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Friday, May 16, 2008

Urgent need for Hydrologists (in DWE)

Apparently there is an urgent need for professional hydrologists in the NSW Dept of Water and Energy. However, the Department might not yet have realised that themselves. Either that or they need really good professional clerks who can actually read questions posed, and answer those questions.

Sunday, 4 May 2008 9:53 PM

To: ................................. (name removed to protect the innocent)
Subject: Urgent Information Requested re Kangaloon Borefield Project

Mr Mark Duffy

Director General
Department of Water and Energy

5th May, 2008

Dear Mr Duffy,

I am writing to you on behalf of the Save Water Alliance (SWA) regarding the proposed SCA borefield in the Upper Nepean River area and to specifically obtain information vital to our understanding of how the project will be operated.

The issues we raise relate to:

- The lack of publicly available information necessary for appraisal of the EA

- The credibility of the SCA’s proposals and

- Possible wider impacts of their proposed operations for this project

We currently understand that there is a draft Water Sharing Plan for the Greater Metropolitan Region - Groundwater Sources 2008 and that this is nearing gazettal. We have tried to obtain a copy of this draft for our analysis, but have not been able to do so as it has been described as not for public scrutiny at this stage. We understand that the ground waters of the Upper Nepean area will be managed according to this instrument when it is gazetted, but that until that time the ground waters of the area are managed according to the Water Act. We note that several local parishes have been embargoed for future groundwater use over the period from 2004 to 2007. The parishes where the proposed borefield is to be sited are part of that embargo.

We are aware of the claims by SCA in their Environmental Assessment of the Kangaloon Borefield, that an allocation for extraction of the groundwater from their proposed scheme has been reserved under the draft WSP and that this provides a safeguard for their scheme to proceed.

We would like to know whether an allocation has been reserved under the yet to be gazetted plan and how this has been possible. Further, we would like advice from the Department how such an allocation can be made when the current management arrangements have embargoed future use, and our interpretation of the Water Act is that any such allocation in an embargoed area has to be accompanied by allocation offsets from elsewhere in the parish or area. Specifically, we would like your view on how this meets the requirements of the National Water Initiative concerning over allocated systems.

Finally, we would also like your advice on whether the draft WSP has provision for hotspot management and how this might affect existing groundwater users in the management area affected by the proposed borefield, and whether the new plan will allow all embargoes to be lifted.

As this matter is related to the SCA EA and our submission concerning the proposal, we would like an urgent response if possible. We apologise for the short notice, but have only just been told that we cannot have access to the draft WSP and see this as our next avenue to obtain information that appears to have been shared with the SCA..

Yours Sincerely,

Bernard Eddy

Save Water Alliance

In view of the imminent closing date of Submissions with the Dept of Planning, a second letter was sent on 14 May 2008

From: Bernard Eddy []
Sent: Wednesday, 14 May
2008 4:39 PM
To: ...... (same innocent recipient)
Cc: ...... (the Dept of Planning contact person)
Subject: FW: Urgent Information Requested re Upper Kangaloon Borefield Project

Dear ....... (name removed to protect the innocent),

I refer to my letter to Mr Mark Duffy dated 5th May.

I have not; to date even received an acknowledgment of my request for urgent information regarding the SCA’s proposed borefield in the Upper Nepean. My great concern is the deadline for public comment on the SCA’s Environmental Assessment in relation to this project expires in two days.

It is not possible for the Save Water Alliance, to present a thorough, well informed comment without access to the Draft Water Sharing Plan together with your comments on the other crucial issues raised in my correspondence.

I suggest, it is grossly unfair for deadline to be placed on public participants in the Dept of Planning’s consultation process when we are dependent upon a separate government agency, the Dept of Water and Energy to provide key information that is not forthcoming. I urge you to please reply

Furthermore, I urge the Department of Planning to immediately grant an extension of time for the Save Water Alliance to submit detailed responses on water sharing issues in relation to Project MP 06-0331

Without such information being made available to all parties (including the DoP), it is not possible for informed discussion and analysis to take place.

Yours Sincerely,

Bernard Eddy

Save Water Alliance


Well what reply did we receive?

As a former Ministerial Correspondence Officer (clerk) I can say that this letter is a classic example of a letter which meets only one requirement - the need to present A response, A letter, ANY letter. From the point of view of the person drafting the reply, the pressing need is not to satisfy the original questioner, but to satisfy the "boss's" need to have a reply of some kind - any kind. This reply reeks of being one of those kinds of responses.

The point is simple.
The reply simply fails to answer any of the substantive questions in the original letters.
If this was an examination test - the "answer" to the "questions" would score no more than 3/10.

I wonder if it was perhaps jointly drafted for DWE by the helpful people at the Sydney Catchment Authority, perhaps in a "very urgent meeting" which certain key personnel from the Groundwater Projects Unit were engaged in, early in the morning of Thursday morning, 15 May 2008 - the same day on which the reply was sent to the Save Water Alliance.

Clearly the DWE urgently needs good hydrologists to fix the mess they are about to allow the SCA to create in the Southern Highlands.

The groundwater is about to be over-allocated - the central point raised in our letter.

It will be interesting to see if the Department of Planning can manage to stand above the issue and use scientific analysis of the facts, or whether they will allow themselves to be "snowed" by the bluster from DWE. Let us assume, at this point, that the DoP are as good as their original work indicates, when they drafted the Director-General's precisely worded "Requirements" under Part 3A of the EPA Act. If they are, then I am confident that they will see straight through this "advice" from the DWE.

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