regularly recorded amp by whom were they recorded

In sec tion 141 p a ge 141 p a ragraph 4 rep lac e (see Chapter 7) with (Letc h 2007)

1519 pg 15-19 section 15412 Performance criteria The acid sulfate soil trigger levels are given in Table 15shy6 not Table 15-5 as stated in the document

In d ot p oint a t bottom of page 1519 rep lac e Tab le 15shy5 with Tab le 15-6

1519 Remove Table 15-5 There are no cross-references to the table

Table 15-5 is referred to on page 1519 and should be retained in the document

162 The summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Additional comment o be inserted in Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir) after text

The ECD of the Coorong and Lakes Alexa nd rina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Nationally listed threatened and migratory species are addressed elsewhere in this table Other species are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetla nd s will persist

Supplementary EIS for the temporary weir near Pomanda Island -51shy

Page Issue raised by

submission(s)respondent(s) Recommended changes

Throughout document

Throughout document

Throughout document

Australia operates on SI system of measurements amp this includes the millimetre metre units of measurement amp does not include centimetres

Convert centimetres to millimetres or meters as appropriate throughout the document

Correct injustice throughout draft EIS of identifying Ngarrindjeri merely as custodians community or people (112 164 165 171 1522)

Cha nge Ngarrind jeri c ustod ians and Nga rrind jeri c ommunity to Ngarrind jeri Peop le as ap p ropria te

throughout the document (as per submission PTW00046)

Text in the executive summary and throughout the document (chapters 1 2 4 8 11 12 13 15 and 16) refers to the use of the wording heavy metals when in fact this is misleading and should simply be referred to as metals

Rep la c e a ll referenc es to hea vy meta ls with meta ls

Supplementary EIS for the temporary weir near Pomanda Island -52shy

References

Bice C and Ye Q (2009) Draft Report - Risk assessment of proposed management scenarios for Lake Alexandrina on the resident fish community South Australian Research and Development Institute (Aquatic Sciences) Adelaide South Australia

DWLBC (2009) River Murray Data Department of Water Land and Biodiversity Conservation Adelaide South Australia httpdatarivermurraysagovau

Wellington Weir Site Flora and Fauna Assessment (South Australian Water Corporation Adelaide South Australia) Ecological Associates (2008) Draft Report

Ganf G G (2000) Aqua tic and ripa rian vegeta tion in A Jensen M Good P Harvey P Tuc ker amp M Long (eds) River Murray Barrages Environmental Flows An evaluation of environmental flow needs in the Lower Lakes and Coorong report to MDBC pp 30 34

Khan M T Khan T A and Wilson M E (2004) Habitat use and movement of river blackfish (Gadopsis marmoratus R) in a highly modified Victorian stream Australia Ecology of Freshwater Fish 13(4) 285-293

Lintermans M (2007) Fishes of the Murray-Darling Basin An introductory guide Murray-Darling Basin Commission Canberra ACT

Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks (Oxford University Press Melbourne)

Williams WD (1986) Conductivity and salinity of Australian Salt Lakes in Australian Journal of Marine and Freshwater Research 37177-182

Supplementary EIS for the temporary weir near Pomanda Island -53shy

8 Appendix 1 Issues Raised by the Department of the Environment Water Heritage and the Arts (DEWHA)

General comments

1 Lots of inconsistencies particularly in figures Several of these are the result of some sections of the EIS having been updated to reflect the current environmental conditions but not others however some are just contradictions

Response Inconsistencies are corrected in the Supplementary EIS

2 In general at -15m AHD many wetland types will have already disconnected so the weir will not cause further impacts but it will slow down any potential recovery from drought impacts Please discuss and quantify these implications

Response The temporary weir will cause a 17cm drop in Lake Alexandrina water levels during the weir pool filling period under modelled worst-c ase sc enario however in the longer term there is little difference in the water levels and salinity values between weir and no weir sc enarios Quantific a tion of the amount of wa ter tha t would be

needed to refill desiccated Acid Sulfate Soils remains a knowledge gap that could be filled through field trials

3 There is a general lack of detail on what measures will be used to mitigate impacts on species (eg on pg 13-6 it says measures should be taken to ensure the wetland vegeta tion and assoc ia ted c ommunities a re not c ompromised without going into any further detail) Please review any proposed measures and provide details and commitments to undertake measurable actions

Response Detailed measures will be written in the CEMP OEMP and DEMP by SA Water The d ra ft EIS EMF and EMP outline wha t SA Water s EMP s should add ress

expec ted etc Please clearly state where you are committing to do something A table showing actual commitments would be useful

4 Vague and uncommitted language throughout the whole document

Response The South Australian Government is committed to the following actions in relation to the weir near Pomanda Island

Development of a CEMP OEMP and DEMP and submission of the EMP to relevant authorities including the SA EPA prior to any works being undertaken Incorporation of a fishway to suit large and small species A detailed submission to the MDBA for approval under the Water Act 2007 (Cwth) On 30 June 2009 the MDBA approved plans for the temporary weir on the understanding that a rock fishway will be included and any significant erosion or settlement of the spillway section will be addressed throughout the life of the structure to ensure the continuing integrity of the structure Mitigation strategies and monitoring program as detailed in the EMP and in the amended Table 15-3 (see question 5 below) o The CEMP will be based on a risk management framework and an

environmental impact assessment (EIA) o Monitoring of water quality will be included in a water quality report to be

made available through the SA EPA

Summary of SA Govt projects in the Lower Lakes Coorong and Murray Mouth

A summary of all projects follows Projects highlighted in green are completed or currently underway Orange highlighted projects are those currently being investigated and are likely but not certain to be undertaken Pink highlighted projects are those either in the early stages of planning and may be difficult to implement or are considered only a last resort solution due to other undesirable implications

Supplementary EIS for the temporary weir near Pomanda Island -54shy

Project StatusTiming Completed or Underway

Pipelines Potable Lower Lakes districts Irrigation Langhorne amp Currency Creeks

Potable construction completed January 2009 Irrigation EPBC referral (20094743) not controlled action if undertaken in particular manner due for completion October 2009

Feasibility study Long term management plan for adaptive management

30 March 2009 - Version 1 - under review prior to public consultation May 2009 Public Consultation on Version 1 30 June 2009 - Version 2 August - public consultation on Version 2 30 September 2009 - Final

Lake Albert Blocking bank in Narrung Narrows Pumping from Lake Alexandrina Lake Albert Future paper Pumping ceases 30 June 2009 Bioremediation

Blocking bank completed in May 2008 Pumping began 02 May 2008 Expert workshop held 8 April 2009 Paper prepared On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from the end of June 2009 and that a bioremediation program will be instituted

Dredging Murray Mouth Ongoing almost continuous operation since October 2002

The Living Murray (TLM) Icon Site management Icon Site condition monitoring Modelling Indigenous partnership Communications and consultation Water bids

Coorong planning document completed TLM progress report sea level impact assessment and alternatives to keep Murray Mouth open underway Condition monitoring ongoing Monitoring methodology plan completed sent to MDBA Modelling Stages 1 2A completed 2B December 2009 Interim modelling results for LLCMM due June 2009 Indigenous partnership program ongoing

Regulators Goolwa Channel Mouth of Finniss River Mouth of Currency Creek

EPBC referral submitted for public notice on 6 April 2009 Initial closure of the regulators 17 July 2009 Commencement of pumping water from Lake Alexandrina to Goolwa Channel 17 July 2009 Practical completion of the regulator within the Goolwa Channel 17 Sept 2009

Assessment of acid sulfate soils Rapid Risk Assessment Lock 1 to Wellington

Fieldwork for both completed Laboratory analysis underway completed for 24 priority wetlands below Lock 1 Survey work and modelling undertaken on inlets to 24 priority wetlands below Lock 1 Identification of priority sites creation of an action plan and application for funding underway

Lower Murray Reclaimed Irrigation Areas (LMRIA) Program

Completion of Program by June 2009 Completion of all mandatory works achieved 2008 Non-mandatory works nearing completion Post-program review to be instigated in near future

Upgrade of Pomanda Peninsula Causeway

EPBC Referra l not a c ontrolled ac tion 23 January 2009 Works currently underway in preparation should it be necessary to construct the temporary weir

Currently Being Investigated

Mitigation of acid sulfate soils using Mulch Revegetation Liming

Trials for all three currently underway Large scale application dependent on trial results and acidification time of the lower lakes

Supplementary EIS for the temporary weir near Pomanda Island -55shy

Project StatusTiming Increase inflows to Coorong South Lagoon REFLOWS Upper South East Drainage scheme (USED) water via Salt Creek Fairview Drain link

REFLOWS funding available REFLOWS cultural heritage underway REFLOWS native vegetation assessment almost complete REFLOWS landholder consultation complete REFLOWS community perceptions survey complete USED second stage feasibility study due 30 June 2009 USED 3 to 4 years to investigate and then implement Fairview initial landholder engagement commenced on hold until Reflows and Bald Hill decision made

Temporary Weir near Pomanda Island Draft EIS released for public consultation Supplementary EIS in progress Construction works to begin if Lake Alexandrina levels drop to -15 m AHD Could be avoided if sufficient freshwater flows obtained Early Planning Stages

Salinity build up in Coorong South Lagoon Dredging between north south lagoons Pump hyper-saline water to ocean

Both under preliminary investigation Pumping could only be done during autumnwinter to allow flows to replace pumped out water hence may not happen till 2010

Seawater intrusion into the lower lakes As a last resort to mitigate acid sulfate soils

EPBC referra l (EPBC 2008 4618) c ontrolled ac tion requiring EIS The final guidelines for the EIS released 13 March 2009 EIS targeted September October 2009

The projects can be divided into three categories

1 Long term plans looking to address the bigger picture with sustainable solutions Projects such as

Potable pipelines around lower lakes districts Irrigation pipelines Langhorne and Currency creeks Feasibility StudyLong Term Plan for Adaptive Management for CLLMM Lake Albert Future paper The Living Murray (TLM) programs Lower Murray Reclaimed Irrigation Areas (LMRIA) Program REFLOWS Upper South East Drainage scheme (USED) water into the Coorong via Salt Creek and Fairview Drain to Coorong link

2 Emergency measures designed to mitigate urgent issues with severe impacts Most are not long term and are designed to address a specific issue

Blocking bank in Narrung Pumping from Lake Alexandrina to Lake Albert2 Dredging Murray Mouth Goolwa Channel regulator Finniss River low level regulator Currency Creek low level regulator Pump water from Lake Alexandrina to the new temporary pool created in the Goolwa Channel Rapid Risk Assessment of acid sulfate soils Assessment of acid sulfate soils from Lock 1 to Wellington Mitigation of acid sulfate soils

2 On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease on 30 June 2009

Supplementary EIS for the temporary weir near Pomanda Island -56shy

o Bioremediation using mulch o Bioremediation using revegetation o Liming of exposed lake beds and o Liming of inflows

Salinity build up in Coorong South Lagoon o Dredging between north south lagoons and o Pump hyper-saline water to ocean

3 Last resort emergency measures only to be undertaken at critical trigger points when all other alternatives have been exhausted

Temporary weir near Pomanda Island Seawater intrusion into the Lower Lakes

Further details on each project are available if required

5 In several places throughout Chapter 15 monitoring is proposed as a mitigation measure by itself monitoring does not mitigate an impact it can only help inform when to implement a mitigation measure Please provide an actual mitigation response linked to monitoring

Response The Environmental Management Plan in Chapter 15 of the Draft EIS has been augmented in the Supplementary EIS SA Water is responsible for preparing the CEMP OEMP and DEMP Environmental Management Plan that will detail the mitigation strategies and monitoring program This will be written in conjunction with the contractor

SA Water will be responsib le to ensure tha t the c onstruc tion c ontrac tor s EMP inc ludes adequate monitoring protocols for water quality and other environmental issues throughout the construction phase The EPA DWLBC SA MDB NRMB NVC local council and other relevant agencies will be consulted on the content of any environmental risk assessment and mitigation measure In addition specific State approvals will be obtained these usually stipulate specific conditions to be included in an EMP or similar management tool

The Contractor EMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

See also 80

Table 15-3 has been amended

Table 15-3 Potential mitigation measures for water quality parameters

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Develop and implement a Soil Erosion and Drainage Management Plan in accordance with the Stormwater Pollution Prevention Code of Practice for Local State and Federal Government

Works are expected to be planned and carried out to minimise the effects of runoff and erosion on the site and downstream areas

Surface water quality

Ensure that erosion and sediment control measures are in place prior to commencing any earthworks

Supplementary EIS for the temporary weir near Pomanda Island -57shy

Project PhaseParameter Potential mitigation measure

Co

nst

ruc

tion

Op

era

tion

De

co

mm

issi

on

Sediment control structures are expected to be established around all areas prone to erosion including stockpiles batters and drainage lines Careful placementremoval of embankment material to reduce turbidity

Scouring mud waves and bank slump are a potential consequence of installation of the temporary weir Scouring and mud waves may be reduced by controlling flows and spillway width while area of impact associated with bank slump is expected to be reduced by weir design and careful placement of embankment materials

Use of sediment curtains around weir placementremoval to limit effects of turbidity created with placement of material and subsequent mud-wave Stabilisation of River banks immediately following constructiondecommissioning Treatments may include

Revegetation

Placement of geofabric

Obtain EPA Endorsement of the proposed approach to surface water

Exception to allow placement of fill material to create weir structure

Wetland management Develop and implement a Wetland Management Plan to manage the change in flow patterns resulting from the construction operation and decommissioning of the proposed temporary weir

Develop and implement a Groundwater Management Plan for the project

Groundwater

Groundwater is expected to be monitored throughout the construction operation and decommissioning phases of the temporary weir project

Groundwater parameters which may require monitoring include

Confined and unconfined water levels

Salinity

Hydraulic gradient

Supplementary EIS for the temporary weir near Pomanda Island -58shy

Project PhaseParameter Potential mitigation measure

Monitoring is expected to take place both upstream and downstream of the temporary weir

Existing monitoring programs which may be relevant include

DLWBC OBSWELL database

RMCWMB groundwater monitoring program

CSIRO Water for a Healthy Country

Obtain endorsement of the proposed approach to groundwater monitoring from DWLBC andor the EPA

Develop and implement a water quality monitoring program based on existing programs and monitoring stations

Monitoring

If water quality parameters are exceeded the following measures may be implemented

Increase use of geofabrics and turbidity curtains to address inadequacies in turbidity management

Cease work if turbidity if triggers are exceeded until such time as the triggers return to desired levels

Aeration should monitoring indicate that oxygen is required

Mixing to prevent temperature stratification of weir pool

Mixing aeration to prevent temperature stratification of weir pool

Co

nst

ruc

tion

Op

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tion

De

co

mm

issi

on

6 The extent of the Ecological Character (EC) of the Ramsar site is greater than the fringing Wetlands It includes the bodies of water in the lakes the species in on and above Although the individual aspects of the EC are mostly noted in the EIS the summary of impacts in Table 16-1 needs to be updated to consider other relevant aspects of the EC rather than just fringing wetlands

Response Additional comment o be inserted in Errata Chapter Table 16-1 Row 1 (Wetlands of international importance) Column 3 (Proposed Temporary Weir)

The ECD of the Coorong and Lakes Alexandrina and Albert Ramsar site lists a number of plant amphibian bird and fish species that contribute to the Ramsar status of the site (table 4 5 6 amp 7 of ECD) Those species that are not listed nationally are unlikely to be impacted by the proposed temporary weir At weir closure only wetland type O remains connected and habitats associated with these permanent freshwater wetlands will persist

7 Is it likely that the water body of Lake Alexandrina will acidify during the no-flow period given the drop in water level If so how does SA propose to manage this Does this mean that the weir closure period will bring the real time management strategy water level acidification trigger forward

Response See page 22 and 23 of the Supplementary EIS

Supplementary EIS for the temporary weir near Pomanda Island -59shy

The South Australian Government is investigating and implementing a range of acid sulfate mitigation measure including application of limestone and bioremediation The possible use of seawater is also being examined (EPBC Act reference 20084618 and an EIS is currently being prepared Introduction of seawater will only be undertaken if the temporary weir is in place the acidification triggers are reached and relevant approvals in place

Water quality monitoring in Lake Alexandrina (eg at -10 m AHD) indicates alkalinity is high (between 170 and 250 mgL as CaCO3) which means the water has relatively good buffering capacity depending on the transport of acidity (fluxes) from exposed sediments During periods of no flow pulses of acid can be transported to the water by rainfall or seiching (wave action) events However given that sulfuric materials have already formed over large areas the higher risk of acidification comes with refilling of the waterbody when mineral salts can be dissolved and acidic porewater can diffuse into the water column (note some research indicates this could occur with freshwater or saltwater ingress)

Management trigger levels for alkalinity and pH have been developed and trends are being monitored fortnightly If any of the trigger levels are approached (ie at different alert levels) the Government of South Australia will instigate certain actions such as monitoring at a higher frequency or implementing limestone slurry dosing programs

The biogeochemical modelling points to waterbody acidification at either a pH less than 6 or water levels below -15 m AHD Further refining of the modelling and investigations of sulfide oxidation rates and acidity transport are being undertaken and early indications are that waterbody acidification is more complex than relating it just to water level As such the weir closure period may not necessarily bring forward Lake Alexandrina acidification

8 The EIS states there will be a number of plans that do not appear to be available yet it is difficult to assess the effectiveness of mitigation without seeing these plans When will these be provided

Response Development of plans and actions is ongoing Response to 4 above lists many of these including the Long Term Plan Many plans have been provided to DEWHA as they are prepared

9 The EIS indicates that disconnection is likely to occur for 2-35 months even though under worst case scenarios it could be up to 7 or 8 months (Table 10-6) The EIS assessment is based on no flow period of 3 months Is the reason for this because SA is currently receiving 896GL over the border and they anticipate getting at least this amount in the 2009-2010 water year and subsequent years Or is there other justification for the reasons for using 25-3 month disconnection This difference in time period could change the likely impacts on hydrology and water levels which are key determinants of ec olog ic a l c harac ter DEWHA s assessment will take into ac c ount the worst case scenario

Response South Australia is now guaranteed a flow of at least 896GL during 2009-10 as the 200GL required for Critical Human Needs has already been secured and is held in reserve Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream The estimated time for disconnection for the 696 GL scenario is not relevant

The Errata chapter includes replacement of references to 940 GL with 896 GL on pages 2-13 and 2-19 of the Draft EIS

The time required to fill the weir pool from approximately -15m AHD to +01m AHD will be approximately 25 3 months If it is necessary to fill the weir pool more slowly (eg to minimise damage to upstream wetlands banks and levees) the flow at Lock 1 will not be reduced and any additional water will be delivered into Lake Alexandrina through a by-pass structure

10 As specified in 1(g) of the EIS Guidelines can you please detail the interaction between this action and others in the CLLAMM

Response Discussed at 4 above

Supplementary EIS for the temporary weir near Pomanda Island -60shy

11 In Part 3 of the EIS Guidelines you are required to take into account the long-term options for the CLLAMM While the Department acknowledges the actions that are being undertaken to develop a long term solution how will this action limit long term options

Response As discussed in the Supplementary EIS South Australia considers that the weir if constructed will not limit long term options Long term options are being actively planned in the knowledge that the temporary weir may be constructed

12 Section 11 of the EIS Guidelines require the objectives of the EPBC Act to be addressed Can you please provide further information addressing these objectives

Response The Draft EIS endeavoured to address the Guidelines for the Proposed Temporary Weir This Supplementary EIS supplements this by the addition of the community consultation report and a detailed review of issues raised

The response to question 4 details all related actions that the government is taking in the Coorong and Lakes Alexandrina and Albert Ramsar site including the development of a comprehensive long term environmental plan that shortly will be released for community consideration

Objects of the EPBC Act

(a) In the face of unprecedented environmental degradation of the Ramsar site and matters of national environmental significance caused by low freshwater inflows we are undertaking substantial conservation and remediation work involving many South Australian Government agencies These are outlined in the Supplementary EIS

(b) (c) (d) Further specific actions to conserve natural resources and bio-diversity are likely to be announced shortly in conjunction with the Australian Minister for Climate Change and Water It is expected that majority of these actions will be undertaken by local government the community land holders and the Ngarrindjeri People

(e) As the South Australian agency responsible for the Environment and Heritage and one of the custodians of the internationally listed Ramsar site the Proponent seeks to c oopera tively imp lement Austra lia s interna tiona l environmenta l responsibilities

(f) (g) The South Australian Government acknowledges the Ngarrindjeri People as traditional owners within the area of their current Native Title Claim within the context of the Aboriginal Heritage Act 1988 The Ngarrindjeri People collectively and individually have been consulted and given an opportunity to comment on the Draft EIS along with all other stakeholders and members of the c ommunity The State Government is endeavouring to develop a formal overarching agreement with the Ngarrindjeri in relation to consultation and negotiation on a range of environmental and cultural matters of joint interest

Work with Aboriginal people to manage biodiversity cooperatively and contribute to the reconciliation of past actions

Comments on ESD are included at question 25

More specific comments

13 NAP ceased on 30 June 2008 and has been superseded by Caring for our Country (pg 3-37)

Response Noted Corrected in Errata

14 On pg 4-4 it says that 3 of the 4 pumping stations are complete with only Murray Bridge to be completed but in Table 4-4 on the same page and on pg 2-3 it says Swan Reach is the only pumping station still to be completed

Response Mannum and Tailem Bend are complete Swan Reach was completed late December 2008 Murray Bridge has 2 pumps modified for lower water level operation but we are delaying some work on one pump at Murray Bridge in order to test it (unshymodified) in order to be better able to confirm the lower limit of operation

DEH s Corp ora te Plan inc lud es the objective

Supplementary EIS for the temporary weir near Pomanda Island -61shy

15 Orange-bellied Parrot sec tion 752 doesn t mention samphire hab ita t

Response Firstly in the history of documentation relating to this EIS on the preferred habitat of the Orange-bellied Parrot There appears to have been some confusion over the use of the words saltmarsh and samphire

Samphire is used interchangeably in South Australia to describe

a) species in the genera Sarcocornia and Tecticornia (formerly Halosarcia and Sclerostegia) and

b) habitat dominated by such species

Thus saltmarsh and samphire are interchangeable terms to describe the same habitat

Food plants associated with samphire (or saltmarsh) habitat are certainly known to be used as feeding habitat by the Orange-bellied Parrot in the lower lakesupper Coorong with recent records from this habitat from the Snake Pit (Tauwitchere Point) and Sir Richard Peninsula (Beacon 19) in recent years (06-08) predominantly from Sarcocornia

However it appears that within South Australia the Orange-bellied Parrot is less dependent than previously suspected on samphire vegetation Recent observations in South Australia (2003-) suggest that the species shows a stronger preference for non-halophytic habitats and more commonly pasture plants and weeds in modified environments

While most records are within 10km of the coast Orange-bellied Parrots were recorded in winter in the Tolderol area (north-western shore of Lake Alexandrina) between 1981 and 1985 (John Eckert sightings lodged with Birds Australia) and there is an anecdotal record of this species foraging in the Wellington area at Nalpa Station

In the referral for the Pomanda Island causeway (EPBC 4676) it is stated that the Causeway upgrade could at worst disturb less than 014 ha of samphire shrubland With 1289 ha of this habitat within the Ramsar boundaries the maximum loss of samphire species would be 001 In addition Ecological Associates (2008) identify that samphire species regenerate relatively quickly after disturbance

16 The Great Egret Cattle Egret and the Caspian Tern are not dealt with satisfactorily (pp 7-3334)

Response The Great Egret is distributed widely in low abundances throughout the fringing habitat of the wetlands lakes and channels The movements of the species are dispersive however some regular seasonal movements are suspected The species forages by wading in shallow water or wet substrates and will frequent a range of wetland types either fresh or saline

The Cattle Egret is widely distributed across Australia where it will regularly forage away from water on low-lying grasslands and on pasture The range of the species is thought to be slowly expanding and is favoured by clearing of wooded lands and conversion to pasture The species is occasionally seen around Lake Alexandrina (Letch 2007) but its presence is more directly linked to the favourable habitat created by the adjacent agricultural activities The species is thought to be a partial migrant birds wintering in southern Australia apparently originate from breeding colonies in SE Qld and NE NSW (HANZAB3)

The movements of Caspian Tern are poorly understood partly resident partly dispersive and possibly partly migratory (HANZAB1) The species is commonly observed on fresh and marine waters foraging on the wing for fish

17 The potential decommissioning impacts (pg 8-7) says tha t The impac ts a re expec ted to be further assessed during the planning for the decommissioning p rojec t as the

3 Marchant S amp Higgins PJ (eds) (1993) Handbook of Australian New Zealand and Antarctic Birds vol 1 Ratites to Ducks Oxford University Press Melbourne

Supplementary EIS for the temporary weir near Pomanda Island -62shy

decommissioning is part of the referred action details will need to be provided to determine what the potential impacts are

Response The nominal design life for the temporary weir is 3 years and therefore not all impacts of the decommissioning are able to be assessed at this point in time For example it is difficult to be able to identify projects where the removed rock can be usefully employed

There a re no Ramsar-listed wetlands between Lock 1 and the p roposed temporary weir site however the Coorong and Lakes Alexandrina and Albert Ramsar site extends someway upstream of the weir site

18 On pg 12-2 the EIS sta tes

Response The Coorong and Lakes Alexandrina and Albert Ramsar site extends approx ten kilometres upstream of the proposed weir site (at the apex) to a point that represents the confluence between Lake Alexandrina and River Murray proper The relevant sentence on Pg 12-2 has been reworded to say There a re no Ramsar-listed wetlands between Lock 1 and the Coorong Lakes Alexandrina and Albert Ramsar site

19 On pg 12-15 the EIS says tha t the weir will ac c elera te d rops in wa ter level during the period of d isc onnec tion however all the downstream wetlands will supposedly have already disconnected due to drought conditions with the exception of wetland type O whic h is not expec ted to d isc onnec t It is not c lear what period of d isc onnec tion is being referred to

Response The period of disconnection being referred to is the time during which there will be reduced flow over the temporary weir from the River Murray channel into Lake Alexandrina nominally 25 3 months (as discussed under question 9 and page 13)

Reword Section 125 (pg 12-15) in its entirety to read

As deta iled in Sec tion 1241 a ll wetland habitats downstream of the temporary weir location are expected to be affected by the drought and by 2012 only Ramsarshywetland Type O is expected to remain inundated and hydrologically connected to the River Murray channel albeit in a highly altered state

Although broad changes are not predicted to occur the operation of the temporary weir is expected to contribute to localised changes including accelerated drops in water level in Lake Alexandrina during the period of hydrological disconnection (ie reduced flow see page 13) between the lake and the River Murray channel as the weir pool fills (Chap ter 10)

20 Throughout Chapter 12 the EIS refers to impacts on EPBC-listed flora and fauna species only but it should be considering all flora and fauna within the Ramsar site

Matters of Na tiona l Environmenta l Signific anc e as a matter of p riority however implic it in the EIS and in our Ramsar obligations are the impacts upon all flora and fauna within the Ramsar site Tortoises and Japanese Snipe are good examples of non-threatened species that have been or are likely to be affected by altered hydrology or water quality There is an infinite list of taxa that could be considered in detail some of which we know little about but much of this work falls outside the scope of the EIS

Response The EIS foc uses on threa tened spec ies and

The EIS refers to Matters of NES (eg EPBC- listed flora and fauna) that will still be occupying Type O wetlands which will be the only Ramsar Wetland Type still inundated at -15 m AHD the trigger for construction of the temporary weir Impacts on other Ramsar Wetland Types (ie the rest of the Ramsar site) were not considered because the impacts of the drought were considered to be the primary determinants of change in ecological character for those wetlands Further discussed in Supplementary EIS

Pred ic ted c hanges to p rimary determinants of ec olog ic a l c harac ter ) only lists the p red ic ted c hanges for 2 out of the 6 p rimary determinants

21 Table 12-4 (titled

Response Update Table 12-4 to include the following

Supplementary EIS for the temporary weir near Pomanda Island -63shy

Primary determinant

Normal operation

Limit of acceptable change (LAC)

Ongoing drought impacts (2010 2012)

Weir impacts (2010 2012)

Salinity Discussed extensively in Section 10 Water Level Discussed extensively in Section 10 Water Regime Discussed extensively in Section 10 Turbidity and Sedimentation

Discussed extensively in Sections 114 115 and 116

22 Sec tion 127 (Summary of Chapter 12) doesn t summarise the impac ts as a result of the weir only the impacts from the drought

Response Discussed in Supplementary EIS

23 There doesn t appear to be any c onsidera tion of the interac tion between the timing of construction and when migratory species will be present (eg no consideration on pp 13-78 of whether the timing of construction (potentially October-January) will impact on when the Orange-bellied Parrot will be there (potentially March-early November))

Response As indicated in chapter 13 of the draft EIS there is a low risk that construction will impact on OBPs Construction works are localised and OBP habitat is not affected The only impacts to migratory birds including OBP may occur during the actual construction phase (displacement and habitat loss) and are expected to be short lived

Orange-bellied Parrot over-winters in South Australia between March and November However observations are more likely between the months of May and September Timing the project to minimise the impact on Orange-bellied Parrots may result in construction occurring when other migratory species are present Migratory shorebirds for example generally return in late August and spend the entire summer at the Lower Lakes

24 In Table 15-9 on pp 15-2526 it says that a fauna inspection will be carried out in the construction area before any vegetation clearance and that any fauna located within the construction area shall be either relocated or dealt with in accordance with recommendations made by the qualified persons more information is needed eg a decision tree flowchart

Response A fauna and flora survey has been conducted by an ecological consultant on behalf of SA Water and DEH This knowledge has been considered by the Commonwealth It is acknowledged that more specific instructions on how this can be ac hieved will be inc luded in the Contrac tor s EMP The p rojec t will ensure tha t expert advice is available throughout the duration of the construction phase

25 Please re-consider 163 ESD whole approach The purpose of the weir is to protect water supplies not to prevent degradation

Response They have become one and the same over the life of the project To secure water quality is to secure supply The emergence of acid sulfate soil threats has presented us with a major risk for the water to become un-potable

The transitory effects of the temporary weir are far less than the long term effects of low freshwater flows

Principles of Ecologically Sustainable Development Guidelines Attachment 1 Part 3A

(a) The social and economic consequences of a city of 12 million not having a secure water supply are incalculable

(b) The threats of serious or irreversible environmental damage are discussed extensively in the EIS Whilst there is no full scientific certainty we are continuing to undertake extensive measurements modelling trials and emergency actions to minimise environmental degradation caused both by low freshwater inflows and the short term impact of the temporary weir

with the purpose of the weir in mind Not South Austra lia s

Supplementary EIS for the temporary weir near Pomanda Island -64shy

(c) Both the construction of the temporary weir if required and the actions being taken throughout the Ramsar site will benefit the present and future generations

(d) Whilst the purpose of the temporary weir is to protect water supplies we will take all reasonable steps to minimise any impact of the temporary weir on biological diversity and ecological integrity For example we are now proposing to include a fishway

(e) South Australia is a buyer in the water markets as required and supports the COAG initiatives to improve water markets and trade water information and research and an enhanced urban water reform framework We see no specific application of the ESD principles of improved valuation pricing and incentive mechanisms in the case of the temporary weir

26 If pumping to Lake Albert was not continued beyond June 2009 how would this affect the projections for impacts on the site (water levels the no flow period ASS exposure salinity levels)

Response On 12 June 2009 the Murray-Darling Basin Ministerial Council noted that funding for pumping to Lake Albert would cease from 30 June 2009

The potential for acidification in Lake Alexandrina is based on worst-case scenario rainfall and inflows during 2009 South Australia receives most of its rainfall in winter and spring so the extent of inflows and how trigger points may be favorably impacted by improvements will not be known until later in 2009 Over winter and into 201011 there will be some recovery in the water level (as has occurred each winter over the last three years of minimum flows) above the critical acidification level due to reduced losses and local rainfall Once losses increase during the warmer months the water level would again fall without any additional inflows

As described in the draft EIS under worst case conditions and with continued pumping to Lake Albert it was projected that the water level in Lake Alexandrina will reach the critical acidification water level of -15 m AHD at the beginning of January 2010

However with 220 GL delivered to Lake Alexandrina during 200910 the water level could be maintained above trigger level for the remainder of the 200910 water year 170 GL of the 220 GL requirement is now being secured by no longer pumping to Lake Albert The remaining requirement of 50 GL has already been secured by South Australia through the purchase of temporary water during the 200809 water year

The South Australian Government has assessed the potential savings that could be made by the decision to cease pumping to Lake Albert and how these savings combined with other water sources may delay the need to construct the temporary weir The 170 GL which now will be retained in Lake Alexandrina each year must still flow past Wellington to ensure that the salinity at the major pumping station at Murray Bridge remains below 1400 EC and therefore cannot be retained up-stream of Murray Bridge and used for other purposes

In conjunction with the additional 50 GL already purchased by South Australia (making a total of 220 GL for the full year) this will delay reaching the critical acidification level in Lake Alexandrina until mid to late 2010 maintain lake salinities at lower levels during this period than would occur if water levels continued to fall and maintain lower ASS exposure during this period

Updated model projections for both water level and salinity in Lake Alexandrina are presented below

Supplementary EIS for the temporary weir near Pomanda Island -65shy

_

Lake Alexandrina Level Forecasting from 16 May 2009

-24

-23

-22

-21

-2

-19

-18

-17

-16

-15

-14

-13

-12

-11

-1

-09

-08

-07

-06

-05

-04

-03

-02

-01

0

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Wat

er L

evel

(m A

HD

)

Projected Level w ith Maximum Net Evaporation (1982) Conditions

Level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Level

Critical Acidif ication Level (-15m AHD)

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Losses Maxmimum Net Evaporation (1982) Conditions

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 and no irrigation in 200910)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD unless stated

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank filled to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -66-

_

Lake Alexandrina Salinity

Forecasting from 16 May 2009

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

11000

12000

13000

14000

15000

16000

0108 0308 0508 0708 0908 1108 0109 0309 0509 0709 0909 1109 0110 0310 0510 0710 0910 1110

Date (monthyear)

Sal

inity

(E

C)

Projected Salinity w ith Maximum Net Evaporation (1982) Conditions

Salinity w ith level held at -14m AHD through 200910 (Cease pumping to Lake Albert end June 2009 additional 50 GL inflow )

Observed Lake Alexandrina Salinity

INDICATIVE ONLY

Forecasting Assumptions (Water year - July to June)

Flow to SA 1181 GL 200809 896 GL 200910 onw ards

Salinity Salinity of Flow to SA varies from 200 to 350 EC (f low rate dependent)

Losses as stated

Diversions Metro Adelaide (151 GL) Country Tow ns Other SampD (50 GL) AOP + LMS (Carryover + 18 + critical plantings + trade + environmental w ater in 200809 no irrigation 200910 onw ards)

Lake Albert Disconnection at -03m AHD pumping to maintain at -04 mAHD

Wetlands Area of connected w etlands ds Lock 1 reduced by 90 15 GL of reduced loss from w etlands us Lock 1

Other Temporary Environmental Regulator at Clayton closed and w ater level w est of bank f illed to +03m AHD (~27 GL to f ill and adjustment for reduced EMLR inflow s to main lake) in JuneJuly 2009

Supplementary EIS for the temporary weir near Pomanda Island -67-

Water supply

the weir is expec ted to have negligible effects on sa linity between Loc k 1 and Wellington

27 On pg 10-22 the EIS sta tes tha t then why is the weir needed to protect water

quality

Response The temporary weir will have minimal impact on water quality upstream of the temporary weir in terms of the inputs (particularly salinity) from upstream The primary purpose of the temporary weir is to prevent contaminated water from Lake Alexandrina being pushed into the River Murray channel upstream of Wellington through wind seiching Monitoring and modelling have demonstrated that even at the relatively low salinities in the lake currently incidents where water with a salinity in excess of the maximum target level of 1400 EC penetrates upstream to Tailem Bend may occur

28 Figure 1-3 (pg 1-4) shows a water level of -15m AHD (ie the critical acidification date) being reached in January 2009 What is the interaction between this and the proposed Clayton blocking bank which would bring the critical acidification date forward by at least 2 weeks into December 09

Response Pumping water to the Goolwa Channel will bring forward the time when the trigger water level of -15m AHD is reached by about 2 weeks however the critical acidification date will be delayed with the 220 GL delivered to Lake Alexandrina during 200910 (see response to question 26)

Should more than 896 GL year be ava ilab le [flowing ac ross the SA border] the potential effects of the proposed temporary weir are likely to be reduced in the Lower Lakes Does this mean that any water in excess of 896 GL will be allowed to flow into the lower lakes

29 On pg 10-7 it says tha t

Response Water allocated to South Australia in excess of 896 GL plus private and state carry-over will be allocated on a priority basis within the state Some of this may be allowed to flow to the Lower Lakes The application of any water in excess of 896 GL per year has not been determined and it is also dependent on the reason why there is exc ess wa ter For example unregula ted flows whic h a re flows tha t the MDBA is not able to capture a re likely to flow to the lakes while regula ted flows a re ava ilab le for allocation to support irrigation

30 The 201 GL critical human needs volume is based on level 5 water restrictions (pg 4-6) what is the plan for moving SA onto level 5 water restrictions considering only 896 GL is expected in 2009-10 (pg 1-3)

Response The total volume available to South Australia in 2008-09 is currently predicted to be at least 1140 GL Areas in South Australia reliant on River Murray water are currently on enhanced level 3 water restrictions The extra saving in moving to level 5 is 17 GL which is negligible in terms of the Lower Lakes

The Metropolitan Adelaide water supply is derived from two sources Inflows in the Mount Lofty Ranges during winter 2009 will impact on any decisions on water restrictions There is currently no plan to increase the restriction level from the current enhanced level 3 restrictions as the difference may be provided by additional MLR inflows

what is the increase in SA water use based on Population growth

31 Fig 2-2 on pg 2-5 shows 40 GL more being demanded than supplied by 2025

Response The 40 GL is the net effect of increasing demand further water conservation initiatives as described in the Water Proofing Adelaide strategy and reduction in available sources of water due to the impact of climate change

The weir is expec ted to a ffec t the amount of wa ter held between Lock 1 and Wellington and provide confidence that an extra [emphasis added ] 685 GL is ava ilab le for South Austra lians The 685 GL represents the amount of water needed to fill the weir pool from -15m AHD to +01m AHD but is not extra water that is available for extraction

32 On pg 10-32 the EIS says tha t

this needs to be clarified

Response Agreed The extra volume could only be available as a last resort and drawing down this weir pool would jeopardise water quality (salinity) as there would be no through flow to the Lower Lakes

Supplementary EIS for the temporary weir near Pomanda Island -68shy

33 On pg 2-2 the EIS states that roof run-off stormwater and recycled water are used for non-potable purposes how much Has this reduced reliance on Murray water Also mentions desalination plant will this reduce reliance on Murray water

Response Use of roof-runoff and stormwater particularly in the northern suburbs of Adelaide has provided additional water to reduce the demand on the traditional sources River Murray and the Mount Lofty Ranges Predominantly these have provided non-potable water for new development and as such are preventing increased demand from the traditional sources

It is clear that in critical periods of drought the 100 GL Adelaide desalination plant currently under construction will reduce reliance on the River Murray

While the desalination plant will reduce reliance on the River Murray this does not necessarily have a direct impact on the flow to South Australia required to maintain salinity at a satisfactory level (target lt1400EC at Murray Bridge) None of these nonshytraditional sources will remove reliance on the River Murray and it should be noted that a minimum flow to South Australia of about 900 GL per year is required to maintain salinity at Murray Bridge at less than 1400EC which is required for all potable use whatever the level of demand for Adelaide and regional South Australia

what is their estimated reduced reliance on Murray water Pg 4-17

34 Strategies 1 and 2 on pg 4-13 same question

Response Water conservation and recycling reduce the average water extracted from the River Murray and the recently released Water for Good plan quantifies this However in periods of extreme drought the same water savings are traditionally achieved through water restrictions and consequently these initiatives do not greatly reduce the need for River Murray water during critical periods

35 What is the safe operating height of SA Water pumping off-takes (pg 4-2)

Response Following modification to the pumps the safe operating level is currently -22m AHD Prior to the modifications the safe operating limit was around -04m AHD The estimates of the critical limits for the pumping stations have varied over time as the river level has dropped and the pumps could be tested outside of their normal operating ranges

36 If the pumps can pump down to -22m AHD then why is the weir pool at +01m AHD Does this factor in evaporation of the weir pool during times of low flow which would lower the water level Or is this considering the water quality of the lower lakes How can this be the case when the weir expected to have negligible effects on salinity between Lock 1 and Wellington

Response This level is set taking into account the requirements of the temporary weir during the recovery phase If Lake Alexandrina becomes saline the temporary weir needs to maintain a physical separation between the river and the lake as the lake level increases to allow the saline lake water to be flushed to sea

The level of 01m is a compromise While a higher level (up to 075m AHD or higher) would be preferred to facilitate flushing of lake water to the sea the foundation conditions for the temporary weir are not suitable for such a high weir if the lake levels continue to drop

c areful p lac ement remova l of embankment material

37 In Table 15-3 on pg 15-17 it says there will be what does this mean

Response Careful placement removal of the weir embankment material during constructionremoval will minimise both the area and quantity of disturbed bed material and hence minimise the immediate water quality impacts (mainly turbidity) and the inadvertent release of sulphuric acid from the sediments

38 SA has previously indicated it would legislate to ensure removal of the weir has this been done When will it be done

Response No The temporary weir will be removed when the decommissioning criteria (as agreed by the Water Security Council and accepted by the MDBA) are met

39 How will additional water secured through SA water security strategy and efficiency measures be managed ie will any be provided to Lake Alexandrina

Supplementary EIS for the temporary weir near Pomanda Island -69-

Response See response to Q29

40 Are there any the implications of predicted future water demand in SA on the period of time that the weir is in place

Response This is not expected to be material during the expected life of the temporary weir

Predicted future demand for potable water for the major off-takes will have minimal impact on the time the temporary weir is needed The temporary weir is required to prevent saline or acid contaminated water from the Lower Lakes entering the river channel until such time as the quality in Lake Alexandrina no longer provides a threat to these water supplies whatever the demand

41 Will salinity increase behind the weir in the weir pool Given that saline water sinks the water overtopping the weir may potentially be fresher water Will salinity levels in the weir pool build up to a point where it might impact on the offtakes

Response Large quantities of salt flow down the River Murray every day but it is largely mixed and therefore will not separate and sink Therefore salinity levels in the pool between Lock 1 and the temporary weir are not expected to impact on the offtakes (Note that there are saline groundwater inflows to the river which can cause localised pockets of salinity but this occurs in normal river operation and is independent of the construction of a temporary weir These pockets of high salinity eventually mix and the salt is carried away in the general water body)

In the absence of a temporary weir when more saline water from the lakes is forced under wind seiche into the river it does sink to the bottom rather than mix with the less saline river water and the saline water then moves upstream This is exacerbated by the differing depths of the water at Pomanda Island and in the river channel upstream of Wellington

Modelling indicates an initial rise in upstream salinity during the weir filling period and then after that no major change in the long-term Provided there is no significant input of highly saline water from Lake Alexandrina (the purpose of the temporary weir is to stop this) the salinity gradients generated by evapoconcentration of the relatively low salinity river water will not be sufficient to resist the natural mixing as temperatures and wind conditions change This has been demonstrated by the natural break-up of the saline intrusions on the bottom of the river due to inflows from Lake Alexandrina which have been identified through monitoring over the past year

42 Can SA provide the modelling on the 696GL scenarios with and without the weir on water levels the no flow period ASS exposure

Response Refer to the response to Q9

The flow scenario proposed is unrealistic as South Australia is guaranteed a minimum flow of over 896 GL in 2009-10 (including the reserve for Critical Human Needs and private carry-over) Modelling using 696 GL was primarily carried out as a convenient way to test the sensitivity of salt movement upstream

The requested modelling results will be provided but should not be taken as representative of any realistic scenario

Removal triggers (pg 1-6)

norma l opera ting levels in rela tion to Hume and Dartmouth and what period of time these levels have to be sustained for

43 No definition of

Response The MDBA states that the normal operating levels for Hume and Dartmouth storages is assumed to be approximately the long-term average level at the end of a water year (end May)

44 How long to fill Hume and Dartmouth Dams and how likely is this What is the worst case scenario Best case Is the filling and operation of these dams likely to be impacted by MDBstate water management

Response It is not possible to predict how long filling these storages to this level may take Hume storage in partic ula r is quite vola tile and c ould easily fill and spill within less than one year Dartmouth storage is more likely to take longer but the average end of season

Supplementary EIS for the temporary weir near Pomanda Island -70-

level is commensurately lower Under continuing worst case conditions the storages will not reach these trigger levels

The filling of these storages could be affected by decisions by all jurisdictions regarding the management of the Murray-Darling Basin including future sharing and reserve arrangements

45 Why was this trigger chosen rather than one focussed around water made available to South Australia from shared River Murray water or based on discontinuationreduction of dry-inflow contingency

Response These triggers were determined because they are open and transparent They are based on the best available technical advice

The triggers were agreed by the Water Security Council and accepted by the MDBA

need to meet a ll triggers Can SA provide any indication about the likely timeframe in which all triggers would be met

46 The timeframes on the removal triggers are unclear

Response Removal triggers are directly related to the drought and how much water is expected to become available It is not known when these triggers will be met

The MDBA notes that the specific timing of removal is highly dependant on the seasonal conditions at the time Lake Alexandrina next fills above +01 m AHD

no water quality impacts from Lakes water quality in the lakes is unlikely to improve with the weir in place so how realistic is this as a removal trigger If it is decided that seawater needs to be introduced to manage ASS this is likely to delay removal of the weir given the inability to meet this trigger

47 Regarding the 3rd removal trigger

Response Water quality in the lakes is unlikely to improve until additional fresh water flows down the river and either dilutes the lake water or flushes it to the sea If inflows to the lakes over the temporary weir exceed evaporation the water quality will begin to improve through dilution Major improvement in quality will not occur until there is a discharge of water from the barrages which cannot occur until the water level is restored to at least +05m AHD The critical salinity level in the lakes has been calculated at 3000 EC If inflows are predicted to reduce the lake salinity to less than this value the potential impact of lake water on major water supply offtakes is considered acceptable If seawater has been introduced to prevent acidification the volume required to dilute discharge salt to the extent that this target of lt3000EC can be met will be greater than if no seawater has been introduced However the volume of inflows required to improve lake water quality to an acceptable level if the lake has been allowed to acidify is likely to be even greater

This trigger has been purposely expressed as water quality rather than salinity because no decision has been made on whether seawater is to be used to manage acid sulphate soils (EPBC Reference 20084618) or whether an alternative strategy is to be adopted

If seawater is not introduced acidification may introduce a number of other water quality issues that need to be resolved before the temporary weir can be removed

48 In relation to the salinity trigger how much water is required to flow in to reduce salinity levels to below triggers stated What is the likely timeframe on getting this volume

Response The volume of water required to dilute salinity in Lake Alexandrina to meet the removal trigger will depend on the quality of water remaining in the lake and when the dilution occurs At the time of closure of the temporary weir it is predicted that the salinity in Lake Alexandrina will be approaching 10000EC Salinity will increase to about 28000EC within 12 months due to river inflows and evapo-concentration and will be significantly higher if seawater is introduced

Figure 211 in the Draft EIS shows how salinity in Lake Alexandrina continues to rise with continued low inflows The volume of fresh water eventually needed to reduce the lake water below the trigger level depends on how long the drought continues Typically the salinity of water in Lake Alexandrina will be diluted by 30 just by re-filling the lakes to 01m AHD

49 If the Australian Drinking Water Guidelines (2004) say that 275 to 550 EC is the acceptable salinity of drinking water (pg 10-4) then why is the removal trigger set at 3000 EC

Supplementary EIS for the temporary weir near Pomanda Island -71-

Response The desirab le sa linity ta rget for d rinking wa ter supp lies in South Austra lia has been identified as 800 EC based on AWRC and WHO guidelines Many supplies do not always meet this desirable limit The removal trigger for salinity in the lakes has been set at 3000 EC higher than the maximum limit set for Tailem Bend (1400 EC) and much higher than the desirable limit for drinking water of 800 EC because based on experience and from the modelling results the risk of water from Lake Alexandrina raising the salinity at the major water supply off-takes above the maximum target level of 1400 EC is acceptable

50 No definition of what the water quality risks are and how these would be measured

Response Refer to response to Q47

The primary water quality risk is salinity and this is dealt with comprehensively throughout the document Additional water quality risks arise from water moving upstream for Lake Alexandrina if the lake has acidified (heavy metals metalloids nutrients) These risks are closely monitored through existing water quality sampling programs associated with a major public water supply Algal blooms (potentially toxic cyanobacterial in particular) present an additional water quality risk that is addressed in the Supplementary EIS The presence of algae is monitored closely through a program established when lake and river water levels started to decline This program which is in addition to the normal sampling for public water supply purposes includes regular airborne videography and infrared photography with immediate ground truthing of any sites identified through the aerial survey work

It is not possible to quantify all of the water quality risks unless the management strategy for ASS is known in particular whether a preventive approach using seawater is to be used or a remediation approach The full impacts of these options are currently being investigated for the EIS to allow seawater into the Lakes

51 Fourth removal trigger is subjective what does this mean in practice Confidence is immeasurable this alleged removal trigger is more on outcome of the other removal triggers being met than a trigger in itself

Response The confidence required is in the consistency and robustness of River Murray water resource projections in relation to being certain we will not return to a similar situation of extreme low water levels as we are currently experiencing in the near future which may require re-instatement of the temporary weir

To some extent the comment that this trigger is an outcome of the first 3 triggers is correct However this trigger is intended to allow for the considerable uncertainty around the management regime for ASS and changes to operating rules in the MDB

52 58 states that once the water level exceeds +01m AHD the weir will cease to serve any useful function How will the structure of the weir albeit below water level change flow rates past the submerged weir

Response The temporary weir will have very limited impact on flows once water levels return to greater than +01m AHD in the lakes When the water level exceeds 01m AHD the temporary weir becomes drowned but it still provides a (partial) barrier to saline river water moving upstream

The submerged weir will still allow the prevailing flow to pass Should flow rates exceed the design of the temporary weir action would be taken to widen the flow path

Additional modelling will be undertaken to identify any backwater impacts from high flows in a situation where the temporary weir has not been removed (eg 50 000 MLday) The presence of the temporary weir would still provide some benefit in restricting any saline flows from Lake Alexandrina in to the River Murray channel even if the temporary weir was d rowned

Wetlands

53 In section 1246 on pg 12-11 under the head ing Impac t of p roposed temporary weir the EIS says Impac ts to emergent vegeta tion is c onsidered insignific ant as many of these species reproduce sexually and wind or bird-d riven seed d ispersa l This is only a consideration of impacts upon reproduction not a consideration of whether the plants will even survive to reproduce

Supplementary EIS for the temporary weir near Pomanda Island -72-

Response Complete disconnection of the fringing emergent vegetation (reeds and rushes) from the water body of Lake Alexandrina occurs at a water level of approximately 035 m AHD At a water level of -15 m AHD this vegetation is at least 185 m above the water level Under these conditions the component species of this vegetation primarily Typha domingensis and Phragmites australis are likely to be in a state of dormancy with below-ground storage organs awaiting future inundation to trigger a growth response ie the formation of new shoots These species are able to persist for several years in a dormant state between inundation events With or without the temporary weir in place this fringing emergent vegetation remains disconnected from the waterbody and the duration of this disconnection is the same under both scenarios Therefore the impact of the temporary weir upon fringing emergent vegetation is considered insignificant The long term persistence of the fringing emergent vegetation of Lake Alexandrina in the elevation band within which it currently exists requires that the lake be refilled with fresh water to its pre-drought level (05 to 08 m AHD) while the below-ground storage organs remain viable

54 In Table 12-3 on pg 12-6 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type O it says that the slightly quicker decrease in water levels as a result of the weir is expected to bring forward the exposure of some sediment (including acid sulphate soils) that would otherwise have been exposed within 9 months how much acid sulphate soils Is this the 5200 ha mentioned on pg 11-7

Response Yes it is 5200 ha and this is reiterated in the Supplementary EIS As discussed in the Supplementary EIS the reduction of flow during the filling of the weir pool reduces the volume of water such that a further 5200 ha of sulfidic soils is exposed in Lake Alexandrina This may result in the generation of a greater volume of sulfuric material Management options to mitigate and manage acid sulfate soils will need to be implemented across the Lake in this case

55 In Table 12-3 on pg 12-8 for wetland type XI how can there be no recorded change at shy05m AHD but complete disconnection at -15m AHD

Response Presumably the comment refers to wetland type Xf not wetland type XI In Table 12-3 for wetland type Xf under Existing c ond ition (app roximately -05 m AHD) rep lac e No rec orded c hange with Not c onnec ted to the ma in body of the lake Will only be a ffec ted by ongoing d rought

Covered in Supplementary EIS

56 In Table 12-3 on pg 12-8 under Impac t of p roposed temporary weir within Ramsar wetlands for wetland type 4 the EIS says the weir is not expec ted to further impac t the management of seasonally flooded agricultural land when are they seasonally flooded Are the 25-3 months following weir closure going to prevent this seasonal inundation

Response In Table 12-3 for wetland type 4 under Impac t of p roposed temporary weir within Ramsar wetlands to existing text add whic h oc c urs a t wa ter levels gt 087 m AHD At the trigger level for weir construction (-15 m AHD) water levels will be 237 m below those that lead to inundation of surrounding agricultural land With or without the temporary weir in place water levels will remain well below 087 m AHD for the 25 3 month period following weir construction if it proceeds

Covered in Supplementary EIS

57 In Table 15-1 on pg 15-2 in the row on acid sulphate soils the EIS says that contingency measures may be c onsidered if a lka linity dec lined to a spec ified level what is this level How and where will this be measured What contingency measures would be implemented

Response Table 15-1 refers to Table 15-6 Potential mitigation measures to manage acid sulfate soils which contains the levels (100 and 25 mgL as CaCO3) In Table 15-6 for dot point 2 it c ould be c hanged to If a lka linity c onc entra tions dec line to 25 mgL as CaCO3 then immediate mitigation measures such as limestone slurry dosing are expec ted to be undertaken

Since August 2008 the SA MDB NRM Board has been coordinating water quality monitoring at 24 sites in the Lower Lakes This monitoring includes alkalinity pH salinity and turbidity as well as several other analyses (eg sulfate dissolved oxygen metals and metalloids) and is being undertaken fortnightly by the University of Adelaide and DWLBC

Supplementary EIS for the temporary weir near Pomanda Island -73-

It will soon be available to the public from the EPA in the form of a Lower Lakes water quality report (report 1 March 2009) The EPA also compiles the raw data in a spreadsheet available to South Australian government agencies

58 How will the Wetland Management Plan (Table 15-3 pg 15-17) manage the change in flow patterns Does have any suggestions on how to mitigate the impacts of the no-flow periodfirst year reduced flows period

Response Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

59 In Table 15-3 on pg 15-18 it mentions several potential water quality protection measures including use of a turbidity curtain stabilisation of river banks etc Under what conditions would each of these measures be implemented Same for contingency measures for acid sulphate soils outlined in Table 15-6 on pg 15-20

Response The EPA has pointed out that the EMP scope should include monitoring and managing turbidity impacts during construction and any EMP should be approved by relevant authorities including the EPA prior to any works being carried out

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This EIA and risk management framework will address a diverse range of potential environmental risks such as hazardous amp non-hazardous waste energy dustnoise EPBC Act- related matters etc

Chapter 15 of the draft EIS outlines the Environmental Management Framework (EMF) which contains the overarching EMP SA Water and the contractor will prepare a CEMP operational EMP (OEMP) and a decommissioning EMP (DEMP) to adhere to the requirements outlined in the draft EIS EMP

Table 15-3 has been amended

60 Will there be any interactions with other referrals Will the presence of the weir impact on the Goolwa Channel referral

Response The temporary weir is part of a planned progressive response by the South Australian Government to worsening conditions in the Lower Murray in South Australia This Cabinet approved response plan is based on water levels in the barrages weir pool The critical trigger for the temporary weir is -15m AHD The trigger for the project to pump water to Lake Albert was -05m AHD and the trigger for the proposed Goolwa Channel Water Level Management Project is -12m AHD These actions are all linked as part of the overall response strategy The presence of the proposed temporary weir will not impact on the Goolwa Channel project as the latter project will be constructed well prior to the proposed temporary weir near Pomanda Island

61 It is likely that the presence of the weir may adversely impact on the recovery and management of the ecological character of the and therefore in the implementation of the long term plan for the site Does SA have any suggestions about how this will be managedmitigated

Response The temporary weir will not adversely impact on the recovery and management of the ecological character and will assist in preserving the range of options that can be considered under the long-term management strategy If the temporary weir is not constructed and the area acidifies or a greater volume of seawater is required to prevent this the detrimental impacts on the long-term plan will be greater

62 Page 10-25 will SA be purchasing water to ensure that the hydrological disconnection associated with the filling of the weir pool is reduced from 3 to 1month Please provide details under what circumstances would this occur

Response The South Australian Government is committed to pursuing a fresh water solution for the Lower Lakes including the purchase of water from the market However

Supplementary EIS for the temporary weir near Pomanda Island -74-

no commitment of additional water to the Lower Lakes can be made until the winter 2009 inflows are known

Re-wetting of upstream wetlands

63 Pg 2-16 says that a range of mitigation measures such as blocking banks flooding and applications of neutralising agents are proposed and will be described in Section 1554

THIS SECTION DOES NOT EXIST and they do not appear to be described elsewhere (pg 10-10 also mentions likely changes to groundwater interactions and the re-wetting of dried sulfidic sediments and the associated ecological effects that would result and refers to Ch 15 for management tha t s in p lac e) mitiga tion measures mentioned aga in on pg 11-9 but no details

Response The reference to section 1554 should read 15412 and has been corrected in the Errata to the Supplementary EIS Table 15-6 titled Potential mitigation measures to manage acid sulphate soils is also relevant Further details are provided in the response to question 64 in regards to ASS mitigation and management of wetlands above Pomanda Island All appropriate approvals for structures will be sought through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project

64 As the weir pool fills and upstream wetlands are re-wetted there exists a real potential for the introduction of low pH water with high metal concentrations into the River Murray (pg 11-8)

Response Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project has been developed to manage the risk of low pH and metal mobilisation into the main River channel The aim of this project is to determine remediation options on a site-by-site basis for high ASS risk wetlands between Lock 1 and Wellington based on potential impact refilling wetlands will have on water quality of the Main River Channel and ecological impact of further acidification of wetlands

The project will provide the following outcomes

Identification of priority ASS risk wetlands for remediation based on CSIRO ASS results wetland and River management and distance from off-takes Recommendations for the most appropriate ASS remediation option for each priority ASS risk wetland between Lock 1 and Wellington on a site by site basis Options will be based on results and recommendations from the MDBC Project Murray-Darling Basin Acid Sulfate Soils Risk Assessment Project as well as ecological and hydrological factors Management options will also draw on the knowledge and information gained from DEH project identifying acidification remediation options for the Lower Lakes Construction of structures and other on-ground works for remediation at priority wetlands and Development and implementation of a monitoring program to assess the success of remediation options at wetlands

The SA MDB NRM Board is managing the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project with a steering committee comprising of relevant agencies to provide expert input and to oversee the decision making process and implementation of the program Agencies represented on the steering committee are SA MDB NRM Board DEH DWLBC MDBA SA Water EPA CSIRO and Local Action Planning Associations

Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at River levels of 01m AHD CSIRO have undertaken a preliminary assessment of the ASS hazard for each of the 75 wetlands An ASS risk assessment of the 25 wetlands was undertaken which identified that 14 of the 25 wetlands required ASS management 10 wetlands did not require management and one wetland required reassessment Options for remediation and management of the potential negative impacts of ASS on the main River channel are being developed on a site-by-site basis to ameliorate the mobilisation of low pH water and metals from ASS soils Management may include regulating structures and a combination of other methods such as neutralising agents mulching and revegetation

In the development of ASS management options for each site the ecological values of each wetland will also be taken into account With all but 3 wetlands in this reach having dried due to the low River levels it is very important to maintain the health and

Supplementary EIS for the temporary weir near Pomanda Island -75-

ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island eg wetlands providing important aquatic refuges

65 Which wetlands will be re-wetted What are their sizes water levels condition etc

Response Of the 75 wetlands between Lock 1 and Pomanda Island 25 have been identified as being inundated at +01m AHD The Table below provides information of the c ommenc e to fill level surfac e a reas and ASS management assessment for eac h of the 25 wetlands

NAME

SA (ha) at pool (~075m AHD)

SA (ha) at 02m AHD

commence to fill m AHD

Require ASS management

Riverglades 446 196 -051 Yes

Wellington Marina lt 191 lt 191 lt -080 Needs reassessment

Saltbush Flat 855 88 -025 No

Teal Flat Hut 202 15 -019 Yes

Walker Flat South Lagoon 888 601 -010 Yes

Wellington North (Murrundi) 9 32 -010 Yes Lake Carlet 3457 2998 -065 Yes

Devon Downs North 2627 822 -040 Yes Lake Bywaters 388 321 -017 No Marks Landing 1929 1453 -060 No

Coolcha Lagoon 1284 436 -045 Yes

Tailem Bend 957 811 -057 Yes

Younghusband 223 23 -010 Yes Younghusband West 1089 887 -062 Yes Caurnamont 903 464 -021 No Craignook 369 208 -002 Yes

Forster Lagoon 80 641 -022 No Henley Park 224 177 -027 No Bow Hill 475 140 -033 No Mannum Swamps 1977 1450 -035 Yes Mason Rock 258 91 -046 Yes Reedy Creek 986 436 -004 Yes Priess Landing 5 29 -069 No

Teal Flat 82 476 -011 No

Wongulla Lagoon 124 365 -046 No

Total 24449 13161

66 In the final paragraph on pg 12-16 the EIS says that re-wetting could potentially cause water in these wetlands to become acidic (if acid sulphate soils are re-wetted) which c ould c ause the following ac id ity would then remob ilise meta ls c onta ined within the sediments causing disease or death in fish due to metal toxicity Should this be experienced management measures identified in Chapter 15 will need to be undertaken What a re the management measures How will SA know if this has occurred (ie monitoring)

Response Refer to response in Ref 64 in regards to management of potential risk of ASS in wetlands inundated at 01m AHD The Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project incorporates the development of a monitoring program to assess the success of the ASS mitigation strategies and ecological impacts This will include the monitoring of water quality metals biota such as fish groundwater and vegetation

67 What will be the objectives of the management plan for re-wetting exposed acid sulphate soils How will it achieve these objectives (Table 15-6 pg 15-21)

Response The objectives of the management plan for re-wetting exposed acid sulphate soils are

To mitigate the risks of acid and metal mobilisation to the main River channel water quality and biota of the River Murray and associated wetlands

Supplementary EIS for the temporary weir near Pomanda Island -76-

Mitigate the risk of acid and metal mobilisation within the wetlands above Lock 1 when they are refilled and Ensure the development of ASS mitigation methods incorporate the environmental values of each of the wetlands

The objectives will be achieved through the Wetlands between Lock 1 and Wellington Acid Sulfate Soils Management Project which will develop site-by-site management options for ASS hazards The risk assessment has been undertaken which has identified 14 wetlands that require management of ASS hazard Management options are currently being developed and may include regulating structures and other methods such as neutralising agents mulching and revegetation with the aim of ameliorating the risk to the main River channel due to the rewetting ASS hazard wetlands

68 Will the rewetting strategy for ASS areas in the weir pool affect the time it takes to fill the weir pool and therefore prolong the period of no flow to Lake Alex

Response The refill volumes for each of the 25 wetlands that will be inundated at 01m AHD with the construction of a temporary weir near Pomanda Island are currently being calculated using modelling and survey work It expected that the total volume of water required to refill these wetlands will be insignificant in relation to the volume of water required to fill the River channel and would not prolong the period of no flow to Lake Alexandrina

With only 3 of the 75 wetlands in this reach currently wet due to the low River levels it is important to maintain the health and ecological function of those wetlands that will be re-wetted with the construction of a temporary weir near Pomanda Island The re-wetted wetlands will provide important aquatic refuges and breeding opportunities for biota

Wetland management plans for the ASS risk wetlands will consider water levels water quality and the mobilisation of acidic and heavy metals- refer to response to Ref 64 The SA MDB NRM Board monitors groundwater at bores associated with a number of wetlands that have been managed in the past which are located along the River corridor and floodplain Groundwater will be monitored at these wetlands prior during and post weir construction These bores were however installed to assess groundwater at these wetlands for their specific management and operation and not to assess groundwater at a regional level

Threatened and migratory species

69 On pg 13-13 the EIS says The lac k of c onnec tivity [ie as a result of the weir b loc king migration] is expected to also hinder gene flow between populations potentially leading to a decrease in diversity in both Murray Cod and Murray Hardyhead populations if it c ontinues for a suffic ient period What would be a suffic ient period in this c ase Would three years (the design life of the weir) be a sufficient period Obviously for Murray Hardyhead even one year of interrupted reproduction could be significant as the species only lives for 2 years (pg 13-14)

Response A fishway to suit large and small species will be included in the weir design and design is currently underway

70 At what water level will the Swamps of the Fleurieu Peninsula disconnect from the main body of Lake Alexandrina (as per pg 13-4)

See page 32 of the supplementary EIS under the heading Impacts upon tributary wetlands

71 Lack of detail in section on Orange-bellied Parrot (pg 13-8) to exactly where will vehicle movement be spatially restricted How will the creation of new tracks be limited What vegetation will be cleared and how much

Response Several surveys over the last few years have occurred with the Coorong and Lower Lakes Positive sightings were recorded within the Coorong National Park region Lakes Alexandrina and Albert have not recorded any presence of the OBP refer to httpwwwbirdsaustraliacomauimagesstoriesdownloadscurrent_projectsOBP_Coor ong_Survey_lowpdf

In order to gauge the potential impact of the construction of the temporary weir on local biodiversity a thorough ecological survey of the immediate area in Spring 2009 is

Supplementary EIS for the temporary weir near Pomanda Island -77-

desirable Survey results can then inform relevant mitigation strategies to be included in the EMP

Construction activities on (Pomanda Island) will be restricted to along the northern edge of the island and locally around the abutment It is expected that the temporary weir will cause a minor loss of some of the reed beds along the western access road to the construction site due to the need to construct a wider road for truck traffic The construction footprint will be minimised as far as practically possible by minimising the road width and avoiding the reed beds where practically possible Construction activities on the eastern side will be localised to the immediate area around the abutment The landscape on the Eastern side is characterised by farmed paddocks Hence no reeds (and no habitat of the Orange bellied Parrot) are expected to be impacted on the Eastern side

The CEMP will be based upon a risk management framework underpinned by an environmental impact assessment for the construction operation and decommissioning of the project This plan and risk management framework will address a diverse range of potential environmental risks such as hazardous and non-hazardous waste energy dustnoise EPBC Act-related matters etc

72 In Section 1352 on pg 13-9 rela ting to the Southern Bell Frog it doesn t mention tha t the frogs have been found at Pelican Lagoon (pg 7-24) the section goes on to mention that the site at which the southern bell frog was recently recorded is expected to be disconnected from the water when Will the regulated pumping system continue to operate

Response The main body of Pelican Lagoon where Southern Bell Frogs (SBF) have previously been recorded (River Murray Wetlands Baseline Survey 2005) has been dry since 2007 It is unknown as to whether SBFs are still located in the dredged area closest to the river It is expected that this dredged area will remain inundated at +01m AHD but the rest of the wetland will remain dry

73 Where is the previously occupied southern bell frog habitat near Wellington How will the raised water level help frogs to recolonise this habitat (pg 13-10)

Response The previously occupied site for the Southern Bell Frog near Wellington is called Ferry Crossing (Coordinates139386 -35337) The recording was in the 2000 frog census on 15 September 2000 numbers were identified as few The only other areas where they have previously been recorded within the Lower Lakes are at Tolderol Game Reserve and Clayton (Dunn Lagoon) These sites are to the West of Wellington on the shores of Lake Alexandrina

The raised water level of the weir pool will re-hydrate the wetland and provide re connection with the main river channel This in turn enables the re-establishment of emergent and submergent vegetation within the wetland providing suitable habitat for the species to colonise and reproduce Reproduction requires still or slow moving water (Australian Government 2009)

Australian Government 2009 Significant Impact Guidelines for the vulnerable growling grass frog (Litoria raniformis) EPBC Act Policy Statement 314

74 An Environmental Management Plan is proposed as mitigation to the likely impact of disruption to Southern Bell Frog tadpole migration (Table 16-1 pg 16-3) how will the EMP mitigate this impact Need more information on the potential for the weir to disrupt the dispersal and migration of southern bell frog tadpoles (pg 13-10)

Response This response takes into consideration the history of inter-governmental documentation on this point in relation to the proposed Pomanda Island Temporary Weir and a lso the Dra ft EPBC Ac t Polic y Sta tement 314 Signific ant impac t Guidelines for the vulnerable growling grass frog (Litoria raniformis) [= southern bell frog] (Feb 2009)

Environmental conditions habitat and breeding

The preferred habitat for breeding of the southern bell frog is high emergent vegetation cover (eg Phragmites and Typha) and still or slowly-moving water (Stratman 2007 DEH 2009) Current conditions in the Lower Lakes region are poor and breeding is unlikely to be occurring in the region at the moment It is unlikely that breeding will occur immediately downstream of the temporary weir in the short-term Immediately upstream of the temporary weir it is likely that habitat conditions will be maintainedenhanced (see also page 30 of this document)

Supplementary EIS for the temporary weir near Pomanda Island -78-

Migration of southern bell frog

It is now considered that the original comment in the draft EIS of The likely impacts on this species are confined to possible Interruption to dispersal and migration of tadpoles Additional pressures resulting from the construction and operation of the temporary weir include short term changed water regimes water chemistry and localized noise As no individuals have been recently recorded at the proposed site these local disturbances are not expected to impact the population was incorrect in its reference to tadpoles The adults of the species are highly mobile (movement of up to 212 m in a single night has been recorded referred to in Schultz 2008) Less is known about the mobility of tadpoles Tadpoles may be involuntarily swept over the temporary weir during significant flow events The top height of the proposed temporary weir is lower than the normal operational sill level at the Goolwa barrages so the structure will only present a barrier to dispersal of the Southern Bell Frog during unfavourable conditions such as those that have prevailed for the last 18 months

Since adult frogs are highly mobile the causeway and abutments associated with the temporary weir may impact on the movement of adults along the banks of the river corridor Experimental developments in Victoria have used culverts or pipes placed beneath roads as corridors to try to link populations however Bell Frogs have not been observed using them to date (G Heard personal communication)

Survey

The SAMDB NRMB advised that a targeted frog survey was needed to determine whether Southern Bell Frogs still remain in the vicinity of Pelican Lagoon prior to the development of the Environmental Management Plan

DEH undertook a habitat preference survey during March 2009 and a follow-up survey is planned for Spring and Summer 2009 to assess population numbers The rapid assessment of suitable habitat for the Southern Bell Frog (March 2009) was conducted around the perimeter of Lake Alexandrina and Lake Albert with survey sites stretching along the edge of Lake Alexandrina from Milang to Wellington then Wellington to Meningie along Lake Albert around to Narrung The result of this habitat assessment is a proposed targeted species survey in line with the original project objectives

As indicated in Figure 7-4 of the Draft EIS L raniformis has been detected at wetland habitats around Lake Alexandrina and in the lower reaches of the Murray River upstream of the lake including locations near Narrung Point Malcolm Wellington and around Milang Most of the sites based on habitat mapping undertaken by DEH are characterised by permanent water and to some extent reedbeds

Mitigation

The comment on mitigation that was included in the draft EIS is relevant

All construction operation and decommissioning activities are expected to be done in accordance with an Environmental Management Plan A survey for this species is expec ted to be c onduc ted in 2009 to better understand the p resent d istribution The initial assessment to indicate likely target sites (preferred habitat survey) has now been completed and the follow-up survey is planned for spring summer later in 2009

75 On pg 13-11 the EIS says that the Yarra Pygmy Perch are more commonly found in the well-vegetated lake margins and the channels of Hindmarsh Island and the lower ranges of the eastern Mt Lofty Ranges tributaries but that these areas are currently disconnected from the main body of Lake Alexandrina (also on pg 14-1) When did the channels of Hindmarsh Island disconnect Yet it is stated in the EIS the eastern Mt Lofty Ranges tributaries (Currency and Finniss) a ren t expec ted to be d isc onnec ted until lake levels drop to -12m AHD (pg 10-1) do you mean Angas and Bremer

Response refer to the discussion on page 23 of the supplementary EIS regarding Connectivity of Surface and Ground Waters

76 Why do PIRSA Fisheries have a policy of not re-stocking fish species (pg 13-14) and what is different about these circumstances that would mean it is now a suitable option

Response PIRSA Fisheries advises that in the absence of a fishway stocking of fish to increase populations in a degraded habitat is unlikely to result in a net increase in the population However as the water is pooled upstream of the new temporary weir there could be some limited restocking as the environment improves to allay any concerns

Supplementary EIS for the temporary weir near Pomanda Island -79-

that cod populations have suffered from the weir works The PIRSA website has a policy paper4 which explains why large scale restocking is not supported (there are implications of spreading diseases in wild populations from those that have been housed in aquariumsgrown in aquaculture there is also the risk of limiting genetic diversity if stock have been bred from only a few source fish and a series of other issues)

In regards to the broader issue of re-stocking native fish species within the site that have been lost to the freshwater environment due to their complete disconnected from the lake re-stocking before recovery of the ecosystem is not appropriate Upon recovery of the ecosystem and re-establishment of an appropriate freshwater ecosystem these species will either re-colonise from elsewhere or if only located regionally re-introduced via a stocking program An existing program is in place whereby populations are being bred in captivity to allow later re-introduction in the future of EPBC listed (Yarra pygmy perch and Murray hardyhead) and regionally significant species (Southern pygmy perch River Blackfish and Southern Purple-spotted gudgeon) We are presently in the situation where for some species (those listed above) there are no remaining genetically-distinct populations remaining in-situ so the only option is to reintroduce those held in captivity if we want the population to persist Murray cod are believed to be a single genetic unit across South Australia and hence re-population from upstream populations should enable recovery This could be supplemented by a breeding program but would be subject to a complete collapse of the SA South Australian population and approval from PIRSA as would the re-introduction of other species presently held in captivity and would be subject to specific testing and satisfaction of relevant conditions

In addition to these potential activities a fishway is now being included in the design for the temporary weir to enable the egress of species from the lake environment into the river channel above Wellington

77 What is the evidence that Murray Cod and Murray Hardyhead are able to withstand high turbidity conditions (pg 13-15)

Response No data on the tolerances of Murray Cod and Murray Hardyhead to high turbidity conditions are available Evidence on tolerance to relatively high turbidity is correlative Both of these species are distributed across lower regions of the Murray-Darling Basin in areas subject to relatively high turbidity Turbidity in the River Murray in South Australia is highly variable and largely influenced by discharges from the clay-laden Darling River (Woodyer 1978) Turbidity at Morgan averaged 516 NTU between 1994 and 2004 with peaks as high as 304 NTU (Westwood and Ganf 2004) Turbidity in Lake Alexandrina is also highly variable with mean values between 1975 and 1978 varying from a high of 93 NTU to a low of 9 NTU with localised values as high as 150 NTU recorded (Geddes 1988)

78 What would the parameters be for reintroduction of Yarra Pygmy Perch andor Murray Hardyhead (pg 13-16)

Response The reintroduction of the Yarra Pygmy Perch and the Murray Hardyhead would be undertaken once the habitat has been rehydrated and the keys components to their survival are in place such as

There is a level of confidence inflows into South Australia will be able to sustain the habitat at least in the medium term Habitat structure has recovered (eg aquatic plants) sufficiently to provide for o Spawning o Shelter o Food source and o Predation avoidance Water quality parameters are within tolerances (specified in the draft EIS) of each species such as o Salinity o pH o Dissolved oxygen o Water temperature o Turbidity and o Concentrations of contaminants particularly Aluminium

4 httpwwwpirsagovau__dataassetspdf_file000950895Stock_enhancement_policy_Aug_07pdf

Supplementary EIS for the temporary weir near Pomanda Island -80-

For Murray Hardyhead the following ranges of parameters have been utilised for reintroduction at a Lower Lakes site

EC 2000 30000 EC

DO gt50 mgL (ANZECC WQ Guidelines)

Turbidity 2-200 ntu (ANZECC WQ Guidelines)

84PH 70

Yarra Pygmy Perch would have similar parameters but with a much lower salinity range

79 On Pg 14-7 it says that a decrease in the abundance of wetland birds has been observed where noise levels exceeded 56 dB what noise levels will construction create

Response At this stage it is difficult to predict what the average noise level might be Presumably levels will fluctuate and for short periods of time the 56db level may be exceeded Important also in the equation is the distance of the waterbirds from the noise source If the equipment levels a re say 85dB(A) then they ll d rop to 45db (A) within 100m

There are no wetlands on the eastern side near the abutment We expect any areas around Low Point populated by birds to receive noise levels similar to that from a busy highway This same comment will apply for the western abutment approaches Any birds in the immediate vicinity of the western abutment could be subject to higher noise levels so it is assumed they would occur further north into the wetland area

Monitoring of EPBC-listed species throughout the project is expected to occur to ensure construction operation and decommissioning activities do not impact on EPBC-listed spec ies how will monitoring ensure this This can only work if particular contingency measures are undertaken if a particular measure is observed during monitoring

80 On pg 15-24 it says tha t

Response Monitoring during operation of the weir Monitoring efforts will be coordinated as part of the SA MDB NRMB s na tura l resourc e c ond ition monitoring program It will include additional monitoring efforts as per expert advice

Monitoring during the construction and decommissioning of the weir It is recognised that the monitoring of the EPBC listed species will be challenging during construction and decommissioning phases of the works mainly due to the relatively short duration of these activities compared to the species life breeding cycles The monitoring focus will be of an observational nature mainly in regards to compliance monitoring to ensure that the constructiondecommissioning efforts stay within approved corridors (approved by Commonwealth and NVC) and the construction method does not inadvertently affect flora or fauna (clearance of vegetation destruction of feeding habitat interruption of feeding or breeding cycle etc) Daily inspections are envisaged using flora amp fauna expert advic e if warranted In add ition the Contrac tor s EMP will identify based on a risk assessment which specific mitigation and contingency measures will need to be applied under specific circumstances andor if a deviation from expected observations is recorded

Fishway

81 One of SA s river hea lth ob jec tives under the River Murray Ac t is Barriers to the migra tion of native species within the River Murray system are to be avoided or overc ome (pg 3shy36) The weir would obviously impede the migration of native species without appropriate measures eg fishways

Response As explained in the Supplementary EIS a fishway is now included in the design for the temporary weir SARDI have indicated that they have sufficient knowledge to be able to design a fishway without the need for further site survey work

82 On pg 5-5 the EIS says that no provision is necessary for fish passage

Response See response to 81

83 The weir may impede upstream movement of juvenile and adult (spawning) Murray Cod and would possibly affect the downstream drift of larvae into if lake if spawning in the

Supplementary EIS for the temporary weir near Pomanda Island -81-

river was to occur (pg 7-29) possibility of fishway to allow larvae movement or other mitigation measures

Response See response to 81

84 On pg 13-12 the EIS says that the weir is expected to limit migration abilities

Response See response to 81

85 Why wouldn t Murray Cod use the fishway (Tab le 15-9 pp 15-2526)

Response Due to concerns about the lack of a fishway a design process has been initiated with the assistance of consultants to determine a suitable design concept that would allow passage of both NES and other fish species A concept design is expected to be available in July 2009 The inclusion of a fishway has a number of challenges not the least of which is the initial desire of the fish specialists to pass all the normal flow of approx 1 GLday through the fishway rather than over the spillway

86 Construction of the weir embankment begins when water levels in Lake Alexandrina are between -05m and -10m AHD (pg 5-11) however on pg 12-17 it says construction is preposed to commence when lake levels are at -11m AHD which will occur in October 2009 according to Figure 1-3 and then in Table 16-1 on pg 16-2 it says that construction is proposed to commence at 9 months before Lake Alexandrina is predicted to reach shy15m AHD

Response We will commence work at the latest date regardless of the water level that will allow closure of the river by the required deadline date It is expected to take approx 9 months from the award of contract to closure of the river but the weir construction will not be completed until a number of months after the closure date

87 2009-2010 expected minimum delivery to SA is 896 GL (pg 1-3 pg 9-9) however on pg 2-13 and pg 2-19 the EIS presumes that 940 GL will be delivered in 2009-10

Response South Australia is guaranteed 896 GL of dilution and loss flow plus 201 GL of Critical Human Needs reserved from 2008-09 The figure of 940 GL was a possibility in December 2008 but should not be used

The graphs provided clearly state 896 GL flow for 2009-2010

88 A dilution flow of 696 GL per year is available to SA which is used to maintain salinity levels at Murray Bridge below 1400 EC (pg 2-13) however on pg 4-5 it says than 200 GL in addition to the 696 GL is needed to maintain the salinity at this level at Murray Bridge on pg 10-7 it says that 695 GL is the dilution flow

Response The dilution and loss component of Entitlement Flow guaranteed to South Australia under the Murray-Darling Basin Agreement is 696 GL per year This does not meet the normal system losses within South Australia (average about 1130 GL per year) and this flow does not dilute salinity sufficiently to maintain lt1400EC at Murray Bridge Modelling has shown that an additional 200 GL is required to maintain salinity at Murray Bridge at lt 1400 EC (ie a total flow of 896 GL)

As stated in the response to question 9 South Australia is now guaranteed a flow of at least 896GL during 2009-10 The 896 GL includes 201 GL extracted for Critical Human Needs

Note that the 201 GL for Critical Human Needs serves a dual purpose in that it also contributes to the dilution of the salt loads as well as being extracted mainly in the lower reaches of the river for use in the potable water supply system

89 The text on pg 2-15 says that it is predicted that by May 2009 salinity in Lake Alexandrina will be about 7260 EC however Fig 2-11 on the same page and Fig 1-4 on pg 1-4 show that salinity is predicted to reach only just over 6000 EC by May 2009

Response Both graphs are the same and by May 2009 it was projected that the salinity would be around 6000 EC Current salinities indicate that this projection will be accurate The figure of 7260 EC on page 2-15 is incorrect and is corrected in the Errata

90 It would require 220 GL in 200910 and 365 GL in 201011 to maintain the lakes at 10cm above the critical acidification level [ie maintain the lakes at 1-4m AHD (sic)] however it is unclear if this means water flowing over the weir or additional water purchased from upstream (pp 4-78)

Supplementary EIS for the temporary weir near Pomanda Island -82-

Response South Australia is committed to providing a minimum River Murray flow of 350 GL per annum to Lake Alexandrina via Wellington This minimum flow is required to maintain potable water quality (salinity not exceeding 1400 EC) at the SA Water Corporation major pumping station at Murray Bridge

The cessation of pumping from Lake Alexandrina to Lake Albert preserves approximately 170 GL per annum in Lake Alexandrina and reduces the additional water requirement for 200910 from 220 to 50 GL and the requirement for 201011 and subsequent years to 195 GL per annum The 170 GL annual savings is a subset of the 350 GL annual commitment

The additional 50 GL (200910) and 195 GL (201011) requirements are over and above the 350 GL commitment and could be sourced from improvements in River Murray flows improvements in eastern Mount Lofty ranges tributary flows better than worst-case rainfall directly over Lake Alexandrina (Lake Albert is now under alternative management) better than worse case evaporative losses and purchases from intra and interstate

91 In 2007-08 SA was supplied 1564 GL of water and the River Murray supplied 95 of this (Table 1-1 pg 1-2 2) however on pg 2-4 it says that in 2007-08 SA Water provided SA with over 176 GL of water 95 of this was sourced from the Murray

Response Table 11 may be poorly labelled The figure of 1564 GL in 2007-08 is the demand from the Metropolitan Adelaide Water Supply System It includes water pumped through the Mannum Adelaide pipeline system and the Murray Bridge Onkaparinga pipeline system so therefore covers Adelaide plus the surrounding areas supplied from these pipelines The 176 GL figure in 2007-08 represents the above demand plus the usage from the other two major pipeline areas supplied from below Lock 1 (ie Swan Reach amp Tailem Bend)

92 On pg 2-12 the EIS says that in 2006-07 SA Water provided SA with just over 245 GL of water approximately 90 of which came from the Murray however in Table 1-1 on pg 1-2 2 it says SA used 1805 GL 79 of which came from the Murray

Response See Response to 91 above

Supplementary EIS for the temporary weir near Pomanda Island -83-

Supplementary EIS for the temporary weir near Pomanda Island -84-

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report

85

1 Introduction

Community Consultation Report purpose The Community Consultation Report is a companion document for the Supplementary Environmental Impact Statement (EIS) for temporary weir near Pomanda Island This Report is the record of activities completed during the public consultation period and a record of the submissions received on the draft EIS

This document demonstrates that the Department for Environment and Heritage (DEH) created a public interest context for the Environmental Impact Statement process

The Department gathered processed and responded to public submissions so that the Supplementary EIS was appropriately produced

Objectives for this Report are

to meet the requirements of the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act)

to record the actions of the Community Consultation process

to record all submission summaries and a response to them This is a significant aspect of the Community Consultation Report (Appendix IX)

to demonstrate that a diligent transparent and effective process was in place which optimised receipt of public submissions relevant to the draft EIS

Summary This document overviews

four Community Information Sessions about the Draft EIS for the general public targeted consultations with Ngarrindjeri and ten other specialist groups media generated during the consultation period processes for receiving submissions and for developing the Supplementary EIS

2 Community Information Sessions Advertising and materials distribution prepared the way for the Community Information Sessions

Community Information Sessions were advertised using newspaper advertisements the DEH website and the Coorong Lower Lakes and Murray Mouth Project (DEH) email Bulletin lists (See Appendix VI)

Draft EIS materials (CD hard copy Executive Summary) were distributed widely free of charge The full text Draft EIS was also made available in appropriately targeted local government offices and schools and a number of full text Draft EIS Appendices were also available Hard copy Draft EIS were available for $100 from one Adelaide retail outlet (See Appendix VI Distribution List)

Four Community Information Sessions were held as follows

Murray Bridge Tuesday 24 March 2009 1000am - 1230pm Uniting church Worship Hall Registered attendees 50 people

Meningie Tuesday 24 March 2009 300pm - 530pm Meningie Bowling Club Registered attendees 47 people

Goolwa Friday 27 March 2009 1000am - 1230pm Centenary Hall Registered attendees 93 people

Clayton Bay Friday 27 March 2009 400pm - 630pm Clayton Community Hall Registered attendees 53 people

Supplementary EIS for the temporary weir near Pomanda Island -86-

A total of 243 people attended the four Community Information Sessions

The agenda for these meetings were as follows

Community Information Sessions Agenda

Facilitator Lindsay Holmes (Meeting Success)

Session Length 25 hours

Timing Task Responsible person

(mins) 5 Welcome and Ground Rules Lindsay Holmes Welcome to Country 5 Explain purpose of Session Peter Croft 5 Introduce specialist panel Lindsay Holmes 20 Explain session agenda and process Hon Dean Brown

Water Presentation 25 EIS introduction presentation Russell Seaman 5 How to respond to the EIS Peter Lumb 5 Explain small group purpose Lindsay Holmes 15 Tea Break 20 Work in small groups Lindsay Holmes

Groups identify and prioritise questions for resourc e peop le

60 Resource people answer questions Chaired L Holmes 5 Meeting thanks and closure Peter Croft

Explanation of the agenda

The purpose of the Community Information Sessions was to provide information about the EIS process and to assist people in preparing their written submission (comment) on the draft EIS It was made clear that the sessions were about gaining information rather than making verbal public comment on the draft EIS

A range of options for lodging submissions was presented

At each Community Information Session there was a panel of five or six specialist resource people

Supplementary EIS for the temporary weir near Pomanda Island -87-

The panel was drawn from the following

Peter Croft DEH Director Coorong Lower Lakes and Murray Mouth Projects

Russell Seaman DEH Manager Environmental

Dr Kerri Muller Contract Ecologist

Ross Carter SA Water Manager Major Projects

Glynn Ricketts DWLBC Environmental Water amp Infrastructure

Judy Goode DWLBC River Murray Environmental Manager

Hon Dean Brown Drought Reference Group

Premier s Spec ia l Advisor on Drought

Paul Harvey Murray Darling Initiative

Program Leader

Jan Whittle SA Murray Darling Basin NRM Board

River Murray Environmental Manager Unit

The panel of specialists was introduced early in each meeting prior to two major presentations

Russell Seaman gave a PowerPoint presentation which overviewed key aspects of the draft EIS for the proposed temporary weir near Pomanda Island

The Hon Dean Brown gave a PowerPoint presentation which provided a Murray-Darling Basin water issues context for the proposed temporary weir

Participants formed groups of eight with a trained DEH facilitator The purpose of the group fac ilita tion was to write questions on la rge post-it notes These questions were to be sorted and answered by the specialist panel

As group facilitators wrote questions the questions were continuously collected and placed on a wall Specialist panel members gathered and discussed who would be the most appropriate panel member to answer each question Like-questions were assembled with like Duplicate or overlapping answers were avoided

The meeting regathered and the specialists answered questions in an open manner

DEH provided a light meal at the end of each Community Information Session Community members were invited to stay on after the meeting to informally discuss issues and ask questions of the specialists Many members of the public accepted the invitation

This meeting format allowed all community members the opportunity to ask questions hear answers from people with specialist knowledge and then to engage with them further This was a successful format for the purpose of sharing information A large number of questions were answered and the community had maximum exposure to specialist panel members Panel members and community members generally responded favourably to this format

The records of these meetings include the wording of each question submitted to the specialist panel (Appendix IV) A summary of broad indicative categories of questions are included in Appendix IV including a graph consolidating answers from the four Community Information Sessions

People who attended the Community Information Sessions were invited to pre-register via email at eisdehsagovau or to register through an EIS 1800 number hotline (Appendix VIII) Registrations were sought to ensure that venues had sufficient capacity there was a sufficient number of group facilitators and so that catering was adequate Registrations were also accepted on entry and all registrants were supplied with a

Draft EIS Executive summary

CD containing a submissions cover sheet the Executive Summary the full text Draft EIS and all Appendices of the Draft EIS and

paper summary of the main PowerPoint Draft EIS presentation

Registration also provided the option for people to provide an email address so that they could receive Coorong Lower Lakes and Murray Mouth project updates

Supplementary EIS for the temporary weir near Pomanda Island -88-

In addition copies of Sim T and Muller K (2004) A Fresh History of the Lakes Wellington to the Murray Mouth 1800 to 1935 SA Murray Darling Basin Natural Resources Management Board Government of South Australia were available to registrants courtesy of the MDB NRM Board

3 Targeted Meetings The Ngarrindjeri People individually and collectively are involved in ongoing consultation about the about the Draft EIS for the proposed temporary weir near Pomanda Island Consultation about the Long Term Plan for the Coorong Lower Lakes and Murray Mouth will be ongoing

Ten targeted meetings were held between 2 February and 2 April 2009 Two meeting were held in Adelaide and eight were in the region (Appendix III)

The targeted meetings were attended by Peter Croft Director Coorong Lower Lakes and Murray Mouth Projects and Russell Seaman Manager Environmental (Department for Environment and Heritage) Peter Croft briefly discussed the developments leading towards the Long Term Plan for the Coorong Lower Lakes and Murray Mouth while Russell Seaman provided the PowerPoint presentation used for the Community Information Sessions but tailored the presentation towards the interests of particular audiences Brief records of these meetings appear in Appendix V

In each case these targeted meetings were scheduled meetings which allocated time on their agenda for the additional presentations about the Draft EIS and the Long Term Plan

4 Overview of media articles (see Appendix VII) This section provides the media context during the time leading up to the opening for public comment on the Draft EIS for the proposed temporary weir near Pomanda Island (12 March) to the close of the comment period (9 April)

In January and February 2009 med ia foc ussed on d isc ussions about flood ing the Lower Lakes Two of the 15 stories provided mention of the proposed temporary weir Through March when the Draft EIS for the proposed temporary weir near Pomanda Island was released 18 of the 20 articles focussed on the proposed weir Some media reporting (as summarised by Media Monitors) did not clearly differentia te between the EIS for the flood ing of the Lower Lakes and the EIS for the Proposed Temporary Weir indicating and exacerbating some public confusion

Main discourse The South Austra lian Government s ma in message was tha t the weir is a last resort tha t will only proceed if absolutely necessary in a worst case scenario situation The South Australian Government is committed to seeking a fresh water solution - they do not want to build the weir

A consistent criticism of pursuing approval for the weir is that it indicates that the South Australian Government has given up on a freshwater solution The media surveyed indicates that a fresh water solution is the preferred and only suitable option If the South Australian Government was serious about providing a solution media discourse suggests they would use the money to purchase water rather than for construction of the proposed temporary weir

Many who are opposed to the weir are of the opinion that the government has already made its decision and the weir will go ahead

Other issues raised There were several other issues raised in the articles including

the proposed temporary weir will cut off the River Murray from the Lower Lakes (one article)

there are alternatives to the weir such as storm water harvesting and more water efficiency (one article)

if the weir is built it is a temporary weir and temporary solution and the final decision on the weir will come six months prior to decision to flood the lakes (one article)

the number of regulators and weirs being planned in addition to the proposed temporary weir Clayton Finniss Latham Point Goose or Goat Island (two articles)

Throughout the majority of articles the weir was referred to as the weir or the Wellington weir and approximately 10 per cent of the time it was called the Pomanda weir

Supplementary EIS for the temporary weir near Pomanda Island -89-

A media release by the Federal Minister for Environment Heritage and the Arts mentioned the need for a long term vision and noted that the Australian Government has committed $200 million from its Water for the Future Plan to assist in the planning process and an additional $10 million towards the development of a long term plan for the Coorong and Lower Lakes

Two media reports expressed concern about the triggers to remove the proposed temporary weir saying that unless increased salinity and acidification levels are addressed and there is freshwater released into the lakes one of the triggers that salinity levels drop below 3000EC - will not be able to happen

Summary

Media analysed

Medium (Total) Channel Number ABC 16 5AA 5Radio (22) Triple M 1 9 Network 2 10 Networks 1Television (4) ABC 1 1 Independent Weekly 1 Adelaide Advertiser 1 Stock Journal (Regional) 3 Times Victor Harbor 1 Murray Valley Standard 1

Print (8)

Lakelander 1

Media release The Hon Peter Garrett Minister for the Environment Heritage and the Arts (one)

Four were regional stations five were Adelaide metropolitan stations and seven were both Adelaide metropolitan and regional stations

Total - 35

5 Receiving submissions and developing the Supplementary EIS The Draft EIS was open for public comment from the 12 March to 9 April 2009

The public were invited to provide written submissions as emails as emails with word attachments or to send hard copy using a free post address

Seventy submissions were received from the public There were 49 individual submissions 18 from community and other organisations and three from local government All submissions are available on DEH website wwwenvironmentsagovaucllmmsubmissions-receivedhtml

Submissions were uploaded twice per week during the public comment period Submissions were listed by author or organisational author as per Appendix I and Appendix II

Supplementary EIS for the temporary weir near Pomanda Island -90-

Timeline of the post-Community Consultation period

9 April Acceptance of submissions closed at 5pm

10 13 April

During the four days over Easter submissions were read summarised and a statement provided in a response column Key words in submissions were identified Summaries and responses were entered into a specially prepared Microsoft access data base Summaries from the data base are provided as appendix ix

14 April

A list of key words was compiled from the access data base The data base was then searc hed by a ll relevant key word s All sub missions jud ged to be in sc ope and a ssoc ia ted with a key word or key word string were then assembled Submissions were then sent to thirteen specialist writers Most writers had attended a meeting at which the requirements for preparing responses were outlined and the constraints of the tight timeline emphasised Other writers had individual briefings Writers could choose to receive hardshycopy of all relevant submissions or access copy on the internet The broad objective provided to writers was to create an over view summary of issues in response to issues associated with the key words for which they were responsible

15 17 April Specialist writers had three days in which to write their over view summaries

17 April Summaries were returned for compilation into the supplementary EIS and an executive writer and assistants then had six days to create an integrated supplementary EIS

24 April A draft of the supplementary EIS was prepared and sent to specialist writers for comment to be returned by 12pm Monday 27 April

27 April

Comments were incorporated into the draft of the supplementary EIS and a new version prepared for a briefing meeting on Tuesday 28 April The objective of this meeting was to facilitate final changes before chief executive and ministerial sign off

30 April The supplementary EIS was prepared and sent to the chief executive and the minister s offic es

Supplementary EIS for the temporary weir near Pomanda Island -91-

Supplementary EIS for the temporary weir near Pomanda Island -92shy

Government of South Australia

Supplementary Environmental Impact Statement for the temporary weir near Pomanda Island

Part tWO Community Consultation Report ndash Appendices

93

Appendix I Submissions received Individuals

Surname First name Suburb Date Submission

number

Cooke Roger Goolwa 29032009 PTW00001

Galea Michael Clayton Bay 30032009 PTW00002

Fargher Philip Norwood 01042009 PTW00003

Zoerner Andrew Prospect 03042009 PTW00004

Smith Douglas Goolwa 03042009 PTW00005

Rees Melanie Henley Beach 03042009 PTW00006

Brisco Mike Campbelltown 04042009 PTW00008

Moyle Ian Woodcroft 05042009 PTW00009

Harvey Richard North Adelaide 06042009 PTW00011

Richards Sally Finniss 06042009 PTW00012

Giles Trevor Langhorne Creek 06042009 PTW00013

Lower Brenda Goolwa 06042009 PTW00014

Michelmore Frederick Gordon Middleton 07042009 PTW00015

Lucas Ann Goolwa 07042009 PTW00016

Jones Glen Adelaide 07042009 PTW00017

Fenton Derek Finniss 07042009 PTW00019

Tjukonai Vesper Meningie 07042009 PTW00020

McFarlane Keith Tailem Bend 07042009 PTW00021

Read Tony Beaumont 07042009 PTW00023

X Mick Mannum 08042009 PTW00024

Hartnett Anne Milang 08042009 PTW00025

Whitehead Alexander Hindmarsh Island 08042009 PTW00027

Fairweather Peter Adelaide 08042009 PTW00028

Thomas Robert Goolwa 08042009 PTW00029

Carroll Barbara Happy Valley 08042009 PTW00030

Jones Henry Clayton 08042009 PTW00031

Bagley Chris Milang 08042009 PTW00033

Yelland Liz Milang 09042009 PTW00034

Vonow Lynton Lobethal 09042009 PTW00035

Trigg Ruth Normanville 09042009 PTW00036

Yelland John Milang 09042009 PTW00037

Brooks Bruce Finniss 09042009 PTW00038

Walker Keith Yankalilla 09042009 PTW00039

Harden Trevor Finniss 09042009 PTW00041

Allnut Bruce Finniss 09042009 PTW00042

Shillabeer Neil Oakbank 09042009 PTW00043

Heyne Ron Goolwa 09042009 PTW00044

Showell Jacqui Goolwa Beach 09042009 PTW00048

South Cecily Milang 09042009 PTW00049

Moon Silver Finniss 09042009 PTW00051

Supplementary EIS for the temporary weir near Pomanda Island -94-

Surname First name Suburb Date Submission

number

Hunter Rex 09042009 PTW00052

Bradford Karen Milang 09042009 PTW00059

South Mike Milang 09042009 PTW00060

Belford Beryl Mt Barker 09042009 PTW00063

Hobbs Elizabeth Goolwa 09042009 PTW00064

Vizard Talina Victor Harbor 09042009 PTW00065

Carter Carlsa Bridgewater 09042009 PTW00066

Scobie Keith Meningie 09042009 PTW00069

Russell Ruth Magill 16042009 PTW00070

Young amp Jury Mike amp Ken Goolwa 16042009 PTW00071

Submission received under special circumstances Submission sent prior to end of community consultation period

Supplementary EIS for the temporary weir near Pomanda Island -95-

Appendix II Submissions received Organisations

Organisation Date Submission

number

Southern Alexandrina Business Association Inc 04042009 PTW00007

Signal Point Riverine Environment Group Inc 05042009 PTW00010

Alexandrina Council 07042009 PTW00018

The Marina Hindmarsh Island 07042009 PTW00022

SA MDB NRM Board 08042009 PTW00026

Rural City of Murray Bridge 08042009 PTW00032

Australian Institute of Landscape Architects 09042009 PTW00040

Ngarrindjeri People 09042009 PTW00046

DTEI 09042009 PTW00047

Environmental Defenders Office (SA) Inc 09042009 PTW00050

The Coorong District Council 09042009 PTW00053

River Lakes Coorong Action Group Inc 09042009 PTW00054

Nature Conservation Society 09042009 PTW00055

Murray-Darling Basin Authority 09042009 PTW00056

Australian Democrats 09042009 PTW00057

Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

09042009 PTW00058

PIRSA Fisheries 09042009 PTW00061

Natural Heritage Trust 09042009 PTW00062

Conservation Council of South Australia 09042009 PTW00067

Goolwa District Ratepayers and Residents Association Inc 09042009 PTW00068

Supplementary EIS for the temporary weir near Pomanda Island -96-

Appendix III Participants and notes from Targeted Meeting Sessions

Local Knowledge Reference Group

Date Wednesday 4th February 2009 1100am 200pm Location The Monastery

In attendance Dean Brown Bill Paterson Prof Diane Bell Mike Geddes Mike Hammer Neil Shillabeer Paul Davis Rebecca Lester Rob Fitzpatrick Sebastian Lamontagne Mary-Anne Healy

Summary of comments or issues

Draft EIS was presented to the Local Knowledge Reference Group (LKRG) - draft is confidential

Consequences of weir removal and ability for system to recover

Scope of EIS should extend beyond matters of NES

Management strategies for potential flooding should be addressed in the EIS

Approvals process

Concerns regarding high water mark in relation to the causeway and Ramsar boundaries

Apologies were given to the group in regards to the lack of communication around the draft EIS in the past

Discussion

Raised issue re water levels relating to the barrages should say 7000 years

Changed the word ing to levels never rec orded ra ther than not seen sinc e the c onstruc tion of the barrages

No work has been done on how to recover the environment after the removal of the weir

Not going to remove the roads and tracks

Impacts locally not Ramsar site

Weir sinks over time

Remove down to bed level should not be any impediment to what was originally there

Will take time but should result in no impact

Weir will be there for 3 years

SA Water suggests there will be minimum impact

Mud waves will cause impact but will be transported away from sedimentary processes

Increased sedimentation as a result of the structure and disagreement that there will be a significant impact after the removal

The need to conserve the Ramsar wetland and what might be the implications Is it just going to go ahead Worried about the significant damage and if the system will ever recover

Cannot assess what has been done Needs clarity about the purpose of the group

Issues around rates of change and thresholds associated with the weir Also life stages and ecological character

Limited scope about this in the EIS only addresses matters of NES

Will edit the factual errors

Will help edit as well

Worried about experts need for higher level expertise for public comment period

Supplementary EIS for the temporary weir near Pomanda Island -97-

What if there are natural water flows floods Recovery Should be reference in the document to flood event happening and the ability to manage that

Agrees with Bill and need to understand and have something in place if there is a flood and removal of the weir

States that the draft EIS seems to have solid blame on the drought but over-allocation and excessive use are contributing factors as well Look at the language and justification of the EIS Issues about the decision making Commonwealth SA Gov

Understands that it goes to Commonwealth and SA Govt makes the decision Need approval under the EPBC Act

Need approval for MDBA and Minister

Interested to see if the Ramsar site is actually the boundary of where the weir will be built and the implications of that and whether the weir can take place

Drew a diagram of where the cadastral boundary is and where the causeway and proposed temporary weir are Assuming this is where the high water mark is

The whole group are concerned that the high water mark is actually exceeding where the causeway is and if that is the case the causeway and where the weir will be built will actually be in the Ramsar site

Supplementary EIS for the temporary weir near Pomanda Island -98-

Meningie Community

Date Thursday 5th February 2009 700pm 1100pm Location Football Club Rooms Meningie

In attendance Approximately 200 locals Andrew Beal Prof Diane Bell Robyn McLeod Dean Brown Peter Croft AProf David Paton

Summary of comments or issues

Dean Brown Prof Diane Bell Andrew Beal Peter Croft Robyn McLeod and AProf David Paton each gave a short presentation on current issues based around the Coorong and Lower Lakes providing management options

Summary of conditions and long term plans to help secure a future for the Lower Lakes Coorong and Murray Mouth

Following the presentations the community members were given the opportunity to ask questions of the presenters

Neil Shillabeer facilitated the meeting

The meeting was a little heated and closed around 11pm with people staying to speak with the presenters and other expertsofficials

Questions and discussion

What can we do to make other states realise that we are in a dire situation and that we need more water

What is temporary

Groundwater

Over-allocation

Where is the support for the community

Ngarrindjeri hurting no one is speaking with them or the community

What are the government officials going to do to help the community

Yes they are helping the environment but not the economic values and people

Why c an t they have a p ipeline like the other side (referring to the Langhorne Creek irrigation line)

Why haven t they been told about the c osts involved with this p ipeline

Lake Albert s a lloc a tion

What level will the Lakes be once the weir is in place

What are the trigger points for removal

If the weir is built are they going to put in fish ladders or will they be blocked

If Lake Alexandrina gets lower how are they going to continue pumping into Lake Albert

If seawater is let in how are they going to deal with the millions of dead fish and the clean up

How are they going to fix South Austra lia s own wa ter issues and a lloc a tions Need to address what is happening here before we blame upstream

Supplementary EIS for the temporary weir near Pomanda Island -99-

Milang Community

Date Thursday 12th February 2009 130pm 500pm Location Milang Institute Building

In attendance Anne Hartnett Dianne Bell Ken Follett Tim Trevorrow (APOL) Rowena Brown Dr Rob Fitzpatrick Bruce Brooks Graham Gates Lesley Fischer Tony Randall Peter Alexander Wayne Brown Carol Richardson Greg Lundstrom Richard Owen Peter Croft Clare Manning Russell Seaman Karyn Bradford Kathryn Rothe Shirley Smith Liz Barnett Simon Oster

Summary of comments or issues

The Lower Lakes Partnerships for Recovery

Lower Lakes communities are keen to use their knowledge labour and community infrastructure to bring about Lakes and River recovery

The community seeks partnership with government to

- Rescue and remediate degraded environments

- Impede further degradation

- Instigate environmental management and development practices

- Address current and future effects of climate change

Projects have been identified for both immediate and long term implementation

Revegetation Revegetate areas subject to Acid Sulfate Soils with plants having low impact on soil

saturation in

- Priority areas in Finniss River and Currency Creek

- Receding lake shores

- Known ASS hot spots

- Spots at-risk of drying out wind erosion and sun exposure and affected by stock access

Revegetation capacity building Collect seeds for replanting (native plants)

Undertake at-risk plant rescue and propagation

Purchase propagation and planting of annuals

Plant large trees away (upwind) from Lake edge as leaf litter will provide sources of organic matter and iron to Lakes (builds resilience)

Flora and fauna protection Control of increased feral populations arising from revegetation

Establish refuges for endangered flora (and fauna)

Weed control

Protecting fringing vegetation Protect lake revegetation areas from cattle

Protect cattle from poor quality drinking water

Environmental remediation Community Acid Sulfate Soil treatment projects

Source local limestone for application to ASS

Supplementary EIS for the temporary weir near Pomanda Island -100-

Nurture and capture knowledge

Train communities to identify and map plants useful for land protection and remediation

Create systems for long term monitoring of soils vegetation growth and regrowth

Establish community survey systems to map current and changing status of soils

Collect and contribute data that will enhance GIS data banks and veracity

Create local administrative and data collation processes to manage the above incorporating two-way communication and mutual benefit from data

Monitor water use to aid in the beneficial allocation of water resources

Supplementary EIS for the temporary weir near Pomanda Island -101-

Peter Croft s Murray Futures update for the Lower River Murray Drought Reference Group representatives

Date Thursday 26th February 2009 200pm 500pm Location Murray Bridge

Summary of comments or issues

Status of Environmental Impact Statement for the proposed temporary weir near Pomanda Island

Timelines for the project

Community involvement

Timelines for the Long-Term Plan to secure a future for the Coorong and Lower Lakes Ramsar site

Community Action Planning

Information provided

EIS has not yet been finalised or lodged but is in the critical final stages and is expected to be lodged shortly

We will be holding some Community Information Sessions in the 4th week of March (pending approval from the Commonwealth)

There will be a media release of notices via national state and local press announcing the sessions locations and times to inform the communities (subject to Commonwealth approvals)

These sessions are to summarise the draft EIS allow community members to ask technical questions of some specialists and provide advice to the community on preparing submissions on the draft EIS

A Reference group has been developed (The Long-Term Plan Reference Group) and brings together community leaders scientists and government staff with a view to develop a long-term plan to secure a healthy future for the Coorong and Lower Lakes Ramsar site

This is an important first step to help identify a realistic sustainable future for the region one that will address the environmental community and economic values that are important to the region

Our aim is for a coordinated management response for the future of the Coorong and Lower Lakes And involving the community along the way is critical to the success of our work

We are aiming for a 1st version of the Long-Term Plan ready for public consultation in April We will ensure that a range of different communities get on the list of possible locations (eg Milang and Langhorne Creek)

Notices of such events will be distributed through the national state and local press as well as our website

On 12th February we met with representatives of Landcare Groups and Local Action Planning Groups to discuss proposals for community action around the Lakes

A number of areas of action were identified and a small team with representatives from DEH Regional Conservation Team and LAP Coordinators will flesh out the actions in more detail

A Plan of Action is being developed for trial projects with potential funding of $100000 that may be available to support some preliminary work We plan to finalise the details and get activities rolling ASAP

Supplementary EIS for the temporary weir near Pomanda Island -102-

Ramsar Taskforce Committee

Date Friday 13th March 2009 1100am 1230pm Location Wyndgate

In attendance Ramsar Taskforc e c ommittee members Peter Croft Russell Seaman and Peter Lumb

Summary of comments or issues

Peter Croft briefly introduces EIS processes and distributes draft EIS community development and hard copy Executive Summary

Russell Seaman gave a presentation in the EIS and asks for feedback

Broad range of questions ranging from fish ladders in the weir to alternative options

Questions and discussion

Will the Supplementary EIS be made public

Will the Australian Government then require community consultation on the Supplementary EIS

Why is there such a short time for public comment on the draft EIS

What do you mean by environmental hotspots

Has any thought been given to a natural causeway near Pomanda Island

Is the weir site within the Ramsar site

Where will the water come from to flow over the weir if a weir is built

Comment about the importance of fish ladders

Emphasise that the weir is not a trigger for sea water incursions

Emphasise that the presentation is mostly based on worst case scenarios

The EIS must mention over-allocation

Emphasise actions taken or about to be taken when possible

Emphasise terrestrial vegetation more as well as Lake bioremediation

How much employment will be created in the region

Is it possible to have Councils administer vegetation and bioremediation projects rather than the Attorney-General

Supplementary EIS for the temporary weir near Pomanda Island -103-

Scientific Advisory Group (SAG)

Date Monday 16 March 2009 930am 1130am Location L5 81 Flinders Street Adelaide

In attendance Rebecca Lester Ingrid Franssen Mardi van Wielan AProf David Paton Adrienne Frears Glynn Ricketts

Summary of comments or issues

Decision trees and timelines

Alternative options

Trigger points

Questionscomments

Needrequest to set aside 5 for science to underpin management

Lake Albert needs early consideration

Need a decision tree as some actions are alternatives or consequent actions

Link decision tree to timeline and water flows

Need to account for measures for Long Term Plan to prevent the need to do reactive work again in ten years

Assumption restore wetland functioning to build resilience

Focus on upper Finniss and Currency dam bypasses upstream modelling water allocation and managing low-flows

Scientific Advisory Group can assist with advice if needed

Pomanda weir s estimated c ost $150m

Need to find out if there is a major ecological downfall if the acidification occurs

Reduce or stop pumping for winter lower evaporation and stop wind erosion

Apply limestone only when triggers are reached

Any ideas for the Long-Term Plan will influence the second version of the Plan

Ephemera l systems a re na tura l Lake Albert is a termina l wetland no outflows

A more complete document will allow a more thorough examination of the situation (possibly in April)

Which trigger will come first

Is a virtual weir still on the table

Does the dam allow for a fishway

Supplementary EIS for the temporary weir near Pomanda Island -104-

South Australian Murray-Darling Basin Natural Resource Management Committee

Date Thursday 19 March 2009 930am 1200pm Location Murray Bridge

In attendance SA MDB NRM Board members Peter Croft Kerri Muller and Lindsay Holmes

Summary of comments or issues

Questions focussed on conditions climate and the environment

Questionscomments

How will the weir be deconstructed

Can we separate the effect of the weir from the effect of the drought

Is the 350GL of wa ter over the weir in c urrent c ond itions

Will water go into the Lake when there are disconnection issues

Will there be a short-term increase in salinity while the pool fills

What is the current river level

Does the EIS consider scouring

Is flooding risk considered (in EIS)

Mud waves are a major issue

Why will construction of the weir be worse during summer

What are other alternatives

When does the EPBC Act review end

Can we make a definitive statement about what happens to the wetlands

Supplementary EIS for the temporary weir near Pomanda Island -105-

Icon Site Community Reference Committee

Date Monday 23rd March 2009 930am 1200pm Location Langhorne Creek Bowling Club

Summary of comments or issues

Questioned the science and experts available

Alternative options were discussed

Questioned engineering aspects of the weir

Russell Seaman presented an overview of the draft EIS

Group showed concern for repercussions of actioninaction

Questions asked

Coorong evaporation 200GL of fresh or seawater

Who will DEH engage as experts to advise on seawater incursion

What will DEH be basing their knowledgeevidence on in regards to the seawater incursion

Has anything like it been done before

Mulching

Limestone locally sourced

Coorong North lagoon monitoring and ASS who is monitoring and what is being done to remediate the hyper-saline conditions

To what extent can we replicate what was in the past southeast freshwater

Salinity in the south lagoon would the level allow Rupia sp to establish itself

Mechanical mouth operation as opposed to dredging has this been considered

What are some other options

Has the department looked at Vortex sand pumping

Will there be culverts between the Lakes through the causeway for water to flow via wind seiching

More research needs to be done has the Department considered engaging the local knowledge Don t dup lic a te researc h

If temporary why are you considering installing fish passages in 5 years time Should that not be done at the time of the weir installation

What levels are you looking at for the lakes

Supplementary EIS for the temporary weir near Pomanda Island -106-

Russell Seaman presentation Overview of the draft EIS for the temporary weir near Pomanda Island

Questions asked Why 01 AHD for the spillway

At what Lake level will it start acidifying

Should we have a lower weir

What is the risk of salt levels increasing when you stop the flows for 3 months

Will ground waters be coming in

What about the banks collapsing

What is the water quality of ground water and will it contaminate the Lakes

What happens if water flow exceeds 15GL per day ie if flood occurs will the structure cope

How quickly will the structure sink is it 1m per year

Will the weir be in place by 1st January 2010 as the graph indicates

When is -15 AHD expected

Has the Premier decided to buy water to see the Lakes through to winter 2010

Have you factored in the local rainfall flows within Currency Creek and Finniss

Is there an indication of seepage of ground water into any region of the Lakes

Have you looked at Biochar for remediation purposes

Lime straight pH neutraliser or feed the bacteria

Why not put a carbon source in there as well

Supplementary EIS for the temporary weir near Pomanda Island -107-

Lower River Murray Drought Reference Group

Date Thursday 2nd April 2009 Location Murray Bridge Council Chambers

Chair Dean Brown In attendance 14 Reference Group members 15 people in the Public Gallery

Summary of comments or issues

EIS Presentation by Peter Croft 30 Minutes including questions

Peter Croft presented overview of the draft EIS

Issues relating to seepage

Costs and issues relating to weir construction

Weir removal

Timelines for weir construction

Questions and comments

All questions asked were from Reference Group members with occasional comments from the public gallery

If the weir is built will more wetlands be closed between the weir and Lock 1

Are estimates being made of loss of water to seepage through the cracked levee banks above the weir And will this seepage appear in the Lake

Will it be the case that water will stop flowing over Lock 1 at some stage to facilitate the construction of the weir

Adrian Pederick MP asked who wrote the draft EIS

Member referred to a rumour that irrigation will cease with weir construction

Can you be clear about the cost of the temporary weir if built

Is the cost of the causeway included

Where will the SA Government get the money to construct the weir (Some anxiety that it would be CLLMM money (Comment wasn t c learly aud ib le)

What is the likelihood of a virtual weir

There was a question (inaudible) about the height of the weir above sea level (Was it about the adequacy of the height to secure water supply if the Lake levels rose)

How much of the weir would be removed when decommissioned

Comment about the complexities of start times and the apparent late start to protect water supply

Update on other matters Peter Croft Closing date for submissions on the draft EIS on proposed temporary weir

Promotion of availability of all documents and information sources

The Goolwa Channel referral lodgement is imminent

Actions Application for projects under $120000 April 10

Approvals process for lime-stoning the first flush coming down the Finniss and Currency Creek

Seeding and bioremediation workshop held Tuesday 31 March

Rural Solutions developing a bioremediation plan around both Lakes

Supplementary EIS for the temporary weir near Pomanda Island -108-

Appendix IV Organisations that participated in Community Information Sessions

The Advertiser

Department for Environment and Heritage

University of South Australia

La Trobe University Centre for Sustainable Regional Communities

Native Food

Investigator College

River Lakes and Coorong Action Group Inc

South Australia Murray Darling Basin Natural Resources Management Board

River Murray Boat Owners Association

River Murray Museum of River History

Department for Sustainability and Environment

Wellington Lodge Pty Ltd

Ranges to River NRM Group

Food and Beverage Australia Ltd

Narrung Wetland Monitoring Group

BMT-WBM (Engineering and environmental consultants)

River Lakes and Coorong Action Group

All Land and Livestock

Clayton Bay Community Association

Finniss Catchment Group

Southern Alexandrina Business Association Inc

Coorong District Council

Narrung Dairy Farmers

Southern Fishermen s Assoc ia tion

Clayton Bay Foreshore Committee

SA Water Corporation

Fleurieu Regional Development

Alexandrina Council

University of Adelaide

Supplementary EIS for the temporary weir near Pomanda Island -109-

Appendix V Participants and notes from Community

Information Sessions

Community Information Sessions Agenda

Proposed Locations Meningie Murray Bridge Goolwa Clayton Bay Facilitator Lindsay Holmes (Meeting Success) Session Length 25 hours

Timing Task Responsible person

5 min Welcome and Ground Rules Lindsay Holmes

Welcome to Country

5 min Explain purpose of Session Peter Croft

5 min Introduce specialist panel Lindsay Holmes Explain session agenda and process

10 min Water Presentation Hon Dean Brown

25 min EIS Introduction presentation Russell Seaman

5 Min How to respond to the EIS Peter Lumb

5 min Explain small group purpose Lindsay Holmes

15 min Tea Break

30 min Work in small groups Lindsay Holmes Groups identify and prioritise questions for resourc e peop le

40 min Resource people answer questions Chaired Lindsay Holmes

5 min Meeting thanks and closure Peter Croft

Supplementary EIS for the temporary weir near Pomanda Island -110-

Meningie Community Information Session

Date Tuesday 24th March 2009 300pm 530pm Location Meningie Bowling Club

Questions asked of the specialist panel listed by category

Lake Albert Is pumping going to stop or continue at Lake Albert

In worst case scenario what will be done about Lake Albert if it runs dry

Assuming a weir will be built what actions will be taken to maintain Lake Albert

What is the future for Lake Albert

Why isn t Lake Albert written up more in the d ra ft EIS

River flows Why are upstream tributaries not included in the flow data considering it is the Murray-Darling Basin system (The information is then misleading for Min Garrett)

Inflow figures Are these figures based on whole basin or just the Murray River catchment

Is there information on how much water is coming in to the basin catchment (not just inflows)

Is 350GL guaranteed to come over the weir per annum Is that happening now

How will the weir pool level be maintained ie Where will the water come from Does this relate to water buy back

Why c an t some of the wa ter held on fa rm dams etc be released and peop le use a little less water to maintain levels (federally)

What measures are being considered to improve sharing and saving water throughout the Basin

How much area is considered Murray-Darling catchment

put in place to use alternative storagemake Adelaide less dependent on the Murray

Ramsar How will the Ramsar convention be respected

Australia signed the Japan-Australia migratory birds agreement (also with China) re wetlands of international significance How will the weir effect this agreement

Is government looking at taking control re Ramsar site

Wildlife What happens if there is a fish kill in Lake Albert

Will the weir affect cod numbers and is there a plan to recover this species

Has the magnitude of a fish kill been considered ifwhen the weir is built Consider Lake Albert amp Lake Alexandrina separately

What will happen to the fish turtles etc if salinity increases

Acid Sulfate Soils (ASS) Why hasn t the government looked a t other op tions for remed ia tion for ASS

What is the long term planmedium term plan for Lake Albert and the ASS issue

What is the gas that comes out of the mud in Lake Alexandrina (Three cases of dizziness when exposed to this)

What can be taken out of Menindee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Alternative catchments Adelaide is now taking 90 water from Murray What is being

Wha t c an be ta ken out of Menind ee La ke (Wa sn t mentioned in the storage in Dea n Brown s p resenta tion)

Supplementary EIS for the temporary weir near Pomanda Island -111-

Salinity issues What mitigation strategies are in place to mitigate hyper-salination in the Lakes

Salt water sits beneath fresh water How will the salt water flow over the weir

If the weir is pumped is the pumped-out water saltier

Does the salt water layer

How are they going to flush the salts that accumulate in the weir pool

What is the evaporation rate per annum at the present time considering the Lake levels today Is it still 800GL

Rainfall Was there rainfall measured over Lake Alexandrina in winter last year (No rainfall measured by farmers)

Why doesn t the d ra ft EIS mention Lake ra in

Will decreasing the surface area of water in the Lakes reduce rainfall over the Adelaide catchment increasing the strain of Adelaide Hills reservoirs

Proposed temporary weir impacts How is the weir going to be removed

What is the trigger point for the weir decommissioning

Given the modelling and g iven the government dec ides to build the weir why isn t a lock considered Would allow navigationfish passageflow management

Why is there no facility for navigation through the weir

Why a re there no fishways Why isn t it nec essa ry to have fishways

Is the base of the weir stable enough to stop slippage of the structure

How will they monitor the silt on the downside of the weir and particularly with ASS

Will time to fill the weir pool be more than three months (based on worst-case scenario) Will some leak out under the levee banks

When would construction start

What would it cost to move the intake points above Lock 1

Will the weir help mitigate acid soils in the Lower Lakes

Why does the EIS not address much between Lock 1 and the weir in relation to damage of embankmentshabitat above the weir

How can they guarantee that removal of the weir will allow things to go back to the way they were

Social and economic impacts What consideration has been given to sustaining cultural flows for Indigenous people

Are the social impacts of building the weir and low flows being considered in the decision to build the weir

What provision has been made in the EIS for socio-economic impact factors

Seawater If seawater is let in how far into the groundwater will the seawater penetrate What will be the impact on the level of groundwater

How will the weir affect the decision to allow seawater into the Lakes

How does the weir link with the seawater incursion and will it need another EIS

Politics and Government When is the Murray-Darling Basin Authority going to get up and running (currently only a CEO and Chairman) If it were in place then politics will be in order ()

There have been a lot off government bodies set up over the last few years What has their role been and what is their role now

What is the government doing to educate the public

Supplementary EIS for the temporary weir near Pomanda Island -112-

Miscellaneous Have the trigger points been addressed

Will the weir guarantee water for stock from existing pipelines

Will the weir cause impact on the positive impact that wind seiching plays in the system

Do submissions all go together to the Commonwealth

What will happen when a flood occurs at the Narrung pumping station Will it be removed and the channel opened

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 2 fishways) 14 River flowsallocations 11 Salinity issues 6 Lake Albert 5 Wildlife (Fishturtles) 4 Social and economic impacts (one Indigenous) 3 Ramsar 3 Sea water incursion 3 PoliticsGovernment 3 Acid Sulphate Soils 3 Rainfall (Lake rain) 3 Miscellaneous 4

Supplementary EIS for the temporary weir near Pomanda Island -113-

Murray Bridge Community Information Session

Date Tuesday 24th March 2009 1000am 1230pm Location Uniting Church Worship Hall

Questions asked of the specialist panel listed by category

Acid Sulfate Soils (ASS)

What effect will the weir have on the current situation of Acid Sulfate upstream given that the weir will not be constructed within the next three years

How extensive are the potential Acid Sulfate areas

How deep does the lake need to be to prevent ASS

What is the plan to deal with acidification post weir

What is worse Seawater or lake acidification

Salinity issues How will salt get back into the Lakes

What measures will be taken to address salt building up behind the weir (upstream)

How can you handle the salt (that will come down the river) How will it be managed

Have you considered installing pipesregulators to manage salinity at the base of the weir

Wildlife What evidence do we have that the birds will return after construction

Have we calculated impact of extinctions

River flows allocations Is there a lot of water available for sale

Why hasn t temporary wa ter been purc hased

What about buying water as an alternative to a weir

If a weir is built will there be more water allocations in SA

If the weir goes forward who will receive the water that will be saved from less evaporation Will the allocation be more

18 wa ter a lloc a tion Universa l na tiona l standard set a lloc a tion Why isn t there an agreed allocation standard to all usersirrigated Why not a special rule to override current allocation agreements

Has there been an audit on un-metered bores in the Basin and what action is being taken

How much have extractions increased and what were base extractions

Developed methods to estimate inflows model for calculating extractions How much water is prevented from entering the system Where do extractions go Why is there no graph for extractions for entire systems How is the flow calculated Where is this information available

What is the definition of inflows

Where is the water coming from to maintain the level of the weir pool and the river level

What are the differences in water quality in the channel with or without a weir How serious is the situation What about the use of water upstream Over-allocation

Proposed temporary weir Has consideration been given to the weir at Wellington having a fishway

Will the weir pool inundate the wetlands upstream

How will the water and salt discharge over the weir into Lake Alexandrina Spillway Gate

How will the process prevent the build up of algal blooms and nutrients behind the weir

Supplementary EIS for the temporary weir near Pomanda Island -114-

What will build up behind the weir (eg iron etc)

Water hitting the weir what is going to happen

Why a temporary weir Why remove it and rebuild it

When the weir is deconstructed what happens to debris rocks etc

What will the volume of seepage be What are the implications

Will construction of the weir begin in June

What are the trigger points for removal of the weir

Why is a permanent weir not being considered CSIRO says conditions will get worse

How are they going to remove the weir

How is the level going to be maintained as weir is expected to sink in sediment

Why is the weir being build to 01m above sea level

If and when the weir is removed can it be reassembled quickly

How long will the weir take to build

Were other options considered for construction of the weir and what were they

Have you found a solution to the weir foundation (ie mud and construction of the weir at Pomanda Point)

What is the trigger to open the weir

Are the triggers to demolish the weir strict

Why haven t they got sta rted on build ing the weir

Lock Have investigations been made to have a permanent weir with lock with fishway and means of allowing the bottom salt water to be discharged

Has there been consideration of a lock with the weir (or a bypass channel)

Why have we not considered a lock

Why consider a temporary weir when a permanent weir could be constructed with a lock to maintain a navigable river system

Politics government and planning What about the constitutional right that the river be navigable from top to mouth

When will the Murray-Darling be run federally Not by the states

Why not hand over water management to the Commonwealth

When will the government declare this a disaster

What grantsassistance will be provided (eg tourism) Irrigators get support Why not others Industry assistance

Why is the weir being considered as part of a piecemeal approach What about a long-term plan

Is the weir part of the broader management of the Lakes and Murray Wha t s the b igger picture and where does it fit

Why is there not an integrated plan including Goolwa Channel regulators rather than doing it piece by piece

What is the present status of the Goolwa Channel projects

Is there a trigger for putting in a desalination plant at Tailem Bend

How will the remediation be managed and the long-term effect of the silt build-up be dealt with

Will building of the weir delay the equitable distribution of water in relation to other states

If the weir is built what are the triggers for letting in seawater to the Lakes

Riverbanks What measures have been taken to ensure the levy banks do not collapse with the higher river levels

What proactive approach will be taken to care for river banks

Ifwhen we build the weir what about the raising of the head River bank decline

Supplementary EIS for the temporary weir near Pomanda Island -115-

Has there been any consideration given to realigning the Lake Alexandrina shoreline Reduce evaporation in future

Pumping stations

Cost of moving pump stations above Lock 1

Chapter 4 Relocation of pumping stations above Lock 1 (needs clarification)

If they put in the weir will they continue to pump water to Lake Albert

Society and economy What is the impact on peoplecommunities

Why is economic impact not dealt with in the EIS

Miscellaneous What s the likelihood of worst-case modelling becoming irrelevant Is it likely that worst-case modelling is over predicted

Numbers of questionscomments on each topic indicative

Proposed Temporary Weir (Locks 4) 27

River flowsallocations 13

Politics Government (2 Goolwa channel) 13

Acid Sulphate Soils 5

Riverbanks 4

Lock 4

Pumping stations 3

Society and Economy 2

Wildlife 2

Miscellaneous 1

Supplementary EIS for the temporary weir near Pomanda Island -116-

Goolwa Community Information Session

Date Friday 27th March 2009 10000am 1230pm

Location Centenary Hall

Questions asked by the specialist panel listed by category

Wetlands Milang wetlands identified as number one natural resource by Adelaide University It has now been disconnected for two years Why is it not mentioned in the EIS

Will the wetlands between Lock 1 and the weir be filled How much water is needed to fill these wetlands Will the filling of wetlands result in an increase in acid

Bioremediation Are they considering bioremediation rather than building a weir

Impac t of g rasses tha t a re na tura lly g rowing on beac hes of the Lake

River flowsallocations What s being done about the wa ter supp ly

How much inflow into the River Murray in SA comes from SA compared with inflow across the VicNSW border (see figure 0-2 of the Exec Summary)

What flows would be necessary past Wellington to support a virtual weir at AHDs of -15 shy2 -25m

Will the weir be able to withstand a significant flood

How will water flow over the weir and into the Lower Lakes or will it flow through a gate underneath

How much water bypasses the weir if it is built

What will happen to the temporary weir if there is a flood Will it get washed away

Has the sc enario of three months without flow into the Lakes to fill the weir pool been allowed for in determining the trigger date of Jan 2010

Is it possible to have a shorter period where there is no flow over the weir but take a longer time to fill the weir pool

Has the government considered buying water to maintain the annual 350GL to the Lower Lakes

If the Lower Lakes are without water for three months during construction will the government purchase additional water to factor this in

Why doesn t the environment get a wa ter a lloc a tion like every other user

Why does Adelaide not have underground storage or other measures to alleviate the need for taking water from the River and hence for need of a weir

What difference would it make if we moved down to critical human needs rather than gardens and swimming pools

What is the impact of the various private and public water storages when comparing the Federation Drought and the current drought

What proportion of the Living Murray water agreement will reach the Lower Lakes (of the 500GL from 30 June 2009)

Ramsar What is the potential threat to the Ramsar status of the wetlands

Has the Wellington weir been put to Ramsar

Could building the weir lead to international action and delisting

Wildlife (Four questions on fish passage a re listed under Proposed temporary weir )

How do we consider the impact on species which are not listed under the EPBC Act These species are part of the ecosystem and food chain

Has the EIS looked at all species that will be affected eg snakes kangaroos and others

Supplementary EIS for the temporary weir near Pomanda Island -117-

Will the weir reduce flows significantly downstream and continue to adversely affect wildlife already in distress

There will be a spike in salinity in the Lake after disconnection which may lead to fish kill in certain species eg carp Fish kill will give high ammonia and low dissolved oxygen what is the impact on the other species as a result of this

Acid Sulfate Soils (ASS) What is proposed to address Acid Sulfate Soils

Acidification problem on land There are options to cover sand other than freshwater

Is the lake bed soil at Pomanda sulfuric

What does the Department anticipate will be the result of disturbing and replacing thousands of cubic metres of sulfuric soil above and below the weir

What is the problem with ASS What does it do that is so bad

When acid soils dry out does they still retain their acidity What happens when they turn to dust

What problems have Acid Sulfate Soils caused so far Why do we need to be concerned about this problem

Wha t is the government s stra tegy to c ombat the ac id and heavy metals entering the river as a result of varying levels caused by wind seiching

Salinity issues Why after Lake Alexandrina has been sucked dry should the Lake have to put up with the salt from behind the weir therefore making the Lake worse with a high salt content

What happens to the salt which normally comes down the River and flushes to the sea via the Murray Mouth

Will the weir result in a highly saline weir pool

How will the accumulated salts be flushed at the weir

How quickly can the rocks be removed if it becomes apparent that the weir pool salinity levels have unexpectedly risen to unacceptable levels If not quick enough what is the contingency plan

What is happening to water above the weir Will salinity affect Adelaide water supply

Where are the salt and other contaminants going to go once the weir is constructed

What consideration has been given to the massive mobilisation of salt that would follow heavy inflows

Has the government considered increased salinity building up behind the weir

If the weir has a long life will salinity keep rising

Won t sa lt and toxin c onc entra tion inc rease upstream of the weir

What science is there that demonstrates the mixing of saline waters in the weir pool immediately above Wellington to be kept to acceptable levels while the weir is in operation Is there any precedent of a similar scale for this mixing scale

Proposed temporary weir impacts If the weir is there for a long time what are the groundwater impacts

Why are there far more truckloads of material being put into building the weir as opposed to taking it out

What are the implications of taking the weir down

Impact of increased vehicle access on Lakes beaches on Sulfate soils dust and wildlife

How do you intend to remove the weir given it is a massive structure

How do you intend to remove the weir given it is a temporary structure

What part of the structure and sub-structure will remain after decommissioning

What are the consequences if the weir fails to withstand a flood

If the temporary weir is engaged for three years but is required for longer what would it take to remain operable for as long as it is needed

Wha t will happen a fter the end of the three years of the weir s life

Is twin lakes concept a possibility Has it been sufficiently considered

Supplementary EIS for the temporary weir near Pomanda Island -118-

What is the effect of the weir on the water ecology in the channel (downstream) Eg water rats crustaceans birds beetles etc

Is a fishway being incorporated into the design of the weir

During the period of disconnection can a tunnel be built through the weir to allow fish passage

Will the temporary weir include provision for a fish ladder

What provisions are there in the weir construction for fish ladders and other access for boating

What is the level of the weir spillway and the level of the weir pool behind it

What is the level of the weir itself

Is it possible that the temporary weir will need to be replaced by a barrage if the drought continues

Why not build a permanent weirlock rather than building a temporary weir that may need to be re-built in a number of years

How long do you expect the weir to be in place

Social and economic impacts Where do we take our concerns about economic and social impacts of the situation

Politics and government What are the budget figures of water (both temporary and permanent) How much do they expect to pay per GL

The weir won t a llow boa t tra ffic Is this aga inst the c onstitution

Is it legal to build a weir which will hold the River flow to the detriment of the Riparian rights users downstream

Is it true that Commonwealth or State Laws require the River to remain navigable

How can I use this process to promote a change to the system of governance (States sharingallocations)

How can this consultation process address over-allocation

What is being done about over-allocation

Over-allocation in other states is at the root of the problem When will governments apply sufficient pressure to deal with the shortage of water coming over the border

What is going to happen with the issue of over-allocation and theft of water upstream

Would it be better to spend money on infrastructure instead of buying back water

We need a 50 year plan to remove all man-made infrastructure in the Murray

Why doesn t the federa l government focus on new sources of water being made available For example new engineering securing water from Queensland and delivering it to northern point of Murray-Darling

Is the Murray-Darling Basin Agreement still a legal document Is it still in force

What is the federa l Minister s responsib ility to the c ommunity c onsulta tion p roc ess (Specifically relating to issues submitted to state and if they disagree with the citizen who adjudicates)

What coordination is there between different government departments

Miscellaneous Why was A Fresh Water History g iven out today To influenc e thinking

How long under the worst case scenarios will the water contained by the temporary weir remain suitable for Adelaide use

What would be the cost of shifting the uptakes above Blanchetown

How are they measuring water quality in Lake Alexandrina What about DO and temperature

What role is the rising water temperature having on the aquatic species and water quality as a whole

Will the water beyond the weir cease to be aerated as a result of the weir

How much has wind seiching been considered in the draft EIS

Supplementary EIS for the temporary weir near Pomanda Island -119-

Why has there been no consultation with community in Milang Why have they been neglected

Wha t does spend mean in rea l wa ter terms We need a bold idea

If the weir is built will the blocking banks at Clayton Finniss and Currency Creek still be needed

If the blocking banks go ahead with the weir still go ahead

If the drought continues and the weir goes in and barrages are left closed what will happen to the Lakes and Coorong

Trigger Points What will be the indication to dismantle the weir

What is defined as temporary and what are the decommissioning triggers for the weir

Lake Albert What is the future of Lake Albert

Numbers of questionscomments on each topic indicative

Weir construction impacts (inc 4 on fish-ways) 21

River flowsallocations 16

PoliticsGovernment 15

Miscellaneous (including 5 on water quality) 12

Salinity issues 12

Acid Sulfate Soils 8

Wild-life (Fishturtles) 4

Ramsar 3

Wetlands 2

Bioremediation 2

Social and economic impacts 1

Lake Albert 1

Supplementary EIS for the temporary weir near Pomanda Island -120-

Clayton Community Information Session

Date Friday 27th March 2009 400pm 630pm Location Clayton Community Hall

Questions asked of the specialist panel listed by category

Regulators Why is a regulator at Clayton for pumping to the Goolwa Channel considered above letting seawater in to it

If the Clayton Regulator is built will it protect the water quality at the pumping stations (without building the weir)

How does the function of the Pomanda Island weir relate to the functions of regulators proposed for Currency and Finniss Creeks and Clayton

Is the weir going ahead as well as regulators If so why are both necessary

With the proposed regulators will the inflows of water to the next section be regulated from the bottom of the weir or from the top ie What will happen to accumulated salt behind the weir

Why is information on the regulators only in the papers and not mentioned in this forum

Lake Albert Should the weir at Pomanda Island proceed what are the ramifications for the future of Lake Albert

River flowsallocations Has blocking off the wetlands between the weir and Lock 1 to allow water when available to run into Lake Alexandrina been considered

If the weir is installed is the initial idea to pump water into the weir pool immediately or to leave it to whatever comes in

If the water extraction cap in other states is applied in 2012 will we get any water flow to SA

What are restrictions in other States on water use

What if anything happens in other states in allocating water as NSW has no meters

How is water removed from the River tracked

How is surface diversion tracked and measured

Has there been an assessment of all water storages available to the MDB

Do we believe SA will actually be able to get more freshwater from the larger eastern states as they are also growing

Would stormwater redirection help the Murray

What is stopping us from buying more water

How can the process of buying water be sped up

Ramsar

of the Murray-Darling Basin and River mouth is of paramount importance

Wildlife Ecology of LakeRiver studies on cod too late They have been in scarce supply for a long time

Given that the Yarra Pygmy perch is in other river systems why is it included

No cod in the Lower Lakes for decades Why are they included in the draft EIS

Is a base line study into Bell Frogs too late

Has anyone looked at the effect of the weir and its repercussion on micro-invertebrates etc on whic h a ll the Lakes residents (human anima l and p lant) depend

The Coorong and La kes site is reg istered a s an interna tiona l Ramsar wetla nd Isn t the Prime Minister responsib le for p rotec ting this a rea Isn t this the b ottom line The ec ology

Supplementary EIS for the temporary weir near Pomanda Island -121-

What effect will the proposed seawater introduction have on the Lower Lakes freshwater species

Why are marine species that were prevalent before the barrages not mentioned in the EIS

What study has been done on non-river marine species threatened by not allowing seawater in as nature would have done under these circumstances

How will species not listed in the EPBC Act be addressed

Acid Sulfate Soils What is the risk of potential ASS becoming actual ASS

The Executive Summary of the draft EIS alerts to the danger of acidification of the weir pool above the weir when wetlands are flooded again Is it intended to close off the entrances to them Has there been any decision yet about exactly what the effect of covering ASS with water (salt or fresh) will be

What will happen to the wetlands above the weir when they are refilled with water Is there a danger of the water being contaminated due to acidic soils

Due to ASS and extraction for urban use it appears that the weir must be in place by mid-January 2010 Is that the case

If the weir is installed is the intention to block off back waters and lagoons below Blanchetown If so are these subject to ASS

Bioremediation Is there something groupsindividuals can do to help with bioremediation projects etc How can we be involved

Will revegetating problem areas with dust fix the problem

Salinity issues What are the impacts of salt water within CurrencyFinniss Rivers

In the introduction it was stated that salt levels in the Goolwa Channel are 20000 ppm (parts per million) I believe they are 30000 ppm Is your information up to date

What will happen to salt accumulation when the proposed temporary weir is removed

Will the water coming over the weir spillway bring the salt with it or will salt build up at deeper levels

How will the salt coming past Pomanda Island be managed with a complete blockage that has a low level spillway in shallow water east of the main River channel

Does the weir prevent salts from being flushed out to sea (ie they will be built up behind the weir)

Rainfall Has consideration been given to constructing a barrage behind the temporary weir given continuing long-term low average rain fall

Proposed temporary weir Given the EIS indicates a 3 year lifespan of the weir what is the situation if the objectives of its installation are not met

Given the criteria for removal why is the design life for 3 years only

How permanent is this weir

If a weir is built upon removal will it all be removed or will it be a narrower channel

Figure 0-4 (lake level and the -15m red line) Is this the trigger for both the start of weir building and the introduction of seawater into the Lower Lakes

In the draft EIS statement there was no mention of effect on commercial social recreational or irrigation impacts Have these been considered

What is the impact of not constructing the weir

If the weir fails to guarantee water supply to Adelaide will it be removed

How long is the temporary weir to be in place

Why is the weir going to be temporary

Supplementary EIS for the temporary weir near Pomanda Island -122-

Has any consideration been given to building a barrage not a weir at Pomanda Point and removal of existing barrages below

Why not build a permanent structure which will service us for the next 100 years

Social and economic impacts Does the EPBC Act consider social and economic issues that the weir will impact on

How is this affecting tourism throughout the Lakes

How are the social and economic impacts being understood

Seawater If we let seawater in would it be flushed out again Would it return to fresh water

Is seawater into the Lakes seriously being considered What are the strong arguments against seawater as a sustainable option for the Lakes

Have we looked at letting seawater in at similar locations in Australia eg Mantra And the effects

Are Professor Gells results for c ore sampling about historic a l seawa ter being c onsidered (in letting seawater in)

Have any studies been conducted to consider the impact of salt water entering this Lake What were the outcomes of it

What prevents the weir height to be increased to say 07AHD to permit ingress of seawater to allow sufficient depth (~05AHD) and the operation of boat ramps jetties sailing clubs and safe navigation within the Lakes

Has a desalination plant option been considered for Beach 19 Lake Albert and Cantara (Replacement of fresh water from evaporation etc)

Politics and government Why has it been left so long for the urgency of this to be recognised and acted on

If the Federal government takes control of the MDB will that make this EIS invalid

Will the d ra ft EIS need to be reviewed due to the Government s rec ent dec isions regarding the blocking banks at Finniss amp Current Creeks

How does the EPBC Act deal with long-term management of the Lower Lakes

As it impacts on matters of NES does a state territory or industry need to get approval under the EPBC Act to get current or future water extractions

Why isn t the Commonwea lth ac ting to restric t a lloc a tions more urgently

Does the construction of the weir contravene Section 100 of the Australian Constitution that gives States or people rights to use water for conservation or irrigation

Due to state environmental assessments being overridden by emergency powers how a re issues suc h as wa ter a ffec ting ac tivities and wetland management p lans add ressed in this process

Miscellaneous Why is the Murray called a river when it is a series of pools

Has the idea of an island in the middle with dredging around it been considered for Lake Alexandrina

Why were 1982 figures used when 2006 was the worst case (until now)

Can we have hope that we will get to a sustainable system and that irrigation can provide Australian food

Has sea level rise been a consideration in the draft EIS and how may this impact on the weir if built

Were there EIS studies on any of the other 4000 barriers across the Murray

Has study of other precedence areas such as Mandura been done

Would it help if we had dry toilets

What level will the Lake be allowed to come up to once the weir is in place How far below the weir will the lake level be

Why have they decided on a pool of 01AHD given that previous pool level of the whole area was at +05 to 06 (Given that top of tide is +06m)

Supplementary EIS for the temporary weir near Pomanda Island -123-

How will water restrictions apply to small farmers on the river

Why wasn t Finniss Angas Bremer etc in MDB c a tc hment a rea

Why hasn t more been done about effic ienc y improvements in wa ter use by loc a ls as well as industry and people in Adelaide and beyond

If we all collected domestic water from properties etc would it negatively impact the Murray

Why isn t Myponga used to supp ly wa ter to the Fleurieu

Why has no impact study on underground water in the Currency Finniss and lower south east region been done

Has there been a comprehensive study of ground water and surface water into the area surrounding Lake Alexandrina

Why is there no navigation pass in the weir or no provision for one in the future

What will happen to Lake Alexandrina if water is pumped out into the Goolwa channel

Once the Lake is dry how will the Clayton channel then be refilled

Trigger Points Where are the trigger points for monitoring salinity and calcium carbonates sites located

Once we reach a certain trigger level at a monitoring site is the weir removed immediately or does it have to sit at a point for a certain amount of time

Will the weir be deconstructed if one trigger point is reached or all trigger points

Wha t is the trigger point for the guaranteed dec ommissioning of the weir

What are the triggers for removing the temporary weir

If the main a im of the weir is p reserva tion of Adela ide s water supp ly why is the level of water in the Lakes the trigger point for construction of the weir rather than the ability to extract water for Adelaide Is the real reason to do with Acid Sulfate in the Lakes

What is being done now to speed up the process of water allocation

Respiratory problems Low water levels are increasing the dust levels How quickly will this be covered to tackle health issues such as respiratory problems

Are health effects of the dust being surveyed What evidence is there of this

Has research been done regarding increases in respiratory problems

Supplementary EIS for the temporary weir near Pomanda Island -124-

Numbers of questionscomments on each topic indicative

Miscellaneous 20

Weir construction impacts 12

River flowsallocations 12

Wildlife 9

PoliticsGovernment 8

Sea water 7

Trigger Points 7

Regulators 6

Salinity 6

Acid Sulfate Soils 5

Social and economic impacts 3

Respiratory problemshealth 3

Lake Albert 1

Ramsar 1

Consolidated list of question topics from all Community Information Sessions

River flowsallocations 50

Weir construction impacts 47

Politics amp Government 39

Miscellaneous 37

Proposed Temporary Weir 27

Salinity issues 24

Acid Sulfate Soils 21

Wildlife 19

Seawater 10

Social and economic impacts 9

Lake Albert 7

Ramsar 7

Regulators 6

Trigger Points 7

Lock 4

Riverbanks 4

Pumping stations 3

Rainfall (Lake rain) 3

Respiratory problemshealth 3

Wetlands 2

Bioremediation 2

Supplementary EIS for the temporary weir near Pomanda Island -125-

Graph of consolidated question topics from all Community Information Sessions

All CIS Questions Summary

0

10

20

30

40

50

60

River flo

wsall

ocat

ions

Wei

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impa

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Miscel

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us

Prop

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Tem

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locks

)

Salin

ityiss

ues

AcidSu

lfate

Soils

Wild

life

Sea

water

Socia

l and

econ

omic

impa

cts

Lake

Albe

rt

Ramsa

r

Regul

ator

s

Trig

ger Po

ints

Lo

ck

Riverb

anks

Pum

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stat

ions

Rainfa

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Respir

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Wet

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Bior

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Supplementary EIS for the temporary weir near Pomanda Island -126-

Appendix VI Advertising copy used in the consultation process

Date Thurs 12th March 2009

The Australian

The Victor Harbor Times

The Advertiser

The Southern Argus

The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -127-

Supplementary EIS for the temporary weir near Pomanda Island -128-

Date Thurs 12th March 2009

The Australian The Victor Harbor Times

The Advertiser The Southern Argus The Murray Valley Standard

Date Friday 13th March 2009

The Lakelander

Supplementary EIS for the temporary weir near Pomanda Island -129-

Supplementary EIS for the temporary weir near Pomanda Island -130-

Public Release Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island Email Update Sent 12th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -131-

Public Release Amended Draft Environmental Impact Statement for the

proposed temporary weir near Pomanda Island Email Update Sent 17th March 2009

Supplementary EIS for the temporary weir near Pomanda Island -132-

Public Release Reminder re lodging submissions - Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 1st April 2009

Supplementary EIS for the temporary weir near Pomanda Island -133-

Public Release Submissions due 9 April 2009 Draft Environmental Impact

Statement for the proposed temporary weir near Pomanda Island Email Update Sent 6th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -134-

Public Release Consultation period for draft EIS closes Draft Environment

Impact Statement for the proposed temporary weir near Pomanda Island

Email Update Sent 15th April 2009

Supplementary EIS for the temporary weir near Pomanda Island -135-

CD Pack Draft Environmental Impact Statement for the proposed

temporary weir near Pomanda Island

Supplementary EIS for the temporary weir near Pomanda Island -136-

Executive Summary

Supplementary EIS for the temporary weir near Pomanda Island -137-

Distribution of draft EIS Executive Summaries and CDs

Organisation Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Alexandrina Council 2 2 5 45 50 Coomandook Community Library

1 0 20 20 1

Coorong District Council 2 2 5 45 50 DEWHA library 2 2 5 5 Goolwa Public Library 1 50 50 1 Meningie Community Library 1 30 30 1 Milang Old Schoolhouse Community Centre

1 50 50

Mount Barker Community Library

1 20 20 1

Mt Barker Natural Resource Centre Mt Compass Library

1 20 20

1 Murray Bridge Library 1 Murray Bridge Natural Resource Centre

1

Rural City of Murray Bridge 2 1 National Library of Australia 2 Port Elliot Library 1 State Library Adelaide 2 1 Strathalbyn Community Library 1 Strathalbyn Council Office 2 Strathalbyn Natural Resource Centre Tailem Bend Community Library Tailem Bend Office of Coorong District Council Tintinara amp Coonalpyn Community Library Tintinara Office of Coorong District Council Victor Harbor Natural Resource Centre

1

5 5

20 20 1 30 30 1

30 30

95 100 5 5 30 30 1 50 50 50 50 1 30 30

30 30

1 30 30 1

1 30 30

1 30 30 1

1 30 30

1 30 30

Victor Harbor Public Library 1 30 30 1 Willunga Environment Centre 1 30 30 CLLMM Project Team 2 2 40 20 Mapland (DEH) 2 2 5 45 50 Meningie Community Information Session

200 100

Murray Bridge Community Information Session

200 100

Clayton Community Information Session

200 100

Goolwa Community Information Session

200 100

Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 Dept Environment amp Heritage 1 SA Government Ministers Hon Mike Rann MP Premier Minister for Economic Development Minister for

1

20 20 20

20 20 20 10

2

10

2

Supplementary EIS for the temporary weir near Pomanda Island -138-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Sustainability and Climate Change Hon Paul Holloway MLC Minister for Urban Development and Planning

1 2 2

Hon Jay Weatherill MP Minister for Environment and Conservation

1 2 2

Hon Paul Caica MP Minister for Agriculture Food and Fisheries Minister for Regional Development

1 2 2

Hon Gail Gago MLC Minister for StateLocal Government Relations Hon M OBrien MP Minister for Employment Training and Further Education Hon T Koutsantonis MP Minister for Correctional Services Hon J Rankine MP Minister for Families and Communities Hon M Atkinson Attorney-General Hon M Wright MP Minister for Police Hon John Hill MP Minister for Health

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

1 2 2

Hon Kevin Foley MP Treasurer Minister for FederalState Relations

1 2 2

Hon Jane Lomax-Smith MP Minister for Tourism

1 2 2

Hon Patrick Conlon MP Minister for Transport Energy and Infrastructure

1 2 2

Hon Karlene Maywald MP Minister for the River Murray Minister for Water Security

1 2 2

Shadow Ministers Martin Hamilton-Smith MP 1 2 2 Adrian Pederick MP 1 2 2 Mitch Williams MP 1 2 2 Aust Govt Ministers Minister Penny Wong 1 2 2 Minister Peter Garret 1 2 2 SA Parliamentarians Parliamentary Leader SA Greens - Mark Parnell

1 2 2

Parliamentary Leader SA Democrats - Hon Sandra Kanck MLC

1 2 2

SA Parliamentary Library 1 1 Chief Exec DEH - Allan Holmes 1 Chief Exec EPA - Helen Fulcher 1

5 2 2

5 2 2

2Chief Exec DWLBC - Scott Ashby Chief Exec DTED - Brian

1 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -139-

Organisation

Hard Copy of draft EIS

Appendices CD Exec Sum

CD Addl HC for Loan

Cunningham Chief Exec DTEI - Jim Hallion Chief Exec SA Water - Anne Howe Chief Exec DPC - Chris Eccles 1 2 2 Chief Exec DPLG - Ian Nightingale

1 2 2

Chief Exec PIRSA - Geoff Knight

1 2 2

Chief Exec DTF Rob Freeman 1 2 2 Dr Tony Sherbon 1 2 2 Mr Dean Brown 1 1 Mr Simon Stretton 1 2 2 Mr Sean Berg 1 2 2 CLLMM Steering Cttee 8 8 8 CLLMM Project board 4 4 4 Conservation Council of SA -Julie Pettett

1 2 5

Spares 2 2 500 500 92 15 25 2410 2012 11

Hard Copy Append CD Exec Sum CD Ordered 140 20 0 2500 2000

1 2 2

1 2 2

Supplementary EIS for the temporary weir near Pomanda Island -140-

Web content

Supplementary EIS for the temporary weir near Pomanda Island -141-

Supplementary EIS for the temporary weir near Pomanda Island -142-

Supplementary EIS for the temporary weir near Pomanda Island -143-

Fact Sheet

Supplementary EIS for the temporary weir near Pomanda Island -144-

Supplementary EIS for the temporary weir near Pomanda Island -145-

Appendix VII Media generated by the consultation process

Radio 12012009 410 PM ABC North amp West SA (Port Pirie) Late Afternoons - Kieran Weir Interviewees Michael Pengilly Liberal Member for Finniss Duration 10

18 01 2009 850 AM 5AA (Adela ide) Mic hael Keelan s Weekend - Michael Keelan Neil Humphrys amp June Taylor Interviewees Simon Birmingham South Australian Liberal Senator Duration 710

8012009 954 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 025

Newsreader News Director Ms Monique Crichton Duration 014

8012009 603 AM Triple M (Adelaide) 0600 News

8012009 1212 PM 5AA (Adelaide) Mornings - Mike Smithson Interviewees caller Jeff Mike Rann SA Premier Duration 1133

8012009 731 PM 5AA (Adelaide) Matthew Pantelis - Jeff Burzacott Interviewees Caller Robyn Duration 1605

8012009 1127 AM ABC 891 Adelaide (Adelaide) The Soapbox - Sonya Feldhoff Interviewees Michael Pengilly Member for Finniss Duration 328

8012009 1212 PM ABC North amp West SA ABC North amp West SA (Port Pirie) SA Country Hour -Annabelle Homer Interviewees Senator Sarah Hanson-Young Australian Greens SA Duration 415

8012009 100 PM ABC 891 Adelaide (Adelaide) 1300 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Martin Hamilton-Smith SA Opposition leader Mike Rann SA Premier Duration 119

8012009 600 PM ABC 891 Adelaide (Adelaide) 1800 News - Newsreader Interviewees Kym McHugh Mayor Alexandrina Council Duration 033

9012009 632 AM ABC 891 Adelaide (Adelaide) 0630 News - Newsreader Interviewees Arlene Buchan Australian Conservation Foundation (ACF) Duration 036

9012009 704 AM ABC 891 Adelaide (Adelaide) 0700 News - Newsreader Interviewees Arlene Buchan ACF Duration 050

3022009 1003 AM ABC 891 Adelaide (Adelaide) 1000 News - Newsreader Interviewees Karlene Maywald SA Minister for the River Murray Duration 046

12032009 830 AM ABC 891 Adelaide (Adelaide) Mornings - Sonya Feldhoff Duration 017

12032009 521 PM ABC North amp West SA (Port Pirie) Late Afternoons - Annette Marner Interviewees Caller Tom Karlene Maywald Minister for Water Security

Supplementary EIS for the temporary weir near Pomanda Island -146-

Duration 847

13032009 809 AM 5AA (Adelaide) Pilkington amp Conlon - Tony Pilkington amp Keith Conlon Interviewees Karlene Maywald SA Minister for the River Murray and Water Security Duration 628

13032009 840 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan - live from Goolwa Interviewees Prof Diane Bell Resident and former Federal independent candidate for the Seat of Mayo Duration 239

13032009 910 AM 5AA (Adelaide) Mornings - Mike Smithson Interviewees Senator Sarah Hanson-Young Australian Greens Party Duration 612

13032009 1024 AM ABC 891 Adelaide (Adelaide) Mornings - Matthew Abraham and David Bevan Interviewees Clem Mason Lower Lakes and Coorong Infrastructure Committee Lesley Fisher Lower Lakes and Coorong Infrastructure Committee Duration 923

13032009 1105 AM ABC 891 Adelaide (Adelaide) The Soapbox - Matthew Abraham and David Bevan live at the Goolwa Sailing Club Interviewees Dean Brown Premiers Special Drought Advisor Robyn McLeod SA Independent Water Commissioner Duration 603

31032009 835 AM ABC North amp West SA (Port Pirie) Morning Show - Kieran Weir Interviewees Dr Jochen Kaempf Oceanographer Senior Lecturer Flinders Uni Duration 1136

Television 8012009 600 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Martin Hamilton-Smith SA Opposition leader Peter Garrett Federal Minister for the Environment Rory McEwen Acting Water Minister Senator Sarah Hanson-Young Australian Greens Party Simon Birmingham Liberal Senator for SA Duration 135

8012009 601 PM Channel 9 (Adelaide) National Nine News - Rob Kelvin Interviewees Henry Jones fisher Jock Veenstra tourism operator Kym McHugh Mayor Alexandrina Michael Smyth Channel 9 reporter Duration 200

12032009 516 PM Channel 10 (Adelaide) TEN News - George Donikian and Rebecca Morse Interviewees Karlene Maywald Water Security Minister Mark Parnell Australian Greens Martin Hamilton-Smith SA Opposition leader Duration 147

Print media PG227 13 March 2009 The Hon Peter Garrett MP Minister for the Environment Heritage and the Arts Final terms of reference for Barrage EIS httpwwwenvironmentgovauepbcnoticesassessmentslower-lakeshtml Stock Journal 19032009 p 8 General News Adelaide Advertiser 14032009 p 27 General News Lakelander 27032009 p 9 General News Stock Journal 19032009 p 12 General News Stock Journal 19032009 p 16 Letters Times Victor Harbour 19032009 p 1 General News Murray Valley Standard 19032009 p 4 General News

Supplementary EIS for the temporary weir near Pomanda Island -147-

Appendix VIII Summary information of enquiries and

submissions for provision of the proposed temporary weir

Summary information

Number of phone calls to EIS hotline 52 Number of emails to eisdehsagovau from unique individuals 82 Number of feedback comments on the CLLMM website 14 Number of subscriptions to e-newsletter via the CLLMM website 48 Number of Community Information Session registrations on the CLLMM website 47

Number of submissions received by email 61 Number of submissions received by letter 9 Total number of submissions received 70

Number of unique visitors to the CLLMM website 1588 Number of visits to the CLLMM website 2834 Number of page views on the CLLMM website 9343

Supplementary EIS for the temporary weir near Pomanda Island -148-

Submission Summary

Mr Roger Cooke The writer proposes a major scheme which aims to simultaneously drought-proof the Murray-Darling Basin and to meet 2020 emissions targets Features of the scheme include - Laying concurrently gas and water pipelines from the NW Shelf to major centres including SA mining towns and Adelaide - Laying irrigation pipes to replace open channels a financial stimulus package - Piping LNG to replace coal-fired energy production assisting Australia to meet 2020 emissions targets The submission outlines a national water distribution scheme as well as a proposal for creating a river channel in order to prevent evaporation across the Lakes while maintaining a freshwater channel The writer proposes a scheme for a long-term solution to the Lower Lakes The writer suggests a permanent weir is necessary as drought will increase in severity and frequency The proposed scheme would aim to reduce evaporation occurring over the Lakes by creating a channel from a proposed permanent weir to the barrages The writer suggests benefits to the Coorong mitigation of Acid Sulfate Soils a freshwater environment for boating while p rotec ting Ad ela id e s wa ter supp ly

Mr Michael Galea Argues there are too many unquantifiable risks associated with the proposed weir and freshwater is needed now The writer bases the submission on local knowledge and common sense He reports the awesome impact of low water on many plants and animals in recent years in the vicinity of Clayton Bay He expresses concern that a weir will pool polluted water upstream and the saline spike will kill tens of thousands of carp and pollute Lake Alexandrina

Mr Philip Fargher The writer is keen to see base environmental River flows established through the use of Commonwealth Government powers The writer outlines established processes of River flooding which periodically flushed out saline water from the Lower Lakes and Coorong Changes to the system due to locks allocations irrigation and the barrage are noted Seawater flooding of the Lakes is thought to lead to negative and unpredictable results as tidal exchanges are insufficient Acid Sulfate Soils require freshwater flows or peripheral lime sand

Mr Andrew Zoerner The writer is concerned that a freshwater environment in the Lower Lakes will not survive unless a Lock is built east of Clayton as well as a water pipeline from Wellington The aim is to maintain freshwater around Goolwa Hindmarsh Island and Clayton for environmental cultural historical industrial recreational and tourism reasons while preserving local flora and fauna

Mr Douglas Smith The submission has nine points The author seeks clarification identifies gaps and expresses points of view The author asks that the definition of sea level and salinity measures are clarified He notes that ferry operations are

Appendix IX Table of submissions

The table below provides a summary of submissions received during the public consultation period An electronic copy of the submission can be located on the DEH website httpwwwenvironmentsagovaucllmmtemporary-weirhtml

Submission no

PTW00001

PTW00002

PTW00003

PTW00004

Submission from

PTW00005

Supplementary EIS for the temporary weir near Pomanda Island -149--

Submission no

Submission from Submission Summary

not discussed under the do nothing option and notes that the difficulties of decommissioning a weir are understated He notices that there is no discussion of management of blue green algal blooms above the temporary weir

PTW00006 Ms Melanie Rees The author argues that efforts to mitigate negative impacts of a proposed temporary weir are grossly inadequate and any amendments envisaged to the draft EIS will not make the weir development acceptable Threats to species and communities are not adequately addressed or are downplayed or discountedThe author indicates concern about the lack of genuine community consultation and argues that the weir development should be considered with other developments because there are cumulative impacts She expresses points of view on public understanding of pertinent issues drought the importance of cost benefit analysis and suggests changed wordings The author suggests investigating filling reservoirs and drawing from them while relocating pumping stations She suggests that stormwater statistics are inaccurate and recommends increasing stormwater harvesting to alleviate reliance on the River Murray The author provides detailed information about the Southern Emu-wren noting Draft EIS information is out of date Gaps are identified in that phytophthora impacts are not considered at the weir building site and the impact of a weir on Callop fish is not discussed

PTW00007 Mr John Clark President Southern Alexandrina Business Association Inc

This submission puts a case for an alternative to the proposed temporary weir near Pomanda Island SABA argues for a permanent lock (Lock 0) in the vicinity of Tailem Bend SABA refers to Gell et al and notes the estuarine but predominantly freshwater environment of the Lower Lakes A navigable lock with a fishway would support the ecology and recreational fishing and boating (boating valued at $200m pa) and meet water security objectives SABA argues that climate change increases the logic of a permanent Lock 0 Supports remediation and revegetation where appropriate and seawaterif needed to check Acid Sulfate Soils

PTW00008 Mr Mike Brisco This submission draws on authoritative literature on climate change The author argues that the weir is proposed in an inadequate context that is the context of severe drought in south eastern Australia The proposed weir should be located in other scenarios - especially for example that of rapid climate change In the event that the weir needs to remain in place projected sea level rises need to be considered in its design The main point is that the impacts of the proposed weir cannot be understood in an inadequate context An additional chapter is suggested Other detailed suggestions are made for changes to the draft These changes show more dramatic water security issues than currently documented in the draft EIS (for example diminished run off over time into Adelaide water storages)

PTW00009 Mr Ian Moyle The writer has lived and worked at Narrung and has lasting educational and environmental interests in the Lakes and Coorong He is c onc erned b y governments lac k of acknowledgement of climate change and previous poor water management He urges the state government to get serious about collecting and using rainwater and grey

Supplementary EIS for the temporary weir near Pomanda Island -150shy

Submission no

Submission from Submission Summary

water re-use PTW00010 Ms Jan Meek

Secretary Signal Point Riverine Environment Group Inc

The group believes a weir willl become permanent and that a revised draft EIS should be prepared based on this premise There are seven issues of concern listed Gaps and lack of clarity in the draft EIS are identified The group indicates - that species rescue outside the Ramsar boundary is unacceptable and that the EIS needs to include species impact statements on a range of species - that an impact of a weir will be increased salt discharge salt interception schemes or mitigation measures need consideration - weir removal triggers are unrealistic and imprecise and out of the control of the SA Government

PTW00011 Mr Richard Harvey

PTW00012 Ms Sally Richards

The writer has a long association with the Coorong and Lower Lakes He indicates his opposition to any seawater incursion In relation to the weir he understands that in the order of 500 tonnes of salt a day would build up This would impair water piped to Narrung The writer urges strong action by Federal Government to reverse over-allocation The writers submission is informed by her residence in the Finniss Catchment and membership of the Finniss Catchment Group Points made by the writer include - more freshwater in the river system - over-allocation and poor management of water continues today - for example in the Finniss catchment where there is no Water Allocation Plan - system wide over-allocation must be addressed - more species than those listed in the draft EIS should be considered - the weir will have impacts beyond the weir site The writer advocates working with community and nature and and disallowing XXXXXXX water supply control (company not named for legal reasons)

PTW00013 Mr Trevor Giles

PTW00014 Ms Brenda Lower

The writer has very extensive experience living and working as a primary producer in the Langhorne Creek District and has a strong attachment to the Lower Murray Region He notes the lack of freshwater will lead to habitat loss and that all water supply proposals are interconnected All projects together are an overall threat to the environment Other concerns include - the bund at Narrung Narrows and proposed regulators prevent wind seiche - lack of consideration of groundwater - no fishway inclusion - the unsuitability of the weir site Freshwater is the only viable solution to retaining habitat The writer is concerned about the river and the people of the district and she asserts that water is needed now The author notes negative impacts of increasingly saline water on turtles birds and fish and is concerned about sulfidic soils and human health The author favours a permanent weir and seawater incursions to cover soils

PTW00015 Mr Frederick Gordon Michelmore Farmer

The author is concerned by the increasing salinity in the Lakes He suggests spending 10 of the cost of the weir on increasing rainwater capture from roofs Other sources of water must be found because the river can not keep up with demand

Supplementary EIS for the temporary weir near Pomanda Island -151shy

Submission Summary

Ms Ann Lucas The writer is concerned about previously estuarine areas between the Murray Mouth and Beacon 19Goolwa Barrage which are an important habitat for migratory birds It is suggested freshwater is accessed for the area in order to return it to estuarine conditions - possibly through the use of an inexpensive Desal plant

Mr Glen Jones General Manager Boating Industry Association of SA Inc (BIASA)

Points on matters of national environmental significance relating to the EIS no comment Concerns - BIASA would have liked to see provision for boating

ac c ess (a vessel loc k ) through the weir - the greatest concerns of BIASA are for both the natural environment and the declining economic viability of many businesses and communities along the River Murray downstream from Lock 1 and in the CLLMM region - concerns are for both the immediate situation and the longer term The submission documents the broad membership of BIASA the operation of BIASA and the organizations with which it liaises and for which it provides advice The submission documents financial losses being incurred (economic losses $ figures) as a result of low water levels and low water flows The cost of repairing river bank slumping and impact on ferry services and nearby communities are mentioned The impact of low water levels and low water flows in the CLLMM on social and health wellbeing of communities and jobs in boating and tourism businesses is documented in some detail and discussed The submission supports the immediate construction of a weir

Mr John Coombe Chief Executive Alexandrina Council

Points on matters of national environmental significance relating to the EIS - concern about the future health of the Ramsar protected areas - concern about the lack of fish passage between Lake Alexandrina and the River Murray and vice versa Concerns - most concerns are based on the premise that the weir will reduce water flows into the CLLMM region however this will be temporary only (90 days) - potential for unknown andor unforeseen impacts of building a weir on biodiversity and water quality both upstream and below the proposed weir - the biodiversity of the CLLMM region is dependent on freshwater for survival and is getting insufficient freshwater - infestations of tubeworms and other pests have the capacity to impact on biodiversity including turtles (not currently listed under EPBC Act) - health problems caused by excess dust from dry lake bed areas - increased impact of environmental condition on social and economic wellbeing of the region Suggestions building of a lock upstream is preferred because it will allow fish passage and boating access up and downstream

Mr Derek Fenton Points on matters of national environmental significance relating to the EIS No specific points were raised but a concern was expressed about impact on other species which are not listed under the EPBC Act

Submission no

PTW00016

PTW00017

PTW00018

Submission from

PTW00019

Supplementary EIS for the temporary weir near Pomanda Island -152shy

Submission Summary

Concerns the main concern is for lack of water for environmental flows in the River Murray in the CLLMM area

PTW00020 Ms Vesper Tjukonai Points on matters of national significance relating to the EIS not addressed except to say that in Ngarrindjeri traditional thinking animal bird and fish species (part of Ruwe) are not separated as in Chapter 13 but considered in an integrated way Concerns - questions the thoroughness of consultation with Ngarrindjeri Traditional Owners - impact of declining quality of river systems on humans (especially Ngarrindjeri in this case) - construction of weir would reduce water flows available for the Ngarrindjeri - continuing noise nuisance from pumps at Narrung Narrows pumping especially low frequency noise (health problem) - lack of clarity of the relationship between the Narrung Narrows bund the proposed weir and the future need for pumping at Narrung Narrows - potential health impacts of dust from the exposed edges of drying lakes - there could be increased pumping in summer and autumn at Narrung Narrows if the weir is built - current restriction of activities including collection of traditional foods basket making and others - soc ia l imp a c ts of the d rought a nd inappropriate water

hoard ing and fa rming method s Suggestions - Include the Ngarrindjeri Nation as Traditional Owners of the CLLMM region in the Draft EIS Executive Summary and Draft EIS Fact Sheet - Refer to Ngarrind jeri as Nation and Trad itiona l Owners - Go beyond consultation to partnership with traditional owners in planning and management - Consideration of impact of the drought and water quality situation on humans (Ngarrindjeri Nation and the wider community)

PTW00021 Mr Keith McFarlane

Background local landowner along Lake Alexandrina (family since 1845) cattle production irrigation Points relating to matters of national environmental significance EIS - Mr McFarlane says that the CLLMM is the most important part of the MBD and that river flows must be allowed for environmental maintenance as the highest priority - He is concerned that increased salinity below lock 1 caused by building the weir will be disastrous for the Ramsar-listed wetlands - He is also concerned that mud disturbance around the weir site during construction would turn the water saline and impact on all fish species Mr McFarlane does not support the building of the temporary weir at Pomanda Island The closure of wetlands along the River Murray is supported as long as there is periodic re-wetting Additional concerns Mr McFarlane is concerned that the seasonality of wind direction and speed across Lake Alexandrina may not have been taken into account when the modelling was done and that SW winds in winter and spring will counteract river flow such that river salinity will

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -153shy

Submission no

Submission from Submission Summary

build up more quickly than has been suggested in the draft EIS Suggestions - that Acid Sulfate Soils have not been a problem to date and could be counteracted in future by seeding into exposed areas - it is not necessary to keep the Lakes up to pool level in drought because the Lakes will present a smaller surface area for evaporation reducing amount of water lost - establishment of more rainfall recording stations around the Lower Lakes region to improve the accuracy of data used in modelling

PTW00022 Mr Tom Chapman Director The Marina Hindmarsh Island

Points relating to matters of national environmental significance EIS - the weir would reduce (economic and) environmental activities of the LLMM region - suggests that a fishway should be included in the weir Support the submission supports the proposed weir as a last resort but argues that a permanent lock between Tailem Bend is a better solution He views the weir as a high cost item to build and maintain as well as not allowing boating access between the Lakes and the River Concerns Mr Chapman is very concerned about the impact of lack of boating access through the proposed weir and the consequent negative impact on economic activity in the LLMM region especially on the recovery of boating but not necessarily limited to boating Perspective a worst case scenario and the weir might not be removed for a considerable time (many years) Alongside this he also supports the introduction of seawater into the LLMM and makes points about historic and current salinity levels in the LLMM

PTW00023 Mr Tony Read The author argues that there is no compelling evidence to build a weir He indicates that long-term investments are required for long-term solutions A short and a long-term solution exist The author refers to research into aquifers beneath the Adelaide Plains and provides a reference He indicates that groundwater bores can be increased quickly if necessary and argues that brackish bore water can be desalinated more cheaply than seawater He makes a case for a long-term solution that is the Twin Lakes concept He notes that the partial weir options do not support any argument to build a weir

PTW00024 Mr Mick The writer supports building a weir He notes that people upstream are suffering He is concerned about evaporation losses

PTW00025 Ms Anne Hartnett Points on matters of national environmental significance relating to the EIS - this EIS is only a partia l doc ument bec ause there a re many interrelated interventions occurring in the CLLMM region a single holistic EIS should be put together covering all of the interventions - the site of the proposed temporary weir is at or near a biodiversity hotspot as pointed out in Appendix 15 and was this considered when the site was chosen - potential for release of metals (including heavy metals) from sediments by acidification and associated ecological impacts are unknown

Supplementary EIS for the temporary weir near Pomanda Island -154shy

Submission no

Submission from Submission Summary

- the potential threat of blue-green algal outbreaks and the associated impact are not addressed sufficiently - concern that the honouring of international biodiversity agreements is not a high priority (migratory birds Ramsar wetlands) - an apparent inconsistency in that -15 m AHD is proposed as the trigger level for building a weir and is also the point at which Acid Sulfate Soil risk increases substantially yet the water level after building a weir

will drop below this to -167 m AHD concern that the scenario from here might need to include seawater introduction into the lakes and there is no EIS relating to this possible intervention Concerns - the size and therefore the impact of mud waves generated during the construction of the proposed weir are unknown - the lack of information on rates of acidification and lack of chemical analysis of the sediments and the potential for release of heavy metals upon acidification - cutting off the river from the Lake by building the weir leading to loss of the aerating wind seiche effect - if there are low water flows over the weir in future what will be the impact on water salinity levels upstream - has sought clarification on the cost of engineering solutions but not received information Expresses supports for 10 other submissions Suggestion - proposes that the money that would be spent on all interventions and engineering solutions be used instead to buy water for environmental benefit as well as human consumption

PTW00026 Ms Judy Goode River Murray Environment Manager SAMDB NRM Board

The SA MDB NRM Board agrees the weir should only be built when all other solutions have been exhausted The submission argues in detail and with reference to EPBC-listed species and numerous other species that a fish passage is required to support migration of species upstream and downstream and to support upstream movement as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river Upstream wetlands The submission asks for consideration of the environmental impacts of re-filling wetlands and potential impacts of Acid Sulfate Soil mobilising into the river The submission indicates inadequate measurement of water savings from wetland closures in Section 434 There is an unquantified assumption about the prevalence of the Southern bell frog in Section 1310 which requires consideration Water qualitywater quantity impacts A significant omission is identified in that salinity impacts are not modelled over three years The weir pool above the weir will be relatively small and the impact of wind seiche in the pool is not understood Additional modelling is sought for acid release from acid

Supplementary EIS for the temporary weir near Pomanda Island -155shy

Submission no

Submission from Submission Summary

soils metals release increased nutrient loads blue-green algal outbreaks increased sedimentation and turbidity increased temperatures fish and other biota kills odour dissolved dust fuel and oil spills Further modelling on a range of scenarios Impacts of construction The weir site is at a junction of the Lake and River and is a biodiversity hot spot A more comprehensive explanation of the choice of this weir site is required Technical issuesmore details which require more consideration What are the environmental impacts of sourcing the weir building materials SA Planning justification in writing for exemption under the Development Act Environment and Construction Management Plans How do all the costs which would be included in a properly constituted business plan compare to the potential purchase of water (for a freshwater solution)

PTW00027

PTW00028

Mr Alexander Whitehead Hindmarsh Island resident

Supports the building of a weir at Pomanda Island Also suggests that regulators not be built in the lower reaches of the river and that seawater be allowed into the Lakes

Prof Peter Fairweather Professor of Marine Biology School of Biological Sciences

Background Research Associate and Prof of Marine Biology Flinders University Points on matters of national significance relating to the EIS - the submission raises a number of concerns about the adequacy of the geographic scope of the EIS the treatment of different types of aquatic habitat the use of averages in modelling and several other points listed below Concerns - there is a concern about gaps in the EIS relating to factors that drive ecosystem change the submission questions whether maxima minima and seasonality rates of change have been considered in addition

to average values as these are important - argues that the Coorong and Lake Albert will be affected and should therefore be included in the EIS - questions whether the impact of a weir really is insignificant relative to the effects of drought - questions the reliability of modelling for years 2 and 3 and suggests that more caution should be used in interpretation towards the end of the period - that there is a gap in the EIS in the treatment of aquatic habitat types such as the benthos and the water column - that the different models appear to use different weather sequences to predict outcomes for the same sets of years and that more attention should be given to variation as a result of different weather sequences The authors are not opposed to the need for or construction of a weir but argue that the accuracy of the EIS needs to be improved in relation to several matters of national environmental significance Other points raised The legibility of many Figures in the EIS was not adequate A comment about bird species discussed in 142 and 143 and whether these are the correct or appropriate species

Mr Robert Thomas Points on matters of national environmental significance relating to the EIS none

PTW00029

Supplementary EIS for the temporary weir near Pomanda Island -156shy

Submission no

Submission from Submission Summary

Concerns - concerned about health problems relating to lowered Lake water levels (dust) Supports the construction of a weir at Pomanda Island Suggestions - not to build the regulators around the lower reaches of the River and allow seawater into the Lakes - as a longer term solution suggests the building of a barrage with a lock at Wellington

PTW00030

PTW00031

PTW00032

PTW00033

Ms Barbara Carroll Native Foods amp Plants

Confidential submission

Mr Henry Jones Commercial Fisherman Boating Industry Association

The writer is a commercial fisherman He and his family have been in the Coorong Lower Lakes and Murray Mouth commercial fishing industry for six generations The industry in the area has achieved a number of significant firsts in sustainable fishery management The author now feels ashamed for the following reasons - the extinction of species - the dredging of the Murray Mouth - the death of two thirds of the Coorong - the changing from estuarine to marine of the remaining third of the Coorong - the change from once busy bustling wetlands to a sandy wind-blown desert - the exposure of Acid Sulfate Soils - the pain inflicted on our native animals especially the pain and death of turtles - the slow death of native water rats deprived of habitat - the death of small Lake birds who no longer have their sustaining habitat - the tonnes of dead mussels invertebrates and macro invertebrates - the Government blaming drought rather than providing environmental flows The writer submits that a weir will cause major fish kills and further environmental decay

Ms Gloria Booker Manager Development amp Environmental Services Rural City of Murray Bridge

The submission points out that there was insufficient time for Elected Members and the Council to provide formal comment The Murray Bridge community may receive aesthetic and environmental benefits from raising the River level but this should not be to the detriment of native wild life and migratory birds Points made include - the weir is a last resort in ensuring water for critical human needs - ecological damage is not irreversible - the proposed weir is of sufficient height to prevent salinity moving upstream from Wellington - professional fishermen are provided with access to Lake Alexandrina - the location of pumps does not allow salt water to be washed back into the river - consideration be given to allowing river craft and fish to move from the River to the Lake

Mr Chris Bagley Dryland Farmer

Points on matters of national environmental significance relating to the EIS - the Draft EIS carries no mention of the highly regarded and important Milang Snipe Sanctuary Concerns

Supplementary EIS for the temporary weir near Pomanda Island -157shy

Submission no

Submission from Submission Summary

- that SA water planning focuses too much on consumption - that the Draft EIS indicates that only 50 of the weir material is to be removed a the end of its life and that this is not acceptable - that there may be a weir collapse with associated impacts due to the nature of the base material Suggestions - the a uthor strong ly suggests tha t Dilution Flow be

rep lac ed by the c onc ep t of Maintena nc e Flow with a rationale and that MDB management should focus on this - that the Draft EIS focuses on a base flow of 350GLyear past Pomanda Island he suggests that other scenarios and their impacts also need to be considered including zero flow 700GLyr and 2000GLyr - the author supplies a water resource report for the MDB (Mar 09) and proceeds to argue that SA can buy environmental water to save the Lower Lakes without building the weir and for 25 less cost than weir

construction and removal a set of Tables outlining water purchases over the next 3 years is presented

PTW00034 Ms Liz Yelland General concerns are expressed about the draft EIS It fails to concentrate on all species and acknowledge interdependency It fails to persuade that sufficient water will overspill the weir into the Lake No or insufficient water could result in Carp dying and then all Lake life dying Suggests that the proposed temporary weir EIS should be considered with a seawater incursion EIS In relation to chapter 10 the author is concerned that Weir construction will signal to upstream river management that there is no need to provide water to replenish the Lakes as it evaporates Ch 10 is not predicated on the view that there is already an environmental emergency further endangering international treaty sites - Political will addressing over-allocation can save these wetlands - The author expresses concerns about Goolwa Channel and Finniss and Currency Creek regulators - Questions why so little attention is given to the Coorong Comments on Ch 5 - The writer provides an image of childrens Lego sinking in porridge - Local knowledge and draft EIS Appendix 6 are referred to as the author makes the case for the difficulty of establishing the weir at the designated site Comments on Ch 11 - Asks the question what is the possible effect of cutting off the seiche surges of water from Lake Alexandrina into the lower reaches of the River Murray - Local knowledge of seiching is provided which indicates that the River beyond Murray Bridge during times of very low flows has been oxygenated and saved - Also during low flow periods the seiche and wind variations allows salinity and pollution burden to be transported to the Murray Mouth Should seiching be interrupted increasing salt build up causes flocculation of clay particles suspended in the River Conditions then support the possibility of blue-green algae blooms

Supplementary EIS for the temporary weir near Pomanda Island -158shy

Submission no

Submission from Submission Summary

- The author is sceptical that temperature inversion will mix salt to an extent which allows low flow to transport it away - Negative effects of seiching - Salinity build up since 2002 is described (reference provided) - Acid A graph is provided with detailed interpretation of wind salinity water levels and pH The author concludes that generally wind seiching has positive outcomes and that acid is not showing signs of being a problem and salinity could be managed by intermittently ceasing pumping - Concerns about mobilising acid upstream from the weir in wetlands which have been cut from the River Comments on Chap 16 - It is the author s view tha t the EIS implies a n ac c ep tanc e of an unacceptable environmental collapse which shames country and governmentThe weir is an enormous gamble due to the possibility of the weir sinking that construction methods will be ineffective and there are probable unexpected consequences

PTW00035 Mr Lynton Vonow Points on matters of national environmental significance relating to the EIS - the EIS is deficient in that it is not presented as part of an integrated plan for the region and its water and environmental problems - potential impact of building a weircompared to only

having the sill a t the entra nc e to Lake Alexa nd rina a t Pomanda on fish eg Murray Cod Concerns - that the environmental impacts of permanent weirs along the River Murray are severe and the temporary weir poses a similar risk - that the weir would increase the likelihood of blue-green algal blooms in the river upstream of the weir (and associated risk to drinking water supply) - that the salinity spike that would occur in the water near Pomanda Island after construction of the weir would be very detrimental to long-necked tortoises through the negative direct impact of tubeworms which are salt-tolerant Suggestions - that better alternatives to building a weir are (a) purchasing water (b) increasing water harvesting in the metropolitan area of Adelaide (c) relocation of pumping stations to upstream of Lock 1 and that increasing the storage at Mt Bold reservoir has significant problems including negative environmental impacts - that as the Lake levels drop the problem of wind seiching of saline water into the river will decrease - that acid Sulfate Soils are not as serious a problem as was predicted - that allowing seawater into the Lower Lakes would be very destructive The author supports the submissions of 17 other people and groups

PTW00036 Ms Ruth Trigg Concerns - the author is concerned about the basic premise(s) for construction of a weir at Pomanda Island and offers a critique of the process which has led to this point She analyses Chapter 3 of the Draft EIS using an

Supplementary EIS for the temporary weir near Pomanda Island -159shy

Submission

no Submission from Submission Summary

ana lytic a l framework and a toolkit of d ifferent method s (such as Critical Discourse Analysis and a number of others) - from the list of 73 reports agreements and Acts of Parliament relevant to the River Murray system in the CLLMM region (cited in the submission and in Chapter 3) it is argued that the existence of these documents has not helped to retain the long-term health

of the river system - the lack of accountability with regard to the health of the MDB river system in the present system of government and interactions between governments - the unavailability of water audit figures for the whole MDB system for more than one month of data at a time (data seen as withheld) - tha t the voic e of multina tiona l c omp anies and sha rehold ers overrid es the environment s need s illustra ted

with recent quotes from the media about continued expansion of irrigation in upstream states - that the decision to build the proposed weir is connected

with the a im of g rowing South Austra lia s popula tion (to 2 million by 2050) and that keeping this expansion target in the face of present difficulties with the

sta te s wa ter sup p ly is unreasona b le - that the collective voices of knowledgeable people who live near and care about the River system in the CLLMM region will not be listened to Suggestions - the author suggests that new models of economic growth and development need to be urgently considered (eg further development and use of the Genuine Progress Indicator Dr P Lawn Flinders University) The author supports the submissions of 16 other individuals and groups

Supplementary EIS for the temporary weir near Pomanda Island -160shy

PTW00037 Mr John Yelland Points on matters of national environmental significance relating to the EIS - concern that the EIS guidelines have not been followed Concerns - the author seriously questions whether the weir structure can be built considering the nature of the foundation material especially the apparent unsuitability of the foundation at the western end and quotes material presented in Appendix 5 - the mud waves formed by the dumping of rock have not been studied adequately - the wetlands upstream of the proposed weir which are currently dry will be re-wet at some stage with potential for acid formation and release of heavy metals these acids and metals might not be adequately

flushed with the weir in place and the risks need to be studied - the Draft EIS is deficient in that it does not refer to other proposals such as the regulators at Clayton and at Finniss and Currency Creeks modelling of salinity and Lake water levels should take these other

developments into account The author supports the submissions of 13 other individuals and groups

PTW00038 Mr Bruce Brooks Points on matters of national environmental significance relating to the EIS no direct comment but questions are asked about some assumptions and the accuracy of

Submission

no Submission from Submission Summary

modelling presented in the EIS which lead to decision points (water levels wind speed and salinity) Concerns - argues that the problems of the CLLMM are not primarily a result of drought by comparing Figures 0-2 and a graph showing Murray-Darling Catchment annual rainfall trends 1950 2008 (both graphs with trendlines the latter graph possibly not in the draft EIS but presented at community consultation meetings) - argues that the data and modelling that have been used that point to -15 mAHD (trigger point) being reached in Lake Alexandrina in early 2010 may be incorrect and predicts that the levels reached will not be as low as this in the worst case scenario Further he presents data from Kotwicki 1993 (a factor relating evaporation from the lake to pan evaporation measured in situ at the lake) which differs from the factor used b y MDBC a nd uses Kotwic ki s factor to arrive at a higher Lake water level than predicted in the EIS - concern that the salinity levels in the Lakes in the modelling output presented in the EIS are underestimates and that the data need to be looked at again

PTW00039 Dr Keith Walker This is a detailed submission which provides important knowledge and information on a range of relevant issues including ecology and threatened species of the lower Murray and CLLMM The submission raises many pertinent questions Points on matters of national environmental significance relating to the EIS - a weir pool is not the same habitat for plants and animals as a river or a lake conditions in the pool will favour species such as common carp and discourage riverine species in particular - there should be a fish passage in plans for the weir - the author is concerned that diadromous fish (ie requiring access to the sea) are prevalent in the lower Murray but these would be unable to move beyond the weir - more consideration should have been given to the wetlands between Blanchetown and Wellington - contends that statements on page 13-17 (Interaction of salinity with EPBC-listed fish species) about salinity tolerance of early stages of freshwater fish are misleading - the author says that the discussion of EPBC-listed species is incomplete and superficial - states that national listing of freshwater species lags behind those for terrestrial environments and that communities in parts of the MDB including the CLLMM region are currently being evaluated for EPBC listing

- the author disagrees with statements in the Draft EIS that suggest tha t the weir would not a ffec t c ond itions a fter d isc onnec tion a rguing instead tha t rec overy will b e delayed - suggests that Chowilla should be listed among the Ramsar wetlands because birds may need to move that far if food becomes scarce in the CLLMM region Concerns - the proposal should be considered alongside other current and planned interventions in the CLLMM regions for

Supplementary EIS for the temporary weir near Pomanda Island -161shy

Submission no

Submission from Submission Summary

the purpose of the EPBC Act - that over-allocation of water is likely to be a major contributor to the crisis in the CLLMM - that the alternatives to a weir have not been adequately considered in terms of feasibility costs and benefits in economic and environmental terms ideas such as shandying water are put forward - that there is a significant risk of development of algal blooms including toxic blooms in the weir pool and that there is scientific literature on this local situation - that the weir will be in place for at least 10 years (with reasoning for this conclusion) - the construction of access roads to Pomanda Island should have been subject to an EIS as it iswas a (dynamic) sand spit - that there is little reference in the EIS to work on Acid Sulfate Soils in other places - that the salinity categories in Table 2-4 are broad and have too little relationship to ecological consequences that the tolerable salinity limits for freshwater species need to take into account peak levels not

average levels - that flooding of the Lakes region with seawater will cause a total ecosystem collapse of a Ramsar-listed wetland - that the weir will have an impact on pest species (common Carp and tubeworm) but this is not addressed in the Draft EIS - tha t the term keystone spec ies is misused in Chapter 6 Suggestions - more attention should be paid to mixing processes in the weir pool and Lake Alexandrina with respect to the perceived increased risk of algal bloom formation - tha t we should ma ke more use of others c onsid erab le experience on dealing with Acid Sulfate Soils

PTW00040 Ms Alison Radford SA President Australian Institute of Landscape Architects

The AILA notes that the following points appear to be missing from the Executive Summary under the terms of reference of the EIS and should be included there as they have been addressed in the body of the Draft EIS - what is the potential for deterioration of the quality of water in the weir pool - is there a soil acidification risk upstream as a result of the construction works - how will the weir pool be filled without increased water flows to the River - there d oes not a p p ear to b e any worst c ase sc ena rio discussion of the effects of further disrupting flows within the main River channel Also AILA notes that while there has been a lot of discussion of impacts downstream from the proposed weir in the Draft EIS there is not a corresponding examination of effects upstream AILA requests that future consultation processes include information sessions in the Adelaide metropolitan area

PTW00041 Mr Trevor Harden This submission argues that dust from exposed dry lake beds in the CLLMM region is a major problem and concern and that the best way to control this problem is to fill the Lower Lakes region with seawater a step which requires that the weir at Pomanda Island be built as soon as possible The author is opposed to community groups who advocate a freshwater solution only and argues that historically the

Supplementary EIS for the temporary weir near Pomanda Island -162shy

Submission no

Submission from Submission Summary

CLLMM area is very likely to have been saline especially at times of low river flow He takes issue with the d oc ument A Fresh History of the La kes by Sim and Muller a nd a rg ues with the support of quotes from journals and personal observations that the CLLMM has a history of being a saline estuary at certain times

PTW00042 Mr Bruce Angus Allnutt Committee Member River Lakes amp Coorong Action Group

The submission mainly addresses Chapters 8 and 10 of the Draft EIS Points on matters of national environmental significance relating to the EIS - queries why there is no fishway in the proposed weir - contends that many statements in the Draft EIS use

language tha t suggest there may be impac ts but the authors believe that many of these impacts will definitely eventuate - the authors suggest that impacts on non-listed EPBC-listed species can affect EPBC-listed species because they are part of the same food chain Errors - Page 10-2 of the Draft EIS the authors state that

Tookayerta Creek is a tributary of the Finniss River not of Lake Alexandrina also the Finniss River and Currency Creek flow into the Lower Murray not Lake Alexandrina Concerns - the lack of consideration of ground water resources in the

Draft EIS - that the site for the weir is unsuitable - the loss of habitat due to lack of freshwater flows - that the social issues and impacts are not addressed - that the effects of drought on low water levels are overstated and that the impacts of water over-allocation are likely to be substantial - Table 10-4 states that water levels in Lake Alexandrina will be maintained at +08 mAHD the authors argue that levels of no greater than +07 mAHD should be maintained otherwise there can be serious

erosion damage - the authors are concerned that the systems modelling uses incorrect assumptions or is not reliable (Table 10-8 and Section 1042) - that Section 107 may not be taking into account the extraction of water from pipelines being constructed that take off water upstream of the proposed weir Questions and suggestions - that the EIS should be part of a combined EIS for the larger set of interventions occurring in the CLLMM region - Section 823 that hazardous substances be stored well away from the weir site during construction - query whether the site of the spillway is optimal and suggest that in the present eastern location this will lead to worse silting problems than if it were placed further west - on page 10-3 there are additional reasons for increase in salinity in the Lower Lakes - in Table 10-3 the word sp illway should be inserted a fter weir in the sec ond aspec t point - query why the dilution flow would be disrupted apart from during the weir pool filling period (Table 10-3) - in Table 10-4 there should be a LAC for the Angas River - the modelling has used worst case scenarios was any modelling done with other scenarios

Supplementary EIS for the temporary weir near Pomanda Island -163shy

Submission no

Submission from Submission Summary

- the authors would like clarification of the last paragraph on page 10-30 - top of page 10-31 The authors endorse the majority of the key points of 15 other submissions

PTW00043 Mr Neil Shillabeer Chairperson Lower Lakes and Coorong Infrastructure Committee

Points on matters of national environmental significance relating to the EIS - potential effects of significant mud displacement during building of the weir on aquatic life - states that the Draft EIS Chapter 12 (page 12-2) is incorrect and that the Ramsar boundary does extend above the proposed weir site and quotes section 1248 (page 12-12) Some wetland s up stream of the

weir [that are] still within the Ramsar boundary are expec ted to experienc e eleva ted wa ter levels Concerns - that the time required to fill the weir pool will be greater that stated in the EIS because swamps between Wellington and Mypolonga have subsided and the soils under the swamps have dried out these will take time to be re-wet

- that the weir will be difficult to complete (close) satisfactorily given the design and construction method and that it may be unstable as a result - that the scale of the proposed weir is much larger than the example quoted in the EIS of the blocking bank at Narrung Narrows which has already had problems that required attention including recent problems not included in the Draft EIS

PTW00044 Mr Ron Heyne The author supports a weir or a permanent lock at Pomanda Island and seawater incursion into the Lakes The author is concerned about other weirs at Finniss River Currency Creek and Clayton and pumping water from Lake Alexandrina into the Goolwa channel He understands this will deplete the Lake and expose more Acid Sulfate SoilsHe proposes a channel into Lake Albert from the Coorong

PTW00046 Mr Shaun Berg Lawyer Ngarrindjeri People

This is a lengthy detailed submission which addresses a variety of issues and makes 57 points about the Draft EIS The submission suggests that the Draft EIS for Pomanda Island be rejected and that the building of the proposed weir should be rejected on a number of grounds It is argued that the EIS has failed to take into account Ngarrindjeri views and that Ngarrindjeri Native Title Rights are affected Finally the submission appends the disclaimers in the Draft EIS and the Appendices to the Draft EIS and thereby points to a number of uncertainties in systems modelling (eg salinity wind) and efforts made by Government and consultants to reduce these uncertainties This submission supports those made by two other individuals Early in the submission the following points are made about the wishes of the Ngarrindjeri

1 natural solutions should be used rather than engineering solutions

2 solutions should consider the CLLMM region as an integrated whole

3 the CLLMM region needs to be maintained as a freshwater area

4 environmental flows to the system are needed to

Supplementary EIS for the temporary weir near Pomanda Island -164shy

Submission no

Submission from Submission Summary

maintain freshwater ecology 5 exposed lake beds should be remediated by

plantings or sand 6 cattle and other animals should be excluded from

these areas to minimize acid soil problems 7 hot spots of acid soils should be treated with lime or

sand Omission Table 4-3 is referred to in the text of the Draft EIS but is not supplied Points on matters of national environmental significance relating to the EIS At least 5 points relate to the EPBC Act - the Australian Painted Snipe should be considered in the EIS (with reasoning) - the EPBC protec ted matters searc h tool wa s used to generate the list of EPBC-listed species likely to be found in the region This result is indicative only has consultation with experts also occurred - the draft EIS does not include the Coorong or Lake Albert in relation to impact on Ramsar listed wetlands yet the Coorong and Lakes Alexandrina and Albert were listed together as a wetland of international

importance under the Ramsar Convention the three are related especially given that water is being pumped from Lake Alexandrina to Lake Albert - the potential impacts of weir operation and removal on

EPBC-related matters has not been not addressed Concerns - EIS process at least 6 points deal with EIS process for

example there is concern that the Draft EIS is not a stand-alone document as required (eg accompanying documents referred to in the Draft are not all available)

- Integration is needed at least 5 points deal with the need to consider this Draft EIS together with the environmental impacts of other current or planned interventions in the region (such as the introduction of seawater into the Lower Lakes)

- Over-allocation it is suggested that over-allocation of water is a major reason for the current crisis

- Technical concern is expressed that too little detail is provided about the construction of the weir

- Removal of the weir no consideration has been given to the removal of the weir if the Lower Lakes have been flooded with seawater This needs to be considered

- Alternative solutions 14 points deal with alternative solutions to the building of a weir it is argued that alternative solutions have not been described or considered in sufficient detail particularly the possibility that

combinations of alternatives may be an effective way to gain sufficient freshwater supplies

- Systems modelling concern is expressed that (a) the impacts are assessed only with an inflow of 896 GLyear to SA other scenarios with lower inflows need to be considered (b) salinity is only modelled for one year (c) impacts of the weir on water temperature

and turbidity are not addressed sufficiently - Soil chemistry risks associated with Acid Sulfate Soils

upstream of the weir and potential impact on the potability of water around pumping stations should be given greater attention there are several questions

Supplementary EIS for the temporary weir near Pomanda Island -165shy

Submission no

Submission from Submission Summary

about Acid Sulfate Soils for example what is the likelihood that the building of the weir itself will lead to a pH crash

- Management and mitigation a number of concerns are raised about what monitoring enforcement mitigation and review procedures will be applied

Suggestions - that the Draft EIS for Pomanda Island be rejected on the grounds that it does not comply with the Guidelines - that the SA Government take into account the changed use of the weir (from a means of securing water supply only to also acting as a barrier to ingress of saline or polluted water into the river) and then resubmit an EIS which covers this broader scope - that the Draft EIS fails to support the construction of a weir at Pomanda Island on the following grounds

1 The proposal does not consider alternatives sufficiently particularly combinations of alternatives

2 That the draft fails to distinguish adequately between impacts of the scenarios with and without the weir

3 There is a risk that the water quality in the weir pool may be poor because of algal blooms

4 There is insufficient attention given to the problem of Acid Sulfate Soils and measures taken elsewhere to solve this problem

5 The proposal should be integrated with other proposals eg the proposal to allow seawater into the Lower Lakes

6 The treatment of EPBC-listed species is superficial and lack plans for mitigation of negative impacts

- that the Draft EIS fails because it does not take into account views of the Ngarrindjeri - that Ngarrindjeri Native Title Rights are affected by the proposal and a number of points are made in relation to this claim

PTW00047

PTW00048

PTW00049

Mr Andrew Milazzo Executive Director TSD DTEI

This submission details the requirements for technical aspects of commissioning the weir according to DTEI regulations Examples are the inclusion and positioning of warning lights on the structure and signage The submission notes that there was no mention in the Draft EIS of the operation of the Narrung Ferry

Ms Jacqui Showell Suggests Adela id e s wa ter supp ly is the main d river for the weir Questions if enough alternatives are being investigated Concerned that decommissioning criteria will never be met Suggests ecological effects downstream will also occur upstream affecting the whole country Believes the system should be treated as a whole Suggests acid and heavy metals will affect regions and Ad ela id e s d rinking wa ter Concern for flora fauna (particularly southern bell frog Murray cod and migratory birds) and Ramsar obligations

Ms Cecily South Over-allocation and human activities need to be addressed The Eastern Mount Lofty Ranges flows into Lake Alexandrina mitigate ASS and heavy metals Further water savings are possible if households have allocations rather than timing restrictions There is water upstream get it Crops that cannot be sustained with irrigation should be

Supplementary EIS for the temporary weir near Pomanda Island -166shy

Submission

no Submission from Submission Summary

abandoned - change to sheep and cereals Reference to technical paper written by Brooks and South The barrages all lead but must be kept closed The SA Government and SA Water should stop pumping from Lake Alexandrina into Adelaide storages Landowners are losing 2-3 metres of lakefront pa The author is opposed to seawater incursions

PTW00050

PTW00051

PTW00052

PTW00053

Ms Ruth Beach Solicitor Environmental Defenders Office (SA) Inc

Points on matters of national environmental significance relating to the EIS

- this submission argues that the proposed weir will be permanent rather than temporary because the conditions for its removal are not likely to be met and that it will be physically very difficult to remove the weir as such the proposed weir should be assessed under the Development Act and the Draft EIS should take into account permanent effects on the environment in the CLLMM region including the Ramsar-listed wetlands and associated fauna and flora

- proposes that the construction of the weir is in contravention of legislation (State and Federal) and international conventions (Federal EPBC Act Water Act Murray-Darling Basin Act State Development Act River Murray Act Natural Resource Management Act Environment Protection Act)

- it is argued that the Draft EIS and proposed weir should be considered alongside other current and planned interventions in the CLLMM region

Concerns - that the EIS has not given sufficient consideration to

alternative sources of water - that other relevant Government reports are still in

preparation Ms Silver Moon Suggests EIS should and fails to be about the impact of an

action Suggests there is deficient understanding of the environmental processes and interactions in the Coorong and Lower Lakes Suggests climate change needs to be addressed Contributes considerable researchedreferenced information on various fauna and suggests they should be included as matters of NES Indicates the significant impact weir construction will have on wildlife and the system Suggests Australia has agreements it must abide by Suggests Chapter 15 is vague and lacking substance Suggests the weir does not meet principles of environmentally sustainable development and calls for action in addressing water allocation in the Eastern Mount Lofty Ranges including Finniss catchment

Mr Rex Hunter Confidential submission

Mr Tim Drew CEO The Coorong District Council

The Council points out - Tha t muc h of the CLLMM area is within the Counc il s boundary and details the population and main land uses - That the area is of particular significance to the Ngarrindjeri - That the Coorong and Lower Lakes were listed in 1985

as a wetland under the Ramsar Convention and that

Supplementary EIS for the temporary weir near Pomanda Island -167shy

Submission no

Submission from Submission Summary

a req uirement is to manage the a rea in a way tha t mainta ins [its] ec olog ic a l c harac ter

- That the Coorong and Lower Lakes are icon sites under the Living Murray Initiative - That as a response to the situation it has established the Lower Lakes and Coorong Infrastructure Committee (2007) - That it is opposed to the construction of the weir at Pomanda Island and any other new man-made structures in the River Murray

Points on matters of national environmental significance relating to the EIS

- the submission points out that there is a Ramsar wetland just upstream of the expected weir site at Pomanda Island and that this needs to be corrected in the Draft EIS - there is concern that there will be significant algal blooms after weir construction and that this will have a negative impact on native fish stocks

Concerns - that the present situation has been brought about by over-allocation of water resources across the MDB rather than by drought - the economic and social impacts of the situation (low water levels and flows) are very serious - that the weir will intervene in the natural river system and have a negative impact as a result - that the Draft EIS Chapter 26 includes the topic of maintenance of water levels for pumping purposes and that this was not included in the original referral to the Federal Government - that the modelling in Chapter 2 is in error because the forecast figures used for levels of L Alexandrina considerably understate the winter rainfalls of 2008 - that the modelling in Chapter 2 may be unreliable because it relies on estimates - that the triggers for removal of the proposed weir need to be more clearly defined and more realistic (the current conditions for removal are not likely to occur for another decade) - that there is a significant risk of blue-green algal blooms in the weir pool - that there is a risk of heavy metal release and acidic soils if the weir is built and potential impact on wildlife - that the weir will lead to the build-up of water with low oxygen concentration with risk to fish populations - that the significance of wind movement (wind seiche) is underestimated in the Draft EIS

PTW00054 Prof Diane Bell Committee Member River Lakes amp Coorong Action Group Inc

The Draft EIS should be rejected because it is inconsistent with the Guid elines for the Content of a Draft Environmental Impact Statement on the Proposed Temp ora ry Weir a t Pomand a Isla nd The p roposa l

- is not a stand-alone document - should properly be considered as part of a larger plan - lacks detail to support plans for construction operation and removal - has no staged and costed short mid and long-term plans for mitigation of NES - fails to investigate alternatives

The proposal will not achieve its stated goals because the

Supplementary EIS for the temporary weir near Pomanda Island -168shy

Submission no

Submission from Submission Summary

- triggers for removal are unrealistic - construction is problematic - water quality above the weir will be poor

The proposed action is likely to have significant impacts on internationally protected wetlands and species that the Federal and South Australian governments are obliged to protect The proposed weir is not the solution to the crisis in the Lower River Murray and Lakes The SA Government should be required to submit a Referral which takes all proposed actions into account and explores all options Part 1 the status of the EIS procedural points Summary It is their contention that the Draft EIS is significantly flawed and should be rejected by the Minister under Section 133 EPBC or alternatively the Minister should require that new Draft Guidelines ones that accurately reflect the situation and the needs of Adelaide for a secure water supply be prepared by the SA Government A number of points require further consideration

1 There is no longer a crisis of water security Minister Maywald has announced she has bought water for next year Acidification and increased salinity are now significant issues but were not when the Guidelines were published Given that both quantity and quality issues have changed the Guidelines should be varied or a new Referral written

2 Since the proposed temporary weir referral there have been a number of other proposals which impact on the quality of water (a weir rationale) The EIS is (therefore) flawed because it is not a stand-alone action and is in violation of the Guidelines

3 The author asserts that the triggers for removal cannot be achieved and there is no long-term plan that explains how they might be achieved

In other points the writer expresses a desire for access to related documents greater clarity and certainty less repetition in the draft EIS and for supplementary reports to be ava ilab le In a d d ition the EIS outlines c onsulta tion whic h has been inadequate ineffective and non-responsive to pub lic questions Part Two Chapter commentaries substantive questions The a uthor s summary sta tesThe EIS is tentative incomplete lacks detail and refers important matters to further supplementary reports and EIS The author states that the SA Government should be req uired to make d eta ils of the freshwa ter solution available as part of the EIS process She asks for a stronger d efenc e of the weir as the only feasib le op tion Referring to Richards she indicates that over-allocation and poor management continue on the Finniss and other tributaries today and asks who makes decisions about critical human needs and under what conditions On wetlands she states that the EIS cannot be considered competent and on seepage and run off the EIS does not give due consideration and states that the criteria for removal are unrealistic and unlikely to be met The Draft EIS displays little or no understanding of the imp ortanc e of c ultura l flows to the Nga rrind jeri

Supplementary EIS for the temporary weir near Pomanda Island -169shy

Submission no

Submission from Submission Summary

Chapter 2 comments as for submission by K McFarlane Chapter 3 comments this consists of pages 7 and 8 of the EDO submission which sets out reasons for non-approval of the Draft EIS under various legislative and regulatory processes Chapter 4 comments this is a combination of K Mc Farla ne s sub mission with a few c ha nges with the addition of the suggested Government freshwater purchase options (staged over three years) from C Ba g ley s submission Chapter 5 Proposed works to be undertaken The author contributes local knowledge about aspects of the Causeway which indicate that it is a dynamic area and that the development of the Causeway will create new flow patterns during floods Comments included

- there is no staged plan for the period of the weir pool filling to manage water issues and consequences below and above the weir - there is insufficient detail describing weir construction methods - insufficient is known about embankment materials and potential to pollute

Concern is expressed about - the amount of weir material which will sink or be washed downstream - the lack of an Environmental Management Plan - the lack of a fish passage - unrealistic weir decommissioning triggers and lack of detail in decommissioning planning

Relevant aspects of the submission by Liz Yelland are then included Chapter 6 comments replicate those submitted by Silver Moon in her submission Chapter 7 comments replicate those submitted by Silver Moon in her submission Also included is a portion of Anne Hartnetts submission (80409 page 5) The first section asserts Australias seemingly low honouring of Jamba Camba Kowamba and the Ramsar agreement and refers to the effect of the weir on migratory birds and the significance of weir placement at a meeting of waters Further Hartnett references (page 5) are made in relation to water levels and the need for spelling out of the effects of MAJOR interventions to remedy the result of these that

would be felt by all other biota Chapter 8 comments this is essentially taken from the submission by B Allnutt and T Giles with an additional comment expressing concern about the risk of habitat loss which in turn leads to species extinction Chapter 10 comments this section contains almost all of B Allnutt a nd T Giles submission (exc ep t for the summa ry of c omment for EIS p lus a paragrap h referring to C Bag ley s submission (questions about salt mobilization when sufficient ra in fa lls) two c omments from K Walker s sub mission (concerns about algal blooms upstream of the weir and acidification of wetlands upstream of the weir) and pages 3 to 5 of L Yella nd s sub mission a b out wind seic hing Chapter 11 comments this includ es N Shillabeer s submission one page (pa ge 4) of A Ha rtnett s submission (the effect of the weir on upstream water quality) and two

Supplementary EIS for the temporary weir near Pomanda Island -170shy

Submission no

Submission from Submission Summary

paragra p hs from S Ric ha rd s sub mission (wa ter qua lity) Chapter 13 The criteria for removal are unrealistic and unlikely to be met This underlines the lack of a long-term rec overy p lan and c asts d oub t on the tempora ry na ture of the weir Chapter 14 comments raise the absence of the Milang Snipe Sanctuary from the draft EIS Page 67 contains the list of birds also contributed by Silver Moons submission (Moon S un-numbered page re section 77 Summary) Commentary on Chapter 15 Environmental safeguards and mitigation measures raises

- Lack of fish passage - Diminution of freshwa ter hab ita t for two mentioned fish spec ies - c omment tha t a rg uements tha t the impac t of the weir c onstruc tion a nd opera tion a re minima l a re misguid ed and fa ils to rec ognise the p rob lem

Further Chapter 15 inclusion replicates in full questions raised by Liz Yelland (submission PTW 34 pages 1-2)

PTW00055 Mr Tim Milne Scientific Officer Nature Conservation Society of SA

Issue 1 Suggests the weir will exacerbate water level reduction and potential problems increasing need for remedial action Also suggests EIS does not address remedial action required Solution 1 examine the impacts of actions to increase water levels in the Lake as these are a direct consequence of weir construction and operation Issue 2 Risks to species associated with increased salinity and acidity Solution 2 EIS should examine impacts of accelarated incareases in salinity and acidity of the water Issue 3 Shortcomings in the environmenetal assessment of construction in Ramsar wetlands Solution 3 Full range of florafauna species need to be examined Issue 4 Lacking accurate information on period of operation and predictions of removal triggers Solution 4 EIS should assume the weir to be permanent to mitigate matters of NES in case this occurs

PTW00056 Ms Gillian Whiting Project Coordinator Murray-Darling Basin Authority

This submission is in the form of the letter addressed to the Director CLLMM Projects under the signature of the Chief Executive Rob Freeman Murray-Darling Basin Authority The letter notes that the proposed temporary weir must be assessed and approved under the Water Act 2007 (Cth) The MBDA requires more details than already provided in the EPBC Act referrals The MBDA asks for clarification and expansion of a range of issues - flow use control and quality of water The MBDA requires information and data relating to hydrology design flow assumptions water balance (inflows storage outflows) assumed water volumes design flood assumptions Hydraulics design details relating to flood surcharge and Water Quality flow cessation into Lake Alexandrina and seawater introduction and acidification thresholds The authority seeks additional information in order to make an Environmental Assessment on fish passage and disconnected wetlands below Lock 1 Weir plans must be submitted to the Authority for

Supplementary EIS for the temporary weir near Pomanda Island -171shy

Submission no

Submission from Submission Summary

consideration and approval Information is required about the capacity of the weir crest to resist erosion More detail is required in relation to weir removal in relation to definitions of normal time required to remove method of removal if a flood Other issues in relation to increased salinity in Lakes Alexandrina and Albert the effect of potentional increase in heavy metals and salinity and increased acid production It is anticipated that the Authority will require at least six weeks to undertake its approval processes

PTW00057 Mr David Winderlich Member of the Legislative Council Leader of the Australian Democrats

The author suggests that the cost of the weir be put into buying water bioremediation and assisting communities experiencing hardship due to low flows In his opinion the Lakes ecosystem and relevant matters of NES will not tolerate the impacts of the construction of the proposed weir The author advocates a natural freshwater system

PTW00058 Ms Kathryn Rothe Project Manager Mannum to Wellington LAPG amp Mypolonga Highland Land amp Water Management Group

Background this submission is on behalf of the Mannum to Wellington Local Action Committee and the Mypolonga Highland Land and Water Management Committee This submission relates in some aspects to the submission by Ruth Trigg Points on matters of national environmental significance relating to the EIS - lack of a fish passage across the weir is pointed out - concern about loss of important habitat Concerns - that the weir is only a bandage solution and that a strong integrated plan is needed that encompasses the environmental as well as social and economic survival of the Lower Murray and the CLLMM region - the submission does not support the construction of a weir and argues that alternative measures must be used especially the purchase of freshwater upstream for the CLLMM and Lower Murray region - that over-allocation of water is an important cause of current problems - that alternative water supplies have not been given sufficient consideration - that there have been and are many plans and reports about the situation but there does not seem to be a holistic or integrated plan - tha t g rowth in the Sta te s pop ula tion will put even more pressure on water and other resources - the allocation of water to different users needs to be reassessed by the MDBA in a holistic way and with food production as a priority - that the weir will be unstable Suggestions - that freshwater be brought downstream to SA where evaporation rates are much less than at the Menindee Lakes - that bioremediation of Acid Sulfate Soils is already occurring - that the new MDBA should start emergency actions in the region as soon as possible - that alternative sources of water and water conservation and re-use measures be put in place The author points out that the task of preparing this

Supplementary EIS for the temporary weir near Pomanda Island -172shy

Submission no

Submission from Submission Summary

submission was daunting and that it took a lot of time effort and community spirit to prepare This submission endorses the submissions of approx 18 other individuals and groups

PTW00059 Ms Karyn Bradford The writer highlights long connection with the CLLMM extensive knowledge and a long list of achievements in the region The submission contains additional references The writer is concerned that there has been a lack of effective public consultation and that government ministers and their employees chose to dismiss the knowledge skills and expertise freely offered by members of the community many of whom have intimate and generational knowledge of the Lakes and Coorong environment EIS coverage The writer believes that the EIS should be rewritten to include all proposed action for the CLLMM region Language used EIS la nguage is c ritic ised a s [c asting] d oub t on the qua lity and veracity of the informa tion p rovid ed and a s having very few d efinitive sta tements

Seiching A very strong possibility that un-potable water could travel down the river and be trapped behind the weir is identified as a flow on effect of interruption of wind seiching Fish passage The lac k of a llowa nc e for a fish passage is sta ted as not meet(ing) one of the three key ecological objectives of the Murray-Daring Basin Commission Environmental Management Plan 2007-2007 for the CLLMM Icon Site River and Lakes system complexity not understood The writer states that the EIS shows that the proponent does not understand the complexity of the interactions between the River Murray Lakes Alexandrina and Albert its tributaries and the Coorong Ramsar principles breached The author submits that the Ramsar wise use tenet and the precautionary principle are breached by the weir at a time when over-allocation and drought have already done c onsid erab le ha rm to the environment The writer endorses submissions of other named persons A table is used to identify and address issues applicable to specific sections of the EIS including - Executive Summary Purpose

Questions whether full information is available No discussion of bad water coming down Murray Seawater option outside this EIS Alternatives to EIS proposal named

- Executive Summary Introduction Possibility that weir will contribute to algal growth if mixing is impeded

- The original referral Lack of fish passage contradicts Murray-Darling 2007shy2007 Management Plan objectives

- Draft EIS section 737 References to Angus and Bremer Rivers are omitted d esp ite signific a nt b iod iversity va lues partic ula rly a t their c onfluenc e with La ke Alexa nd rina

- Draft EIS section 7-5 Why were only 9 of the 68 listed threatened species discussed in detail

Supplementary EIS for the temporary weir near Pomanda Island -173shy

Submission no

Submission from Submission Summary

Short and Long necked turtles and the Japanese Snipe are of particular interest to local people

- Appendix 15 Raises concern with levels of confidence in 64Confidence in impact assessment Suggests that further information is required

- Selections from the EIS The uncertainty expressed by the use of qualifiers in the EIS language is raised as a concern Question Is there enough evidenc e for this p rop osa l to proceed without further study of all aspects of the p roposa l

- Section 121 A sta tement is mad e tha t the weir will not may interact with the ecological values of the Lower River and Lakes

- Section 141 An attachment provides a record of migratory birds sighted in the area The definition of regularly sighted birds in the EPBC Act is questioned and a Web address supplied at which a local record of birds sighted is kept httpwwwmilangorgauMilanghtm

PTW00060 Mr Mike South Attachment Brooks B amp South M Discussion Paper 19 August 2008 Applying a localised water balance approach to estimate losses from Lake Alexandrina and Lake Albert for the years 1970 to 2006 The author suggests that the models used for the virtual weir should be used with caution and a range of further scenarios need to be modelled A clarification is offered in relation to weir pool levels and pumping SA Water pumps can access water at minus 30m therefore there is no need to maintain levels at +1m AHD The a uthor d isc usses in d eta il sec tion 452 Red uc ing Evapora tive losses of the d ra ft EIS and d isputes the statement that 70 of evaporative losses occur in the Lower Lakes He concludes that long-term evaporation for the Lower Lakes is an over estimate and that the apportionment of losses inappropriately biases the Lakes

PTW00061 Mr Jonathan McPhail Inland Fisheries Management Officer PIRSA Fisheries

The proposed weir will increase pressure on fish stocks and fish habitats which will have significant environmental impact on commercial and recreational fishing Habitat above the weir water will be more stable than currently The changed flow regime will better support European carp and negatively impact on spawning recruitment and migration of Murray cod Murray hardyhead and Yarrra pygmy perch This will work contrary to the MDBC Native Fish Strategy Water quality Removing saline water above the weir will d iminish na tive fishes c omp etitive a d vantage Potentia l decreases in salinity and increases in nutrients and sedimentation will also favour European carp and Mosquito fish and potentially increase the threat of blue-green algae blooms A fish passage is required to support migration of species upstream and downstream and to support upstream fish movements as a response to declining water quality in Lake Alexandrina Without a fish passage large scale fish kills in the Lake are possible and fish life cycles will be disrupted and recruitment decline

Supplementary EIS for the temporary weir near Pomanda Island -174shy

Submission no

Submission from Submission Summary

In addition the MBD has invested $45M on the Lake Hume to the Sea fish passage program A weir near Wellington would be the only barrier to 2000km of river The proposed temporary weir will have severe negative impacts on the available fish habitat and water quality and affect the environmental sustainability of commercial fishing

PTW00062 Mr Glenn Williams Natural Heritage Manager Natural Heritage Trust

The writer has 4 areas of key concern with the EIS 1 Failure to take an ecosystem approach

- The imp a c t of adding a further 5200 hectares to the tens of thousands of hectares of fringing reed-bed habitat that have already dried out and degraded along with their micro and macro invertebrate populations has been stated but not properly assessed in the EIS

- The EIS tends to b e qua lita tive ra ther tha n quantitative both of the proposed weir construction and the altered water regimes across ecosystems A clearer quantitative estimate of potential impacts upon na tive vegeta tion is need ed An example is given relating to impact of rock acquisition on native vegetation

- The writer states that the impact on wetland vegetation and (specifically) samphire plant communities should be quantified more accurately

- The writer is concerned that the EIS does not address over-allocation of water and states that no water allocation has been made for the Ramsar site Irrigation and upstream allocations are referred to

- It is asserted that the weir will withhold even more flow including 350MLday to flush out salt emanating from upstream water-using activities

- EIS is considered to give insufficient attention to the potential implications for the Coorong and the hydrological links between the Lower Lakes the Goolwa Channel and the Coorong particulalry during the period of filling the weir

- The writer believes that the Draft EIS lacks context and overview of the range of other feasible actions that might have been taken as well as those needed with the construction of the temporary weir

2 Failure to seriously examine pursue and commit to fund ing other rea sona b le a nd p rud ent a lterna tives

- The writer argues that human needs have been given priority with minimising of environmental impact being a secondary objective

- The writer asserts perceived lack of action by the state government to decrease reliance on Murray giving examples of water allocation from the Murray to the Clare Valley the BILL scheme Port Lincoln and a Port Hughes golf course

- The writer sta tes tha t the p roponent s EIS ob liga tion to exa mine p rud ent a nd fea sib le a lterna tives has

not been fulfilled by the failure to seriously address - Harvesting of stormwater and more substantial flows

from the short west-flowing creeks of the Mt Lofty Ranges

- Promoting water tanks - Increasing Adelaides water restrictions - Pricing water more competitively particularly for

Supplementary EIS for the temporary weir near Pomanda Island -175shy

Submission

no Submission from Submission Summary

industry and irrigation - The writer considers that the movement of the

pumping stations to above Lock One is a better alternative to the weir

3 Failure to adequately address impacts on EPBC Act-listed fish and frog species

- The writer sta tes tha t the EIS ignores c ond itions below the weir and only concentrates on higher water levels above the weir

- The writer notes that there is no commitment to building a fishway to address the impact on Murray hardyhead and Murray cod caused by disconnectivity between the Lake and River and further sta tes tha t the EIS seems to g loss over the very serious impacts that the iconic Murray cod will suffer from reduced water levels and wa ter qua lity

4 Failure to address geotechnical structural problems with the weir

- Refer section 55 and Executive Summary and Appendix 6

Specific issues raised refer to - poor foundation conditions except for the eastern

half of Getochnical model 1 - low sheer strength indicating slope instability - continuing movement and settling of clays - seepage and possible development of piping - impact of earthquakes on foundation sands

Other concerns addressed in short are - The temporary weir being left in place for a longer

period - writer s rec ommend a tion tha t a c tive-adaptive

processses be adopted for bio remediation of Acid Sulfate Soils and a need to clearly identify the indigenous plants to be used

- lack of information on impacts of temperature changes in the Lakes water column

- failure to address the oxygenation of the River water through wind seiching

PTW00063

PTW00064

Ms Beryl Belford Writer supports a one river and whole of basin approach to ecological management of the River and Lower Lakes The writer believes that - water is available in the basin to save the River system - the federal government must take responsibility for equitable distribution of water - state government should regulate water held in stock and domestic dams in Eastern Mt Lofty ranges to ensure environmental flows to the Lower Lakes

Ms Elizabeth Hobbs Points on matters of national environmental significance relating to the EIS - the author is alarmed that the potential impacts of the weir on the Coorong are referred to so little - states that the list of endangered species in the EIS is too narrow and argues that as both species and habitats are interconnected they should not be split up for the purpose of the EIS - emphasizes the need to have healthy waterways in the region due to its ecological importance Concerns - the author is concerned at the cost of the weir and other interventions in the CLLMM region and quotes from other

Supplementary EIS for the temporary weir near Pomanda Island -176shy

Submission no

Submission from Submission Summary

submissions on this point - from first hand experience at seeing sediment build up due to low water flows the author is concerned that this will occur at the weir site and there will be an impact of this silting up - that the weir is a technical solution for problems that should be solved by other means - that the proposed weir needs to be considered as part of the larger set of interventions occurring and being planned in the CLLMM region - that over-allocation of water rather than drought is the reason for major problems occurring Suggestions - the author proposes that there are alternative measures that should be put in place and expanded to reduce Ad ela id e s relia nc e on wa ter form the River Murray - an interconnected systems solution needs to be developed to protect the area listed under the Ramsar agreement

PTW00065 Dr Talina Vizard The writer questions Can local springs be channelled into the river (eg from Victor Harbor) Would redirecting storm water into the system help Have views of Ngarrindjeri been considered Can the use of bore water be policed and how can farmers be educated to the effect of taking water from the c ommon store

Writer Comments Time for comment too short Writer supports the submissions of Liz Yelland (PTW00034)

PTW00066 Ms Carlsa Carter The author states that the South Australian Government ignores the serious environmental condition of the Coorong and Lower Lakes and withholds minimum environmental flows The author states that there is a lack of thorough information about EPBC-listed species and species of the freshwater ecosystem and states that the loss of reed beds and habitat during the period of weir construction is trivialised Attention is drawn to a bird survey by Dr Kingsford of Newcastle University (2009) which shows greatly reduced numbers of water and wading birds over a short period

PTW00067 Ms Julie Pettett CEO Conservation Council of South Australia

The CCSA opposes the construction of a weir near Pomanda Island while accepting that the provision of drinking water is critical CCSA states that the impact of the weir will have unacceptable impacts on several matters of NES and the idea that the weir will be temporary is strongly contested CCSA argues that the EIS is seriously deficient and that the EIS for the proposed temporary weir should be reshyconsidered in conjunction with a referral EIS and public consultation about the introduction of seawater into the Coorong and Lower Lakes The CCSA is concerned about the impacts of a weir on Southern bell frogs Murray cod Murray hardyhead and Yarra pygmy perch and may be able to provide a supplement to the submission about these concerns at a later date CCSA states that the construction of a weir will destroy and degrade more than a hectare of Ramsar wetlands flora

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Submission no

Submission from Submission Summary

and reed beds and have consequent impacts on listed threatened species and migratory fauna Construction of a weir is likely to contaminate the Lake and impact on Ramsar wetlands threatened species ecological communities and migratory species Triggers for removal are discussed CCSA states that the weir will exacerbate acidification of the Lower Lakes and thus the weir will need to be permanent In addition CCSA states the Hume and the Dartmouth storages have not been at normal operating levels for ten years and achieving the prescribed salinity level is unrealistic These factors suggest a permanent weir CCSA believes more consideration needs to be given to the Federal government purchasing water and structural adjustments under the Water for the Future Program Stormwater harvesting aquifer storage and recharge and wastewater re-use would be less environmentally harmful options than a weir

PTW00068 Ms Paula Horbelt Secretary Goolwa District Ratepayers amp Residents Association Inc

This submission urges the State Government to consider water alternatives as Salisbury Council has done It is suggested that Cheltenham could be similarly used as a water capture site The Association encourages rainwater tank policy but questions the energy intensity costs of desalination The Association is concerned that a weir will increase salinity levels in Lake Alexandrina and that Ramsar sites of significance will not be protected The Association understands that water quality between Lock One and a weir at Pomanda island would inevitably deteriorate due to inadequate wind seiching In conclusion the submission states We support the purchase of water rather than weirs temporary or otherwise

PTW00069 Mr Keith Scobe The writer is a member of the Ramsar Taskforce His submission expresses a preference for securing water from upstream He refers to submergable floating booms as a method managing water (instead of a weir) He expresses uncertainty about the no flow period over the weir and expects weir construction costs will escalate He expresses hope that the MDBA will manage the Murray Darling Basin well in future

PTW00070 Ms Ruth Russell The writer is opposed to the construction of a weir and argues for a sustainable freshwater long-term management plan for the Murray-Darling Basin overall The author contributes to Adelaide University Frog Census work and has engaged with CLLMM issues in the region She urges a well researched long-term freshwater solution so that there is a postive outcome for future generations The writer urges - better use of a range of water alternatives - accessing water from the temporary water market through the Water for the Future Program - adoption of the precautionary principle - rejection of this EIS in favour of a more holistic and systematic EIS acknowledging complexity and interdependency The writer understands that the weir will be destructive of nationally listed species and suggests a fish passage should be included She fears algal blooms due to ineffective wind seiching as well as acid soils impacts on water qulaity The

Supplementary EIS for the temporary weir near Pomanda Island -178shy

Submission Summary

writer also fears that the weir will not be temporary PTW00071 Mr Ken Jury and

Mr Mike Young The authors are critical of the unrealistic timeline for consultation They propose a permanent weir which prevents loss of freshwater above and allows an esturine environment in the Lakes below This environment would support wader birds and improve tidal access to the north CoorongThe River Lower Lakes and Coorong must now be regarded as a human-altered environment and managed to suitThe authors argue that it is important not to allow the mobilisation of acid from soils into water as this will corrode the barrages They believe the only option is to inundate the Lakes with seawater and query the freshwater science presented A diversion pipeline is suggested from Morgan and questions are raised about loss of River water into aquifers

Submission no

Submission from

Supplementary EIS for the temporary weir near Pomanda Island -179shy

Government of South Australia

  • Table of Contents
  • Part Two - Community Consultation Report ndash Appendices
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