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2022_02 Water issues summary document sent to council / councillors

Armidale Regional Council water supply – summary of issues relating to supply in Armidale and Guyra – February 2022
Water supply shortfall and Malpas to Guyra pipeline solution identified
2017 01/06 Guyra Argus quotes Adam Marshall as saying that “the construction of a new water pipeline and associated pumping infrastructure between Malpas Dam and Guyra was the best option to permanently prevent water shortages in Guyra and improve water quality and provide plenty of capacity for the community to continue to grow and attract further industry and horticultural developments”. And: “At my request, Armidale Regional Council has worked with the Department of Primary Industries to assess all the options and developed a business case presenting the pipeline as the preferred option”. State government contribution: $12,375,000.
2017 October – notes from business case prepared by Public Works Advisory for construction of a pipeline connecting Malpas Dam to Guyra Water Supply.
– Guyra population: 1947
– Water source: two small dams on the Gara River, 7 km north of the town.
– Historically, Guyra water supply system has been relatively secure. The township has not experienced any significant water supply issues even during the millennial drought.
– For the past 10 years, average annual water demand has been 423,000,000 litres, about 39% (165,000,000 litres) of which is supplied to the Blush Tomato farm on the eastern side of Guyra with 258,000,000 litres supplying the rest of Guyra . The demand however has steadily increased due to other commercial and industrial development, including a new glasshouse tomato farm off the New England Highway and further residential and tourism growth in the district. Council estimated that over the next 30 years, the future average annual water extraction is expected to grow to 525,000,000 litres and dry year extraction to 633,000,000.
– Estimated secure yield of the existing Guyra Dams is 277,000,000 per year thus laying bare the severe water security issues facing the township and surrounding district.
2018 19/06 Adam Marshall quoted in the Guyra Argus: “the township uses an average 423 megalitres (423,000,000 L) of water each year, with demand steadily increasing, which far exceeds the town’s current storage capacity of 277 megalitres (277,000,000 L)1. The pipeline will expand that capacity to 740 megalitres (740,000,000 L), exceeding anticipated growth over the next 30 years.”… “This will not only benefit every resident who uses town water but also help provide infinite capacity for Guyra’s expanding horticultural industry. Guyra will (be) ­completely drought proof and have complete water security”.. “The project is critical to unlocking Guyra’s growth”.
Expansion of Water demand in Guyra attributed to Costa group operations
2018 December – Costa opens its expanded operation on New England Highway, Guyra based on the water security to be provided by the Malpas Dam to Guyra pipeline which will expand capacity to more than 740,000,000 L.
See Todd Hopwood Review of Supply of water to Costa Group for changes in water storage and water restrictions and negotiations between Council and Costa Group regarding water allocations (in October 2018, council supplying 250,000,000 per year or 685,000 L per day, Costa requesting 300,000,000 L per year or 822,000 L per day) and water rates
2019 April – ARC agreed to provide Costa Group with reduced water rate up to June 2019 of $2.13 per 1,000 litres backdated to 01/07/18 contingent on the Elm Street tomato farm switching to untreated water from the Malpas pipeline. (Note that Costa had presumably been paying the 2019/20 Guyra residential and Commercial Stepped tariff of $2.70 per 1,000 litres for quantities greater than 250,000 L and in 2020 Coffs Harbour council was charging $3.05 per 1000 litres intensive horticulture treated bulk water)
Drought severely compromises water supply – Guyra Dams empty, water trucked to Guyra from Armidale, raising of Malpas Dam touted as solution
2019 05/09 Guyra Argus; Guyra Dams water supply below 30%, estimated to be empty by mid July. June, Adam Marshall announced State Government funding to truck water to Guyra. Aim was for pipeline to be operational by early August. There were operational problems preventing the pipeline from being fully operational in September and Guyra was still receiving 60 % of its water supply by tanker. Overall cost of trucking water: NSW government paid $820,000, ARC paid $250,000, total $1,070,000. There was concern that Malpas Dam could run out of water for Armidale supply. Adam Marshall quoted as believing that enlargement of Malpas dam could sustain future population growth in Guyra, Armidale and other communities like Uralla. (Note change prompted by unprecedented drought and water shortage likely to have been driven by climate change, from the assumption of existing water security being provided by Malpas Dam to the potential need to enlarge Malpas Dam, and additionally to supply Uralla).
Due to drought conditions in 2019 council consulted DPIE and was advised to revise the Integrated Water Cycle Management Strategy and Secure Yield model and to prepare or revise Drought Management Plans.
Residents deeply concerned by potential impacts of borewater extraction and lack of public consultation and transparency by Armidale Regional Council
2019 December – Guyra residents were deeply concerned when they found out that an apparent quantity of 300,000 litres per day was being trucked from a bore at Izzeard Park bore to the Costa tomato farm east facility at minimal cost and with no prior community consultation. Water supply continued for about 46 days from about 25/12/19 until 9/02/2020. Transport of 300,000 litres would require the equivalent of 10 tankers per day carrying a volume in the vicinity of 30,000 litres. A reply to a question on notice to council by Dorothy Robinson on 27/05/2020 indicated that a total of 11,000,000 litres had been extracted from Izzeard Park bore and 3,000,000 from Guyra Showground bore. A table of daily bore water extractions at Guyra reported to the ARC February 2021 meeting revealed that water extracted from the Izzeard Park and Showground bores was 15,171,000. If extraction from the bores occurred over 46 days, average water extraction per day would have been 329,804 litres – in excess of the initial report of 300,000 litres per day.
Guyra residents were particularly concerned regarding potential impacts on the hydrology of Mother of Ducks Lagoon, a rare upland wetland that has already been considerably adversely impacted by drainage works and a range various human landuse practices. Guyra residents have observed that water inflow into the Nature Reserve from rainfall run-off is supplemented by spring feed and stormwater runoff. Residents were concerned that these springs may be connected via cracks through the basalt and granite aquifers, and that deep bore water extraction may cause downward flow from the upper aquifer through cracks into the lower aquifer. See Dr Ian Reeve’s report on Guyra Geology and Groundwater and National Parks and Wildlife Management Plan for Mother of Ducks Lagoon Nature Reserve for further information on values and threats to the lagoon and environs.
Nearby residents with bores, already deeply concerned about drought and water shortage, noticed drawdown in their bores with an absence of available water in some bores that had previously never run dry. They considered that the drawdown was a consequence of water extraction from the council bore .
Community webinars on the Emergency Ground Water Supply Network were advertised on the Council website in Feb 2020. “Council will explain how the groundwater supply could contribute to a secure yield study being conducted as part of a required assessment and approval process for options to enhance dam storage levels.”
Council community information sessions held in the first quarter of 2020 provided the following information:
– In December 2019 in the context of unprecedented drought and water shortage in the area, and with Guyra Dam empty, council arranged for bore testing of multiple sites accessible to water infrastructure. Four sites in Guyra were considered to have production capacity. Although not informed of this at the time, the community were later able to confirm that Costa group funded development and installation of above ground infrastructure of a bore and water storage tank at Izzeard Park while council was to retain ownership. Due to the ongoing drought conditions and water supply issues for Guyra at that time, and an exemption under Section 39A of the Water Management Regulation 2018, the bore was able to be installed without a licence application or requirement for a Review of Environmental Factors despite its close proximity to the Mother of Ducks Lagoon. The amendment clause states that “The minister may only grant an exemption in time of drought, if satisfied the exemption is in the public interest.” A subsequent council letter stated that the section 39A exemptions applied to testing only.
– Council also assisted with negotiations that enabled Costa Group to extract water from privately owned bores – the quantity of water extracted from these bores has not been made available to the public.
In response to community concerns, Scot McDonald from ARC (12/03/20) stated that the drilling contractor had been asked to install a monitoring bore adjacent to the Izzeard Park Bore (depth of 30m) and other council bores to determine whether there was any impact of water extraction on the adjacent water table hence other bores. It does not appear that any information has been made available to the public regarding bore monitoring.
2020 September ARC administrator resolved that council negotiate to purchase all the infrastructure assets at the bore at Izzeard Park and commission an independent report review of supply of water to Costa Group by Armidale Regional Council (report completed by Todd Hopwood).
The Hopwood report concluded that the supply of water to Costa Group was in accordance with legislation and regulations but that there was a consistent theme of not making such decisions in an open and transparent manner and that record keeping was poor – a significant number of meetings were held with external companies / participants for which there were no agendas and a large number of emails between Costa and Council staff were either not stored in Councils record management system or not stored when they should have been. It recommended improved community engagement and record keeping.
Concern that groundwater, accessed for emergency purposes, is being factored in as sustainable yield
Council applied for a Water Access Licence (WAL) for the Izzeard Park bore and 3 others in the Guyra area. Initially the community was told the water would only be used for emergency purposes, perhaps once every 7 years.
A report on Guyra Geology and Groundwater by Dr Ian Reeve (2020, Casual Research Fellow for the Institute for Rural Futures at UNE) shows that much of the water in Guyra’s fractured rock aquifers is likely to be millions of years old, that connection through rock fractures is possible between shallow and deeper aquifers, that the aquifers are the source of flow for numerous springs, that the only source of replenishment of these aquifers is rainfall and that infiltration of water into the aquifers is very slow and likely to comprise less than 1% of rainfall across the landscape.
Based on evidence of the finite, relict nature of water in the aquifers, and their importance in feeding springs, agricultural water supply and water storages, community members were deeply concerned when later informed that the WAL application was for the inclusion of water extraction from the Izzeard Park bore as part of the ongoing water supply for Guyra. Evidence and personal experience has led them to believe that ongoing extraction of water will deplete the Guyra aquifers, leaving residents without potential for backup supply in the event of future severe drought.
On 11/04/2020, ARC officer Scot McDonald wrote in reply to a resident that: “The bore network is designed to supply the Guyra Water Treatment Plant and subsequently all its customers” and “If underground water is required in the future, residents and businesses will not be constrained by a delay in months waiting for this infrastructure to be constructed”.
15/05/2020: Dorothy Robinson wrote that council had paid the licence fee and expected the licence to be issued within the next fortnight. In February 2022, the community has still not been informed of the outcome of the WAL application, which was to be assessed by NSW Water / Natural Resources Access Regulator (ARAR).
Community concerns regarding lack of transparency validated
Following on from community concerns raised, it was announced in the Guyra Gazette of 06/04/21 that ARC had been issued two penalty notices by the Natural Resources Access Regulator (NRAR) for unlawfully taking water between December 2019 and February 2020. Fines totalling $3,000 were issued to council on 10/03/21. The regulator alleged that council allowed a business in Guyra to take water from two of its test bores (a total of 13 megalitres from Izzeard Park and Guyra Showground) without the required Water Access Licence.

Community concerns regarding the need to conserve water held in Guyra’s aquifers
Due to reasons mentioned above, many residents in the region are of the strong belief that water in Guyra’s aquifers should be reserved for emergency use only. It is noted that Water NSW is responsible under the Water Management Act 2000 for surface and groundwater management including ensuring water security for NSW. However, Armidale Regional Council is in a position to decide to reserve use of council owned bores for emergency use only and to be an advocate for its community with regard to concern regarding the sustainability of cumulative extraction.
Even though the Izzeard Park bore is stated to be approximately 100 m deep in order to avoid depletion of shallower (30m) aquifer, Dr Reeve’s report shows that connection through rock fractures is possible between shallow and deeper aquifers. Bore casing is designed to prevent exchange between different level aquifers at the site of the bore infrastructure, but will not prevent movement of water through aquifers that are connected at separate locations.
Integrated Water Cycle Management Strategy (IWCM) and Secure Yield Study
In April 2020 Council acknowledged that a Water Security Policy cannot progress until the IWCM and Secure Yield study have been completed and that these will form the basis of any planned infrastructure works to achieve increased water storage and security. The IWCM has not been made available to the public at this stage.
In May 26 2021 Malpas Dam Upgrade options assessment report, NSW Urban Water Services Armidale Yield Study (Progress report 4) and Malpas Dam Upgrade Assessment by Council Staff was presented at the Council Meeting. The studies are based on average demand per year in the Armidale/Guyra areas increasing from 2,734 ML/yr in 2016 to 4,017 in 2048. (HW note:There appears to be no assessment to date of the potential to improve efficiency of or economise in water use or of concerns that climate change impacts and water resource availability could be seen as limits to growth potential or of potential, if the dam height is increased, for changed hydrology, downstream impacts or adverse environmental impacts).
– Based on historic climate, ongoing secure yield of existing dams was assessed at 3,428 ML/ year, increasing to 4,308 ML/year if Malpas dam is raised by 3 M or 5,279 ML/year if the dam is raised by 6.5 M. . Taking climate change projections of 1C temperature increase into account, secure yield from existing dams was assessed as 2,333 ML/year, increasing to 2958 ML/year if Malpas dam is raised by 3 M or 3,595 ML/year if the dam is raised by 6.5 M.
– Council resolved to adopt the recommendation to proceed with the option to raise the Malpas Dam spillway by 6.49 metres (plus associated reports) and increase in storage from 12.2 GL to 27.6 GL, noting the preliminary projected project cost of $25,723,979 and that council should commence the preparation of a business case for this project including clarity on funding source, impact on Councils financial sustainability, impact on operating costs and affordability (including willingness to pay) for residents and businesses.
– Council also noted that upgrading the storage of Malpas Dam to 27.6 GL does not meet the projected town water dry year demand for Armidale and Guyra in 30 years in the 1C temperature increase / climate warming scenario and that meeting a secure yield for the LGA would require further options assessment for water supply.
– Quotations to be called for in June for development of an Armidale Regional Council Catchment Water Quality Strategic Plan, to encompass a 10 year plan to elevate water quality in Councils storages and improve catchment health to enable higher water quality entering and being stored in Councils storages.
Catchment Water Quality Strategic Plan
In 2022 Aug 26 local company 2Rog Consulting was awarded the tender to develop the Armidale Regional Council Catchment Water Quality Strategic Plan which would outline the goals, high priority actions, supporting initiatives and measurement mechanisms to assess and improve water quality outcomes in the greater catchment areas of Council’s storage dams. The report will be presented to council in the first quarter of 2022.
Increased water demand
Based on available figures, Costa Group water use has increased by 283% from approximately 165,000,000 litres per year (about 39% of Guyra’s average annual water demand of 423,000,000 litres) in the decade to 2017 to a usage of 468,000,000 per year in 2020 (estimate based on Armidale Regional Council agreement to supply 9,000,000 litres per week of town water to the Costa Group from 10/02/2020). Promotional material by Costa in 2021 specifies a smaller usage across the Elm Street and New England sites of 356,000,000 litres per year (excluding 166,000,000 of recycled drain water) in 2020. This quantity would have comprised somewhere between 84% and 110% of Guyra’s total average annual water usage for the decade prior to 2017.
These figures pre-date the $80 m expansion of Costa’s glasshouse operation, opened on 03/12/2021, with two new 5 ha glasshouses and a 2.5 ha nursery, described as being fully water self sufficient. It is to be hoped that this is correct, but the increase in water usage specified above creates concern that additional water will nevertheless be required, particularly during dry years when rainfall will be insufficient for roofwater and groundwater collection systems.
Details and approval of Costa group’s application to construct a 50,000,000 litre surface water storage dam and a 40,000,000 litre Bore Water Storage Dam can be found in item 11.4 of the 28/10/2020 ARC Ordinary Council Meeting minutes and attachments. Documents included as part of the application indicate that the original bore allocation was 88,000,000 L per annum but that groundwater extraction had decreased since the original bore construction due to “the drought conditions, the falling water table and the need to utilise the bore on a daily basis”. It was estimated that the current achievable amount per annum without exhausting the bore and maintaining the approved pumping plan was 31,500,000 per annum. The tomato farm proposed to maintain a bore pumping rate of 31,500,000 litres per annum and required 340,000,000 litres annually to operate (including a 20% contingency – the baseline figure is 264,000,000 litres) and that the minimum annual rainfall required to achieve 314,000,000 litres of water within the existing roofwater and groundwater capture systems is 640mm. It is not clear whether these statistics apply only to the New England Highway greenhouses and nursery or to Costa Group’s total operation. Note that Guyra’s annual rainfall in 2019 was 302 mm, well below what is needed for the Costa greenhouses to be self sufficient in water.
The plethora of water statistics mean that it is difficult for the community to clearly understand the cumulative implications of water usage. Council is in a position to assist the community in this regard in a spirit of genuinely seeking to understand and address community concerns. Concerns expressed by long term community members such as the letters to be found on pages 749 and 751 and 761 of attachment 8 to the Ordinary Council Minutes of 28/10/20 deserve proper assessment and should not just be put aside. Decisions made by the NSW water regulator based on models and statistics need to be ground truthed to fully assess broader implications and conflicting needs of water users. Costa Group’s description of drawdown in their own bore validates concerns of other bore users and neighbours relying on spring fed water courses.
Technical improvements towards a high level of water efficiency are commendable but do not always prevent cumulative water resource depletion, as can be seen from devastating impacts on the Dead Sea arising from diversion of the Jordan River in Israel for the purpose of water efficient irrigation (https://www.smithsonianmag.com/science-nature/the-dying-of-the-dead-sea-70079351/).
Potential future water shortage and need to be prepared for future climate driven composite events
In February 2022 there continues to be deep community concern that despite innovative water efficient design of new greenhouses, the expansion of the Costa group intensive horticulture operations has resulted in a steep increase in water consumption in four years since 2017 and that the issue of potential future water shortage was not resolved in 2019 by the construction of the Malpas Dam to Guyra pipeline.
Even if the height of Malpas Dam is raised as proposed, it is possible that an intervening severe drought may prevent adequate water flow to fill the increased capacity of the dam and meet water needs in case of a future severe drought. Also, damming of upstream water will compromise availability of water downstream to a greater or lesser degree – it is important that water management options ensure adequate downstream supply for biodiversity needs and human use. This is also the case if alternatives to Malpas Dam storage are being considered – we should not rob from the water needs of other regions in order to grow our own regions. During the bushfires of 2019, just as firefighters were struggling to find adquate water in Armidale region for firefighting, firefighters downstream in the Macleay catchment were also struggling to find adequate water in the Macleay River.
Existing levels of water use have been shown to compromise the ability of Armidale regional communities to adapt to existing climate driven crises such as severe drought, water shortage and bushfire. Unless the region as a whole pays particular attention, there is a risk that water demand will continue its steep upward trajectory, particularly in the context of expanding intensive horticulture. Investigation of truly water efficient options, requiring zero increase in water consumption, is needed along with the need assess and specify limits to growth.

Information compiled from sources gathered by a range of community members. These included newspaper items, council minutes and reports
Helen Webb, Convenor, Sustainable Living Armidale February 2022

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