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Corangamite Salinity Action PlanCorangamite Salinity Action PlanCorangamite Salinity Action PlanCorangamite Salinity Action Plan

Response to comments on the Regional Draft - 2003

Background report No 7

November 2005

Mike Stephens & Associates Pty Ltd

Corangamite Salinity Action Plan. Background Report No. 7. Response to comments on the Regional Draft – 2003.

Mike Stephens & Associates Pty Ltd 1

Authored by:

Peter Dahlhaus1 & Cam Nicholson

2

1Dahlhaus Environmental Geology Pty Ltd, Buninyong 2Nicon Rural Services Pty Ltd, Queenscliff

Corangamite Catchment Management Authority, 2005 Published by the Corangamite Catchment Management Authority, 2005 64 Dennis Street Colac Victoria 3250 Website: http://www.ccma.vic.gov.au Citation: Dahlhaus P.G & Nicholson C. 2005. Corangamite Salinity Action Plan: Response to comments on the Regional Draft – 2003. Background Report 7, Corangamite Salinity Action Plan, Corangamite Catchment Management Authority, Colac. The National Library of Australia Cataloguing-in-Publication entry:

ISBN ISSN This document has been prepared for use by the Corangamite Catchment Management Authority by Mike Stephens & Associates Pty Ltd and has been compiled by using the consultants’ expert knowledge, due care and professional expertise. The Corangamite Catchment Management Authority, Mike Stephens & Associates Pty Ltd and other contributors do not guarantee that the publication is without flaw of any kind or is wholly appropriate for every purpose for which it may be used and therefore disclaim all liability for any error, loss, damage or other consequence whatsoever which may arise from the use of or reliance on the information contained in this publication.

Corangamite Salinity Action Plan (2005 – 2008)

Principal consultant: Mike Stephens & Associates Pty Ltd Project team: Mike Stephens, Mike Stephens & Associates Pty Ltd Cam Nicholson, Nicon Rural Services Pty Ltd Peter Dahlhaus, Dahlhaus Environmental Geology Pty Ltd Graeme Anderson, Department of Primary Industries Roger Standen, Karlie Tucker & Clare Kelliher, Rendell McGuckian Pty Ltd Project management Tim Corlett, Corangamite CMA (2003) Felicia Choo, Corangamite CMA (2005)

Introduction

This report is the seventh in a series of background reports on the development of the Corangamite Salinity Action Plan (SAP) for the Corangamite Catchment Management Authority (CCMA). The second generation plan is being developed in line with Victoria’s Salinity Management Framework - Restoring our Catchments, which sets out broad and challenging targets for management of salinity across the state. The SAP also relates to the Corangamite Regional Catchment Strategy 2003 – 2008 as one of its sub-strategies and action plans which provide the investment framework for integrated catchment management.

A Regional Draft of the SAP was distributed for public comment in July 2003. Comments were received from the Department of Sustainability and Environment (DSE) and the Department of Primary Industries (DPI), Barwon Water, Golden Plains Shire, and Moorabool Shire. Of these, the vast majority were from DSE and DPI (163 comments) which were collated and sent to the CCMA in March 2004. The comments were then reviewed by a panel convened on April 1st 2004, however the panel’s responses were apparently not lodged with DSE at that time. With changes to project management staff and the implementation committee responsible for salinity management, the original responses are no longer available.

In August 2005 the original consulting team was engaged to finalise the SAP, and their responses to the comments are listed in this report. In reviewing the comments, four broad categories were apparent, viz;

1. Relevant comments that resulted from ambiguous wording, inadequate explanation, omissions, or where the completion of subsequent work has since improved the available information (123 of the 163 comments, or about 75%).

2. Comments that indicated that the respondent had not read the entire document and/or background reports (35 comments, or around 20%).

3. Comments that were ambiguous, vague or not understood (3 comments).

4. Comments that are disputed, rejected, or on which guidance was sought. These comments related to the priority area selection process (GSHARP), the community consultation process, the view of primary salinity as an asset, the importance of urban water supply, the economic analysis and the technical rigour.

To clarify the required level of responses to the comments a meeting was held with Mr Shayne Annett, Senior Policy Analyst, Landscape Change, DSE, at the CCMA office in Geelong on 15th September 2005. At that meeting a number of comments were subsequently clarified.

The response to the comments is tabulated on the following pages. The table includes reference to the report, section and page of the Regional Draft or Background Report, and the report, section and page of the final SAP or Background Report in which the comment has been addressed.



Review comments on Corangamite SAP Regional Draft

(original file: Corangamite collated comts 30304 V2.doc) Collated by Paul Simpson 3rd March 2004

DSE Reg = DSE Regional CAS/DPI = Regional Catchment and Ag. Services/ Dept. Primary Industries SI = Sustainable Irrigation (Vic Prde Melb) NV = Native Vegetation (Vic Prde Melb) DPI – Ag = DPI Agriculture Division, Industry Policy Grp.(Nicholson St) LCT = Landscape Change Team (Vic Prde Melb) CS = Catchment Strategies (Vic Prde Melb) BNS = Biodiversity and Natural Resources .(Nicholson St)

Major comments

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Comment & suggested action or amendment

Required action (by CCMA)

Please respond – provide explanation

or justification

Please address - make the required

changes, additions, editing Or

provide suitable justification why the

change is not made or warranted

Response (from CCMA)

Document, page

number & section

in which the

comment has been

addressed

1 General 82

There appears to be good underlying use of research data informing policy but it is somewhat difficult to assess the contributions of the background papers to the key document. DPI -Ag

Include an overview of each of the background papers as an Appendix to the main Report. Key issues arising from the background papers could be highlighted in the text.

An Appendix can be added to summarise the full range of background documents. The majority of these are currently listed in the foreword of the Regional Draft.

2 General On-ground works 8

On-ground works that have been undertaken in the past, don’t appear to have been accounted for in the Plan

Need to document if/how the assumptions in the Plan account for the previous salinity work in the region. . CAS/DPI

Please address – make the required changes

The previous on-ground works were accounted for in the development of the salinity actions. How this was done is included in Background Reports 3, 4 & 5.

3 General Farm Forestry 15

The SAP should note the existence of farm forestry programs such as the West RFA Sawlog Farming Project and the Plantations for Greenhouse Project which are currently offering incentives for commercial tree plantations in western Victoria with further incentives given to those with potential Landcare benefits, including salinity management.

Extension schemes such as these being expanded and targeted more specifically in areas that would benefit from broad scale tree planting would seem to be a logical recommendation. Yet these schemes are barely mentioned.

Making these schemes more flexible to allow areas less than 10 ha to be eligible for grants would open the scheme up to many more landholders and could go a long way to getting target tree plantings achieved. . CAS/DPI


Noted. Although this comment can be made in the SAP, it is up to the implementation group to attempt to alter flexibility of other complementary programs

4 General Assumptions 24 Assumptions need to be clearly stated in the plan. While a few are documented in the text an Appendix should be provided which summarises all the assumptions in the Plan. . CAS/DPI


The assumptions for each stage of the process are detailed in the Background Reports. These can be included as an Appendix in the final report if required.



5 General Referencing 25

A significant number of references used in the text are not listed in the appendix.

Ensure all referenced texts are included in the Appendix.

Background reports named in the plan have subsequently been renamed as Technical Reports and numbered.

Ensure all references to Background Reports are updated. . CAS/DPI


The bibliographic reference for all those cited in the text will be listed at the end of the final report.

The final report will ensure consistency in the naming and numbering of the Background Reports.

6 General Assessment against Guidelines

41

A number of sections required by the Guidelines for action plans do not appear to have been incorporated. In some instances the information is distributed throughout the text, or is contained within the background papers. It is important that key elements of the action plan are clearly identifiable and are at least summarised in the main document. Apparent gaps include:

Community consultation in development of the plan. Consultation with asset managers is described however other consultation processes have not been well described

Process of development

Implementation structures

Links between plans ie other regional strategies

Assumptions: should be provided as an appendix for ease of reference.

Adaptive management / continuous improvement.

Reporting

. CAS/DPI


Noted. The structure of the Action Plan will be amended to comply with that required by DSE Catchment Strategy.

7 General Local Govt Planning scheme

43

A local provision for salinity would be a much quicker and simpler way of incorporating salinity into shire planning schemes, which should be considered as an alternative to implementing salinity overlays.

Eg a council could have a Salinity Policy, which sets out the specific issues created by salinity in the municipality and how the issues could be managed through the planning process, eg the salinity-management matters to be taken into account by the council when considering a planning permit application. . CAS/DPI


A local provision would be useful for strategic planning. However an SMO based on risk management principles is considered more effective for asset protection and takes into account the hydrological impacts of each proposed development and works.

8 General Urbanisation 44

The Moorabool river supplies drinking water to Ballarat and Geelong. Urban infrastructure and water users contribute to the rise of salinity. The urban contribution to remedy water issues must not be ignored. Salinity is not just a rural issue. . CAS/DPI


To our knowledge, it is unproven that urban infrastructure and water users contribute to the rising trend in river salinity. Until the salinity process associated with urban development is clearly proven, actions cannot be taken to prevent, stabilise or reverse the trend. Note that the urban water use was accounted for in the benefit-cost analysis.

9 General 58

Useful references to aid in finalising the CSAP include:

Draft Guidelines for Review and Renewal of Action Plans;

National NRM Framework for Standards and Targets;

National NRM Framework for Monitoring and Evaluation; and

Australian and New Zealand Guidelines for Marine and Fresh Water Quality (2000). SI

Noted

10 General 59 The SCAP is well written although the document would benefit from a different style of writing (less consultant report, more community document). SI

Noted



11 General Vision – 84 There is no vision of a future state for salinity in the region. Is that important? If no, move on; If yes, then make a statement. DPI -Ag

Attempt to capture a vision statement and relate this back to the RCS framework.

Background Report 1 and the first section of the SAP provide statements on the future of salinity in the CCMA region. The Aspirational Target (section 2.6.1) provides the vision. The final SAP will attempt to clarify this. The final SAP will relate to the RCS framework.

12 General section 1.2 to 1.7 90

Found the discussion in section 1.2 to 1.7 a useful backdrop. Particularly the distinction between human induced and naturally occurring and in fact as part of natural resource management practices in some of the areas of Corangamite “salinity or salting” should be encouraged. CS

Please acknowledge Noted. This can be highlighted in the final report.

13 General 91 A major comment is that there is very little discussion of how they engaged their local community — other than the “experts”. From this perspective it is not a community owned document.

Please respond

The community consultation was a major step in the process (section 2, Figure 2). Workshops with asset managers, CCMA & NRE are detailed in Background Report 4. The draft SAP was endorsed by the implementation committees and Board of the CCMA.

14 General 92

This plan is incomplete. The guidelines for SMPs require that the plans make clear proposals for actions to be taken to manage salinity in a region. This plan does not describe the actions that need to be taken clearly enough. Appendix 3 in the document appears to suggest that the work has been done but it is not transparent what exactly is being proposed within each of the priority areas. LCT

Please address

Table 3 in Section 2.4.6 of the SAP list the management action targets for each priority region. They are justified in Background Reports 3, 4, 5 & 6. Appendix 5 specifies the treatment options and adoption rates for each priority area. The final SAP will make this clearer.

15 General - Major

53

The Corangamite Salinity Action Plan (CSAP) reads like a consultant’s report to the CMA. It does not provide a sense of being owned or endorsed by the CMA or the regional community. The CSAP does not provide a sense for how the CMA has been engaged in the process of development, and this is of major concern because the CMA should have the pivotal role in preparation. This is particularly so for the second part of the document (sections 2.6.4 and onwards), which deals with the roles and responsibilities of the CMA and how these could be enhanced or strengthened. These are the kind of issues that should be resolved with the CMA and included as management action targets if there are specific actions arising, ie it should be resolved prior to the release of the document for review/consultation. It is strongly recommended that the CMA has the primary role of preparation of the next draft, building on from the good foundations that the draft CSAP and background documents provide. SI

Please address

The comment on style is previously noted (item 59). The implementation of the SAP was discussed in the draft SAP to foster community debate, and comment as appropriate.

Both these issues will be resolved in the final version.

16 General - Major

54

The technical rigour of the CSAP is hard to assess. The technical rigour may be demonstrated in the background reports, however there appear to be “leaps of faith” between discussing the general causes of salinity in the catchment, to the management actions. This may be due to the way that the report is structured. SI

Please address

The technical rigour is demonstrated in the Background Reports, as appropriate. The comment on report structure is noted and will be addressed in the final version.

17 General - Major

55

The CSAP directly mentions that integration of salinity management activities with other natural resource management activities is imperative, however it does not provide a very good emphasis in the document on related issues and how salinity management activities may impact on these, for example, biodiversity, river health. The document only pays “lip service” to these and very much comes across as a single issue focussed document, ie not part of an integrated NRM program. If integration is truly imperative to the region then this should be clearly reflected in the implementation program. SI

Please address in re- editing of document

The links to other sub-strategies is noted in Background Report 1 and accounted for in the benefit-cost analysis (Background Report 5). At the time the draft SAP was developed, the CCMA RCS was not finalised. However, the final SAP will clearly link the SAP to the RCS.



18 General - Major

56

Threats to assets have been addressed poorly. The discussion is very general and scattered throughout the document and does not lead to an understanding of why particular management actions have been determined to be necessary (eg rabbit control options). A section discussing the threats to the assets is required. A section detailing why the assets are considered to be assets would also be really valuable. There need to be strong links between the ASSETS, the THREATS to these assets, and the MANAGEMENT OPTIONS. SI

Please address and provide additional sections as required.

The threat of salinity to assets was determined using an objective process, viz: the GSHARP model (PIRVic report). The actual threat was verified by ground-observations in each priority area (Background Report 2). The threat to water quality was assessed using GAM modelling (Background Report 3). The effectiveness of the management options were modelled (Background Report 3) and the management actions and targets were developed in consultation the asset managers (Background Report 4). However, the link between assets and threats will be made clear in the final SAP.

19 General - Major

57

Other areas that appear to be poorly addressed in the document include ASSUMPTIONS. Also what are the cost share principles for the region and how have the cost shares between private and public investment been determined? These should be based on those documented in Victoria’s Salinity Management Framework. Please make sure that this information is included in the final document – it is very important. SI

Please add additional information on Assumptions and cost share.

The cost-sharing arrangements and assumptions are contained in Background Report 5. The final SAP will be revised to clarify this.

20 General - Major

78

The plan does not provide specific details of implementation, including the roles and actions to be undertaken. The discussion on the implementation structure is useful, however it would be more beneficial if there were some more details. More detail on the treatment options and where and when they will be applied would also be beneficial, such as when to use indigenous or forestry type revegetation. NV

Noted

21 Overall 81 A readable treatment but needs a broad overview of what is included. DPI -Ag

Include an Executive Summary that captures the essential components of the plan and the key messages, targets, actions and expected outcomes.

Noted.

22 3 Foreword 60

The Foreword has prepared and signed off by the consultant, which is not really appropriate for a CMA plan. It would be better for a representative from the CMA Board or the Implementation Committee (SALMIC) to prepare the foreword and provide their support and endorsement of the CSAP. Some of the information in the foreword would be good to keep in the document (eg the list of background reports), however this could be included in the introduction. SI

Please consider having the foreword prepared by a representative of the CMA (either the Board or the relevant IC)

Noted. The draft SAP was prepared for public comment by the consultant. The draft has a completely different context to the final CCMA sub-strategy.

23 3 Foreword 61

The last paragraph of the Foreword highlights the consultant’s concern at releasing this draft as a public exposure draft. I would concur with the consultant. It is my understanding that this document has been sent out for public comment (is this correct Paul?) – these kinds of comments are completely inappropriate to be left in a document being sent out for public exposure. SI

Thorough reviews of documents need to be undertaken prior to public exposure of drafts.

Noted.



24 7 1.2 26

The discussion in the first paragraph is incomplete as a summary of existing status of salinity, however, this is a reflection of the discussion in Technical Report 2 which also treats the subject lightly.

Information is available on the severity of known sites and a comment on this would be appropriate here.

A review of salinity discharge mapping was completed in 2001 and the output of this work should be discussed as a minimum in the Technical Report.

The long term discharge monitoring program work should be noted.

The comment about the level of completion of salinity mapping needs to be qualified by consideration of the methodology used within the program.

While identified as a gap the Plan does not identify any actions to remedy the situation. See previous comment. . CAS/DPI


Background Report 1 has an extensive summary of the status of the existing salinity. This can be reviewed and reflected more completely in the final SAP.

The final report on the review of salinity discharge mapping was not completed at the time of the draft SAP. It was referred to in the review of the previous SMP ‘Restoring the Balance’ (Nicon Rural Services P/L).

A report on the long-term salinity discharge program was not available until after the draft SAP was finalised.

The establishment of catchment health sites to monitor the trend in area of land salinised in the target areas is recommended, costed and included in the SAP.

25 7 1.2 46

The Plan states that…”The salinity mapping is regarded as incomplete and many hectares of salt affected land remain unmapped.

If the Salinity Plan does not include revise salinity mapping as an action, then it should. DSE Reg


Salinity mapping is a monitoring action in most of the target areas. Improving the data sets for GSHARP is also a research action, although of medium to low priority (Background Report 6). The area of land salinised is a RCT in those target areas where agricultural land is an asset, therefore a catchment health site has been costed into the plan.

26 8

1.3

Primary Salinity

TR 2

9

‘A mind shift is needed if we are to manage these areas for their inherent salinity values rather than attempt to minimise salting within them’.

This statement needs further qualification. As discussed in the text there are numerous areas of Primary salting in the Corangamite region – many of which are on public land and have been actively managed and protected for their intrinsic salinity values for a long period of time. This is evidenced by their listing as RAMSAR etc type wetlands. The statement may be true for primary sites on private land.

While Primary salinity is a natural part of the landscape and there are significant hyper-saline and brackish wetland systems in Corangamite, these wetland associations occur at particular salinity ranges. An increase in salinity in these areas is not necessarily a good thing, as it will alter the vegetation, which in turn impacts on the wildlife values. The other associated problem (example Lake Corangamite) is the altered water regime, which affects the salinity concentration.

Greater consideration of Primary salting required. CAS/DPI


While it is true that most of the primary saline sites are on public land they are managed for their biodiversity value rather than to maintain their water quality (i.e. salinity concentrations). Lake Corangamite is an excellent example of a poorly managed RAMSAR wetland (and therefore, the highest priority in the SAP).

RCTs which will maintain the appropriate salinity ranges to support primary salinity ecosystems are set for each priority area where the primary salinity is identified as an asset under threat. Appropriate management actions have been identified and costed into the plan.

27 8 1.3 27

There is no explanation or definition of secondary salinity given in the text.

Include the definition of secondary salinity.

.. the depth of groundwater … have been relatively unchanged for 200 years.

Reference required. CAS/DPI


Noted.

Background Report 1 is cited for a full explanation of the salinity processes in the CCMA region. This will be revised for the final SAP.



28 8 Section 1.3 93

A sub-section of 1.3 is titled ‘Secondary salting- not as simple as recharge and discharge.’

This section title is misleading. It appears to suggest that salinisation in Corangamite is caused by some process other than recharge and discharge of groundwater. Reading the text does not explain this, but seems to suggest that it is a complex process, but still based on a recharge and discharge model. The suggestion appears to be that the situation is more complex than native vegetation removal causing secondary salting. If salting in this region is not based on recharge and discharge dynamics then using GFS as the basis of the plan becomes problematic. LCT

Suggest that the title of this section is revised. Perhaps something like:

Secondary salting- not a simple case of recharge- discharge.

Revision of the title is appropriate.

The response of the GFS and the trend in salinity are the most important factors in determining if recharge management will result in discharge reduction.

29 8 1.3 Secondary silting 107

This section poses a couple of issues WRT how salinity may have developed, and refers to associated documents. However there is no position taken as to how the Corangamite CMA sees these issue and how this will influence the plan, or actions to manage salinity. It is good to raise the issues, but it is not very useful if there is no conclusion drawn from such comments. If they have not influenced the thinking or action regarding salinity, then what use have they provided? LCT

Please indicate how these issues have/will affect salinity management.

Noted. This will be expanded but the SAP clearly recommends differential actions for areas of primary and secondary salting appropriate to the origin of the salting.



30 8.

1.3 & 2.2 & Table 3

47

States that … “Secondary salting – not as simple as recharge and discharge”

Then states … “Land use changes, where excessive water may have caused soil water logging and shallow, temporal water flows in the near surface are more influential than simple vegetation removal.” This seems to have a contradictory element in that presumably the initial and major land use change was clearing and change to native vegetation. Most readers / users of this Plan would reason that if native vegetation was removed ( eg trees and / or native grasses removed ) then there might be an increase in soil water logging and near surface water flows.

However the Plan continues with the statement … “This position contrasts with the widely held assumption that extensive clearing of native vegetation and its replacement with exotic species that use less water has mobilising the salts stored in the regolith and resulted in secondary salting.”

Then on p17, the references to biological treatments include:

• “High density tree planting on recharge areas”

• “Tree planting interception belts on recharge areas”

• “Shallow surface drains to intercept lateral flow of perched groundwater ….. Preventing intrusion into discharge areas lower in the landscape.”

• “Tree planting adjoining or near saline discharge areas for watertable reduction / draw down.”

• “Protection and management of discharge areas to allow natural vegetation recovery.”

• “Protection and management of discharge areas with establishment of additional vegetation”

• “Surface water management on discharge areas in conjunction with establishment of additional vegetative cover.”

These treatments clearly have a strong focus on managing recharge and discharge, and therefore there seems to be some degree of inconsistency or contradiction between the focus of these treatments and the earlier statement … “secondary salting – not as simple as recharge and discharge.”

Adding to this perception of inconsistency or contradiction is some of the actions identified in Table 3 ( p25 – 27) which include actions such as :

• “Commence saline discharge area revegetation program”

• “Commence tree planting work on areas immediately above discharge sites.”

• “Commence methods of making commercial forestry more attractive on recharge areas.”

• ”Commence discharge management program … “

• “Conduct PAR trials on suggested recharge control treatments.”

DSE Reg


Provide an explanation / justification for these statements rather than simply relying on referring to the other cited reports.

Explain what the land use changes were, and whether there is or is not any cause – effect relationship between (1) soil water logging and near surface water flows and (2) removal of native vegetation. Explain or remove the inconsistency between identifying a range of biological treatments, which clearly have a very strong focus on managing recharge and discharge, while also stating it is “not as simple as recharge and discharge”.

The relationship between removal of native vegetation and the onset of salinity is not as clear in the high-rainfall zones of south west Victoria as it is in the low rainfall zones of Western Australia and the Murray-Darling Basin. Background Report 1 will be revised to include citations to all the scientific published literature to support this.

Land-use change other than the clearing of native vegetation, such as the drainage of wetlands and waterlogged areas, diversion of rivers, extraction of surface water and groundwater, regolith disturbances caused by mining and agriculture may have had a greater effect on the near-surface hydrology than the biological change. This can be made clearer in the final SAP.

The treatment options are directly related to:

the response of the GFS

the ability to prevent, stabilise or reverse the trend in increasing salinity

the protection of the asset at risk

The SAP has designed effective treatments based on the conceptual models of the salinity process in each target area and the modelling of the management options.

Biological control of recharge is recommended in 3 of the 12 target areas where the right conditions prevail. For the others, discharge management using saline agriculture or wetland management is recommended as appropriate.

31 9 Urbanisation 18

“changes to the hydrologic balance created by urban development is suggested to have a greater impact on salinity than that induced by agricultural land management” If urban development has a greater impact on Salinity than the management of agricultural land why isn’t it mentioned in any of the change scenarios. CAS/DPI


The impact of the urban development, particularly in water consumption, river diversion and drainage, was being studied in separate large consultancies and had not been finalised at the time of the draft SAP. It will be addressed (or clarified) in the final SAP.



32 9 1.4 48

It is difficult to understand and accept the statement … “The changes to the hydrologic balance created by urban development is suggested to have a greater impact on salinity than that induced by agricultural land management."

In a Corangamite whole of region context it is difficult to accept that the relatively small area of urban development (and its associated water use) compared to the very large area of land cleared for agriculture would have a greater impact on salinity across the region than agricultural land management.

Then later in the Plan (p11) in the context of “six major forces that are likely to affect the Corangamite region.” One of these major forces is “An intensification of agriculture, with grazing and cropping systems concentrating on the more productive land with some areas of land being managed less intensively or in an alternate way.” The two statements seem to have an element of contradiction.

DSE Reg

Please address – provide suitable explanation Provide an explanation for this statement rather than simply relying on a reference to another report.

See comment above (item 31) regarding the impact of diversion and drainage schemes and the allocations of urban water use.

Further explanation of the statement can be included in the final SAP as required.

33 9 85

Priority Setting – It is unclear if all learnings have informed the priorities

For example, the plan says that hydrological balance from urban development is more important than agric. land management for salinity outcomes. How is this conclusion arrived at? Does this appear in the Priorities and how is it expressed? Does the planning scheme need an overlay for salinity hazard? Do subdivisions need to be assessed for salinity credits?

Urban subdivision is mentioned only once in the hazards section (pg 15) but agric. land is noted in 8 out of 12 target areas. How does this fit with the above conclusion? What about SW runoff? DPI -Ag

Clarify which key strategic policy learnings have been incorporated and recognised as a hazard, which have been adopted as a priority objective for action and how they are implemented?

This information is provided in the Background Reports, especially reports 3, 4, 5 & 6. The learnings can be clarified in the final SAP document.

34 10 1.6 28

Surely additional key differences between the plans is the changed emphasis on Primary salinity, expectations in relation to integration and the more targeted recharge management.

Expand the discussion. CAS/DPI


Noted. The discussion can be expanded and clarified.

35 10 1.6 108

Although the original salinity plan is referred to, there down not appear to be a summary of the key findings of the review of this original SMP. These findings should have provided a basis for different, similar, new actions in the new plan. This is also a section identified as being required in the Draft SMP Guidelines. LCT

Include a section outlining the key findings of the review of original SMP.

A review of the original SMP was provided as a separate report. Section 1.5 of the SAP Regional Draft lists the key findings and recommendations of the review.

36

10

83

many statements in the text could be improved (sharpened) by spelling out exactly what is the point or message from the writer Example, “This plan is different from the previous one” – how? Is the answer, it will adopt the NAP and be guided by the Victorian Salinity Mgt Frame’k?

If so, it includes an objective of a quarter of agric. production from NR managed within their capability.

Will CSMAP pursue this and how is it interpreted (measured)?

“Urban water, the environment and biodiveristy must be elevated in our approach to salinity management” – what does this mean and how? – through Stat. Planning, education, salt credits? DPI -Ag

Link statements with key point or meaning and conclusion or next key message or objective in plan.

Noted. Consideration will be given to this point in the final SAP.

37 11 1.6 62 The relationship between the CSAP and other action plans under the RCS should be explored in this section. SI

Please include a description or diagram showing how the CSAP relates to other action plans.

Noted. However, at the time of the development of the Regional Draft SAP, the RCS had not been completed.



38 12 13

The SAP cites the increase of 18 EC units per year over past 26 years at end of the Moorabool River and goes onto say this threatens the urban water supplies of Ballarat and Geelong. This is not accurate. Water uptake for Ballarat is from the upper reaches and would not therefore be affected by the level indicated.

Delete reference of threat to Ballarats water supply.

Please comment on how removal of this water asset affects plan – market and non- market benefits. . CAS/DPI


Ballarat’s water supply is threatened by rising salinity in the Moorabool River upstream of the Lal Lal Reservoir. This is outlined in Background Report 3 and is the sole justification for including the Upper West Moorabool catchment as a salinity target area.

This can be clarified in the final SAP.

39 12 1.7 29

Discussion needs to refer specifically to the long-term discharge-monitoring program underway in the Corangamite region.

The intent of the last sentence in this section is not clear. What particular aspect of these assets needs to be elevated?

Restructure the sentence to clarify its meaning. . CAS/DPI


The reports on the long-term discharge monitoring (PIRVic, 2004 & 2005) were not available at the time of the SAP development. Reference to them can be included in a revision of Background Document 1.

The emphasis on urban water, environment and biodiversity mentioned in the last sentence can be clarified in the final SAP.

40 12 1.7 63 Paragraph 4, final sentence – note should be made here of the impact on aquatic ecology of increasing salinity levels. SI

Please expand this section to mention aquatic ecology.

Aquatic ecology can be mentioned, but there is no known data on the impact of salinity on the ecology of the Moorabool River.

41 14 2.1 7

Target areas & non target areas – implications for extension services & community support.

To ensure equity of the process, a program for updating information is required. This needs to include:

Further information for the next iteration of the Plan should focus on previous salinity hot spots that are no longer priority areas. As these areas will be receiving funding for a limited time and if these areas are to in future become priorities again, we need to ensure this occurs before the phase down funding is withdrawn. The phase out period is an important issue and it is good to see that this has been considered within the Plan

Although it is recognised that there are potential disadvantages with a ‘living plan’ from a community perspective, there is no suggestion of how the detrimental effects could be ameliorated. There should be a caution against changing priorities for on-going projects when a ‘cranking of the handle’ may re-establish the area as a priority at a later date. Momentum will be lost and the implementing groups or individuals disengaged. Also recognition that long-term investment and commitment is often needed in priority areas in order to make ‘a difference’

Long term commitment needs to be addressed, because if we change within one or two years our credibility will be in question.

Boundaries should be flexible when it comes to the funding and landholders that adjoin these areas should have the same chance at the funding if it’s available.

Maintenance of community capacity over the long term and the social issues arising in changing resource allocation, needs to be managed carefully. . CAS/DPI


(First dot point): This issue is flagged as an emerging issue in Section 2.9.1 of the Draft SAP and recommendations have been made.

(Second dot point): This issue was recognised 2.9.1 but is seen as an implementation issue. It is impossible to prescribe what actions should be taken if an area loses its priority status.

(Third dot point): Guidance is being sought on this point. Should we continue to invest in areas that, because of new knowledge, are now deemed non priority areas just to ensure credibility?

(Fourth dot point): Boundaries have been delineated using groundwater flow systems and assets at risk. While the boundaries of some areas may be a little flexible, the majority are based on investing where the management will have an affect on the asset at risk.



42 14 2.1 30

‘For practical salinity control, greater importance was placed on zones influenced by local ground water flow’

This statements needs further discussion in the text, it is not sufficient to simply refer to a background paper. The logic for the decision making must be clear as a stand alone document.

‘… A final check was introduced to ‘ ground truth’ the asset salinity hazard intersections.’

Please qualify - was this done for all asset class intersections or only some (which ones). . CAS/DPI


A brief explanation of the theory of groundwater flow systems can be included in the final SAP if required.

Full details of the procedure for ground truthing and the assets considered are contained in Background Report 2.

43 14 79 Figure 2. This diagram appears to be missing steps such as implementation, and monitoring and evaluation. If these steps are not going to be addressed in this document it should be explained why. NV

Please add required section, and /or respond.

In the seven step process illustrated in Figure 2, Step 7 “Decide on an implementation structure” and Step 6 “Determine catchment health sites and monitoring systems” are intended to include the points of concern.

44 14 Sect 2.1-2.2 94

Interim target areas.

These target areas are identified and then described as interim because further analysis could ‘exclude their selection’ (p. 14 Sect 2.1). It is not clear why they would be excluded and whether this process is part of the current planning exercise.

Also- the use of the expression needs to be consistent through the plan. It appears to vary from ‘Interim target area’, ‘interim location’ and ‘target location’. LCT

If this is not already covered in the plan then it needs to be explained.

This valid criticism of the inconsistent language will be addressed in the final SAP and the status of the target areas will be clarified.

45 15 42

Water supply catchments (WSC) were not in the original Assets model - the concept is good, but the activity is confined to small areas and more work is urgently needed

Use of Water Reservoirs to classify assets - suggest change this to Proclaimed Water Supply Catchments. . CAS/DPI


The GSHARP model used water reservoirs as one of the potential assets at risk. However, it was recognised (Background Reports 2 & 3) that this was inadequate and trends in water quality was substituted.

46 15 2.1 64

Under the list of asset classes the Environment is listed however this seems to be limited. Where only these aspects of public land VROTS and significant wetlands considered? Other aspects that should have been looked into include EVCs and remnant vegetation on private land. SI

Please expand the scope of the analysis of environmental assets.

Noted. At the time of the GSHARP modeling the EVC layer was not available. The process will include more environmental layers as appropriate in future revisions of the plan. The final SAP will add EVCs to the asset register for the target areas where appropriate.

47 15 2.1 65

Why have Flow Weighted Salinity trends been used to select streams for statistical trend analysis? Rather the actual salinity should have been used as this is what is measured for trigger levels eg WHO drinking water guidelines, aquatic ecology decline (ANZECC, 2000) or for agricultural use. FWS may be useful to consider for some applications, however it is not considered to be appropriate for the purpose that it has been used for here. SI

Please revise this assessment or provide sound reasoning why this approach was adopted.

GSHARP used flow weighted salinity as an initial parameter in determining hazard. However this was later substituted by a GAM analysis technique developed by CSIRO for the MDB modeling. Refer to Background Report 3 for the detailed explanation.

48 15 114

The section on ‘possible treatment options’ does not provide confidence that those actions indicated (p 17) are effective or appropriate. Is there evidence to this effect? There is neither validation of, or referencing of any treatment options indicated. There is not discussion on their effectiveness. Given this, it is hard to see how appropriate actions could be determined even though a ‘sound basis for exploring management actions’ may have been established. LCT

Section need to be expanded to support suggested treatment options WRT specific GFS. Reference to another document only is not sufficient.

Noted. The actions are related to specific GFS and then modelled (Background Report 3) for their effectiveness. This can be clarified in the final SAP.

49 15 2.1 115 Section 2.1 – Why wasn’t native vegetation used as an asset class? This omission is significant and needs to be rectified ASAP as native vegetation is a major asset class at risk. What plans are there to do this? BNS

Please address this issue.

At the time of the GSHARP modeling the EVC layer was not available. The process will include more environmental layers as appropriate in future revisions of the plan.



50 16 2.2 95 A good discussion of a range of possible treatment options and their implications. LCT

N/A Noted.

51 16 Table-1 12

Water quality is not listed as an asset on p. 15 yet turns up listed as an asset for Pittong and Illabrook in Table 1 – but not for other locations.

The cost benefit report did not or could not put material cost benefit to water? Incorporation of water quality as an asset needs to be applied consistently across target areas. . CAS/DPI


Noted. “Water reservoirs” should read “Water quality (water reservoirs, trends in river salinity)”. Adjustment will be included in the final SAP.

The water quality was consistent over all target areas (hence the inclusion of the two Moorabool areas)

52 16 Table 1 31 Please provide some explanation in the text describing why the targets are interim. . CAS/DPI


Noted. Refer to the reply to comment 44.

53 17 Native saline species selection

10

The Plan identifies the protection and management of discharge areas with native grasses / herbs species as a recommended management option.

Capacity to implement this action is currently limited to natural regeneration. Limited information exists on suitable indigenous species or their propagation techniques. This is addressed in Technical Report 8, which identifies selection and development of native saline plants as a high priority research action. Further to this however, effective implementation will require development of species /propagation knowledge within regional nurseries (as potential future suppliers of plant stock for these targets).

This gap needs to be noted as an action within the capacity building program. . CAS/DPI


Background Report 6, 3.2 high priority action 16 recognises this point. However, the explanation will be expanded in the final SAP

54 17 Tree Species selection 11

Indigenous or forestry species have been identified for ‘Tree planting adjoining or near saline discharge areas’. Many indigenous trees planted near discharge sites will not survive. It may be necessary to use other native but not necessarily indigenous salt tolerant species for successful establishment. (supported by landholders in p. 13 of report Technical Report No 6).

Species selection for successful establishment may include non/indigenous plants. . CAS/DPI


Refer to comment 53

55 18

2.8.1

TR 6

2.4.5

2

The Plan recommends integration of the SAP with other programs and plans but there is no attempt to incorporate the shared priority areas, or overlap, in the priority setting process. Links should be made in the model with other regional strategies and assets identified eg. Nutrient Management Strategy, Native Vegetation Plan or regional biodiversity priorities such as EVC information on values of Waterways in the region from the RIVERS model. Stronger links need to be made with other Regional Plans

Technical Report 6 outlines the importance of delivery of all issues not just salinity, but draft SAP does not elaborate further on this. Important that integration of SAP with other strategies and integration of issues on the ground is considered and developed?

Should mention the Western District Ramsar Lakes Management Plan. (Parks Victoria, document). . CAS/DPI

Please address – make the required changes,

Recognised in draft SAP 2.8.1 and 2.7.3 (paragraph 3). This can be clarified in the final report.

56 20 3

The background papers indicate that there is not enough information to suggest realistic targets. The change scenario table on page 20, however, identifies specific changes in EC units or tonnes/day as a result of plan implementation. Given the paucity of data these EC savings seem overly specific and misleading when reading without the contexting available in the background paper.

Refer to the EC savings as estimates and provide a statement in the text qualifying their confidence level. . CAS/DPI


Noted. However, some RCTs were set for target areas where there was sufficient data. Since the release of the Regional Draft of the SAP, additional research has allowed some more specific RCTs to be set for EoV targets.



57 20 Morrisons- Sheoaks 21

From Table 2, the proposed change scenario for the Morrisons-Sheoaks priority area is that ‘Treating 500 ha of designated recharge will reduce salinity at Sheoaks by 1 EC/yr’ and ‘Treating 63 ha of saline discharge will reduce salinity by 0.5 EC/yr’.

The no change scenario for the same area has salinity rising from 15 to 30 EC /yr.

Assuming that these figures are correct and it takes 2 years to implement the treatment (revegetation) – it will take 30 – 60 years to get salinity levels back to where they were when the treatment commenced. . CAS/DPI


The reasons for the rising trend in the Moorabool River remains largely unknown (Background Reports 3 & 6). However in the interim, revegetation of certain areas will slow the trend. As more research is completed, additional actions can be developed which will assist in stabilising or reversing the trend.

58 21 2.3 96

The list of asset managers varies greatly. Some are direct managers of land assets while others may manage some land but have a large influence over other land managers. This distinction must be considered as should influence the consultations- if this has been done then it needs to be made clear.

In particular, ‘landholders’ are listed, along with Modewarre Catchment & Lake Communities. Its is unclear why the latter group is singled out without also being specific about which landholders are involved. LCT

Please address Noted. The final SAP will expand on the reasons for consultation

59 21 86

Landholders are referred to as one large group but they are not one large homogeneous group. There are many different types in addition to primary producers. Forestry landholders are separate from forestry owners and dryland producers vary from irrigated enterprises. Each will vary in their capacity and willingness to invest in salinity management DPI -Ag

The plan should reveal how the backgound reports provide basis for any social analysis. Do the report’s have access to this type of data and the work been done?

If not, the need for better social data to inform actions is required as an R & D need – social assessment component of the TBL process

No useful social data existed before the analysis. The findings from the targeted asset manager approach (documented in appendices of Background Report 4) is the most relevant social research available. This is used to develop the support programs in each target area.

60 22 2.4 66

Only asset managers have been consulted and it appears that some key stakeholders for program implementation or people that may be affected by implementation actions have not been consulted in the process, eg DPI, DSE (more broadly than crown land), CMA, SALMIC, environment groups, industry groups. Also the CSAP does not mention the CRC for Plant Based Management of Dryland Salinity – how has this directly relevant research body and the findings of investigations been used in the process? SI

Please consider the comments regarding consultation. It does not appear that all key stakeholders have been consulted from the information provided in the CSAP.

This was the first of a 3-stage consultation process approved by the CCMA as was all that was expected in the first draft of the SAP. The other 3 stages are occurring as the SAP is finalised.

61 22 2.4 32

This section seems overly comprehensive in relation to other sections. Much of this discussion would more appropriately be provided in the technical reports. Comments appear to be based on perception at times rather than fact. While the asset managers’ comments are valid from their point of view they may not be accurate and it would be inappropriate to validate these views by repeating them in the main document.

Education programs with the asset managers to support informed decision making is critical to progression of salinity plan implementation. See also previous comments on community education.

2.4..3 Treatment of these areas is costly…..Financial returns are deemed small compared to the required investment.

Current, establishment, management and production of productive saline species compares favourably with non saline areas. . CAS/DPI

Please respond – provide explanation Refer to comment 59



62 23 2.4.3 97

Para 3 discusses perennial pastures and some apparent differences in the views of landholders in one area. The suggestion that further investigation of perennial pastures as a recharge control option needs much more discussion if it is acted upon. Dissenting opinion based on local anecdotes is not sufficient evidence that more R&D needs to be done. This needs much more thorough consideration. LCT

Please address Noted. This issue is identified in research action 19 and has been recently backed by the Evergraze project.

63 23

Valuing assets 1

Salinity Action Plan (SAP) has been written based on iterations run in GSHARP/ISCRP and other analysis. It is well documented that the information used in GSHARP/ISCRP was of poor quality.

Given that utility managers have admitted, “the intersection of a utility with salinity did not necessarily infer salinity damage to assets”, is it appropriate to use it as a value without some qualification? . CAS/DPI


While the data used in GSHARP was, in some cases, of dubious quality, the process of target area selection is relatively sound. The final weightings took into account the lesser importance of damage to infrastructure and utility conduits.

64 23 87 “Each of the utility managers had their own strategy for protecting their asset against salt” DPI -Ag

This approach might be appropriate for other land managers, inc. primary producers?

There doesn’t seem to be a recognition that all businesses regardless of sector need a plan to protect their assets even if that plan is not to do anything or not to spend money but alter management.

Noted. This was taken into account using the program logic approach (Background Report 4). Comments will be expanded in final report

65 23 88

Scepticism in the rural community needs to be specifically addressed and further investigation of perennial pasture options may not be warranted based on other experience in other regions.

What are the institutional arrangements that have actively discouraged management of discharge and are they likely to be addressed , by whom and over what time frame? DPI -Ag

Provide a more detailed analysis of the failure of rural landholders to understand accept and engage in solutions to salinity management

Explain more fully what the institutional barriers are to effective discharge management if this has a bearing on success in salinity management.

Institutional arrangements that hampered previous salinity implementation are listed in the draft SAP but will be expanded in the final version, in light of this request.

66 25 Pest Plant & Animal Control

14

The SAP outlines the ‘next action’ in certain priority areas as requiring ‘implementation of rabbit control program’. Integration of implementation is a critical component of the plan and pest animal and weed control should be seen as a precursor to any onground works.

The Salinity Plan is one layer contributing to decision making on target areas for the pest plant and animal program. Given limited resources consideration needs to be given to how this integration precursor will be resourced when target areas fall outside the multiple benefit analysis for pest control.

Expand actions to include priority weeds. . CAS/DPI


Noted. This will be amended in the final SAP. See comment 55



67 25

Mapping

1.2

&

2.4.3

6

Section 1.2 states ‘salinity mapping is incomplete and many areas remain unmapped’. Discharge information is a core data set used in the selection of target areas, establishment of resource condition targets and for analysis of progression towards targets.

Section 2.4.3 comments from agricultural land managers’ highlights the need for salinity mapping.

Given the significance of this data, it is surprising that there are no actions identified for improving the quality of the data within existing identified priority areas or outside these areas (to inform reprioritisation).

Include action to improve discharge mapping data set quality.

Table 3 recommends recharge mapping be undertaken by university students.

The quality & reliability of base data collection is critical. The issue of region wide consistency is particularly important, and has been criticised in the past. Mapping done over time by a series of different people has inherently lower confidence levels.

University students may not be the most effective implementation option. See also comment 28. CAS/DPI


Salinity mapping is a monitoring action in most of the target areas. Improving the data sets for GSHARP is also a research action, although of medium to low priority (Background Report 6). The area of land salinised is a RCT in those target areas where agricultural land is an asset, therefore a catchment health site has been costed into the plan.

University research can be of the highest standard, provided that it is at graduate or post-graduate level and closely supervised. Recharge mapping needs only be done once, therefore it’s appropriate that it be carried out as university research.

68 25 Table 3

20

Pittong, dot point 2. It would seem premature to initiate this action without further research particularly if it is based on the information provided in TR 6 (see below)

TR 6P54, 55 Woady catchment Surface drainage.

Discussions with community groups about management options can be quite controversial and inconclusive and can lead to misconceptions or false expectations if not carefully addressed.

Further research into surface drainage, as a management tool should be undertaken before whole scale adoption is implemented. . CAS/DPI


The conceptual model for salinity indicates that surface water management is a viable method to reduce the area of land salinised and the salt export to the Woady Yaloak River. The method is experimental for the area and only small-scale trials are proposed initially and are being monitored.

69 25 Table 3 22

The action plan guidelines do require responsibilities and roles to be defined, however, the approach taken in Table 3 is to assign responsibilities according to preferences of asset managers approached. There are several limitations with this approach.

If an asset manager was not approached they have not been included and may perceive themselves as excluded from implementation responsibilities / accountabilities.

The nominated delivery agent may not be appropriate given other factors, which need to be taken into account. Eg capacity to deliver, reputation, confidence levels etc.

Responsibilities refers to who is responsible for making sure the action happens and not the person / group who may actually complete the task. . CAS/DPI


All asset managers should have been identified from the GSHARP process and consulted during the consultation process. This will be reviewed and additional consultation undertaken if needed.

The list of nominated delivery agents does not imply acceptance of responsibility. This has to be negotiated at the implementation level and on a case by case basis. The list is simply a starting point (market research) to begin negotiations

70 25 Table 3 Time frame 23 There have been no timeframes assigned to the implementation of actions or apparent priority ranking of actions within target areas. . CAS/DPI


Appendix 3 lists the proposed funded actions for the first 3 years. Background Report 6 lists the priorities for the research and monitoring actions.



71

25

34

2.4.6

2.6.3

67

Table 3 provides “Next Actions”. How are these related to the management action targets in Appendix 5? Why have actions been separated into on ground works and then other additional targets are not even in this plan, they are in the background reports? SI

Please provide link between Table 3 and Appendix 5.

Please ensure that all MATs are listed in the CSAP, preferably together.

Noted. A link in the table can be included in the final SAP.

72 25 2.4.6 68 Table 3 refers to implementation of the rabbit control program, however this has not been mentioned previously in the document. There needs to be clear links between management actions and threats to assets. SI

Please ensure that threats to assets are clearly documented in the CSAP and that this is clearly linked to management actions.

Noted. This can be clarified in the final SAP.

73 25 2.4.6 69

Table 3 lists DPI as the co-investment party for many of the activities, however it is actually DSE that are the investors and DPI are the service provider.

There are also investors highlighted that do not appear to have been consulted – surely they are important in development of an implementation program? SI

Please amend.

Noted. DPI will be changed to DSE. At the time the SAP was developed the NRE = DSE +DPI deconstruction was still underway and roles were not clear. Some of the other co-investors were chosen because they are current stakeholders in the same or similar actions (eg. University of Ballarat research)

74 25 2.4.6 70 Table 3 – what are the time frames for “next actions”? SI Please provide time frames. Noted. Refer to reply for comment 70.

75 28 2.5.1 33

Tourism, recreation industries and cultural heritage are mentioned as benefits in other places, but are not listed as either market or non-market benefits of the plan.

Benefits need to link to specific actions identified in the plan. . CAS/DPI


Noted.

76 28 2.5.1 71

Table 4 – a market benefit for the Upper West Moorabool location could include the savings on water treatment by keeping salinities below 800 EC. This cost should be known and able to be applied to the no intervention scenario and the preferred management option. SI

Please determine if these market benefits are readily available and include in assessment

Noted. This will be considered in the final economic analysis.

77 28 2.5.1 98

Table 4 is labelled as market and non-market benefits. This terminology is not correct. It is expected that this sort of terminology would be used to differentiate between economic costs (which can be priced or costed) and social or environmental costs (which cannot be priced or costed). For example:

protecting urban water supplies is listed as a non-market benefit. This is a benefit that can and should be priced. It is the value of the water, or the cost of having to restore it to required quality. It is therefore a priced benefit.

In the Morrison Sheoaks area salinity impacts on urban water supplies are listed as $5.4 million per annum. If it can be priced it should be considered an economic benefit (in this case a cash cost avoided).

Impact on municipal roads is listed as a market benefit. If so, why isn’t water supply protection considered a market benefit.

Protection of urban sub-division assets is listed as non-market. This can be priced or costed so should be considered as an economic benefit. LCT

Please address. This table needs major revision and brings into question the economic analysis in the plan. Eg. If impacts of salinity on urban water supplies has been considered to be a non-market issue, and therefore it is not costed in the cost-benefit analysis, then the analysis is seriously flawed. This concern must be addressed.

Refer to comment 76.

78 30 2.5.3 34

‘Three of the target areas did not have any tangible benefits at this point in time.’

If there are no identifiable market or non-market benefits from implementation in these areas why are they ranked so highly in the plan Lake Corangamite – Priority 1 and Upper West Moorabool – Priority 3. Further discussion and explanation is required to justify their ranking. . CAS/DPI


The target areas without tangible benefits were ranked as tabulated in Appendix 2. Background Report 5 will be revised with comments noted.

79 30 2.5.3 76 Table 5 – What does ‘Overall’ refer to in the title ‘Benefit cost ratios (BCA) for each location Overall’ Does this mean including all actions in appendix 3 or ??? The use of the term ‘Overall’ is not clear, nor appropriate. LCT

Please clarify, and indicate what this refers to.

Noted.

80 30 2.5.3 77 Benefit cost ratio is required at 8% also. LCT Please address Noted.



81 30 2.5.3 99

Terminology is incorrect here. Tangible benefits appears to be used as a proxy for economic or priced benefits. Some tangible benefits cannot be priced- eg. Biodiversity benefits from treebelts are tangible (eg. Fauna populations) but cannot be priced. LCT

Please clarify and address Noted.

82 30 2.5.3 100

Para 2: ‘On a purely economic rationale, investment should occur without intervention.’

This is not correct. It assumes that private landowners or ‘asset managers’ know what the benefit cost ratio is, that they believe it, that it is correct for their particular circumstances etc. These are huge assumptions and will not be correct. Even when the benefit:cost ratio is well over 1, it is still an estimate and still will not ensure ‘investment without intervention’. LCT

Please address Noted.

83 30 2.5.3 109 Paragraph 2. The sentence ‘However the basis for expenditure…just economic’, should this actually read ‘just financial’? LCT

Please respond Noted.

84 31 2.5.4 72

This section notes that the “project team considered both the marker and non-market benefits and have suggested a priority based on a combination of the two”. How have the CMA, the IC and key stakeholders been involved in prioritising the works? SI

Please clarify. If key stakeholders have not been involved in prioritisation then this should be a key next step in finalising this plan.

The IC and key stakeholders were involved in the ranking though their participation in workshops specifically held for this purpose. Stakeholder consultation will be expanded in Background Report 4 and the SAP

85 31 2.5.4 101 The prioritisation process appears to take a good range of factors into account. The listing of the ‘intangible’ benefits is good (appendix 3). LCT

No action. Noted.

86 32 Woady catchment Pittong & Illabrook areas

19

The Woady Catchment is 3.3% of the Corangamite region. However, it is assigned 25% of the funds $M1.6 over 3 years. This would prevent an increase of 5 EC in the river – seemingly insignificant for such a cost.

There appears to be an imbalance toward the Illabrook and Pittong areas with a disproportionate amount of resources recommended to be allocated at the expense of more significant areas:

The intensity of actions in these two catchments is to the extent of “Refine recharge maps to allow for farm scale application”, yet in other catchments, (with the exception of Morrisons, with higher or similar priority ranking, (p.32), such an intense level of investigation is not advocated.

Illabrook and Pittong rank 6 and 7 out of 12 in Table 6. “Investment Prioritisation for Actions in Locations”. Why is the cost of implementation of the SAP in Illabrook the third highest amount for all the sub catchments? Recommended allocations appear unrelated to priority ranking.

In the “Assets identified at risk from salinity”, (Table 1.), these two sub catchments, (especially Pittong,) are small in size and asset risk significance in comparison to other areas such as the Upper West Moorabool where urban water supplies are at risk from rising salinity.

Is 25% of the implementation funding earmarked for the Woady Catchment warranted, achieving a reduction of 5 EC? . CAS/DPI

Please respond – provide clear and detailed explanation

There is obvious confusion over how to interpret and use benefit cost analysis in ranking. This will be revised in Background Report 5.

(First dot point). There are only three of the 12 target areas where recharge control is considered an appropriate management technique (based on GFS response). There three target areas are treated equally.

(Second dot point). The top four priorities have relatively few actions, pending the outcomes of the major research projects being undertaken at the time of the SAP development. The fifth ranked (Geelong-Conneware) also requires research before on-ground actions can be developed.

(Third dot point). The on-ground actions for the Upper West Moorabool are pending the outcome of major research.

87 32 2.5.5 35

Significant expansion of this section is needed. It is not sufficient to simply refer to background papers. Adequate discussion needs to be included to enable the reader to understand the intent of each of the themes beyond that inferred by the title.

There are no apparent actions, priorities, timeframes, and implementation responsibilities listed in plan arising from these region wide themes.

Actions relating to region wide themes need to be listed in the document. . CAS/DPI


Noted. This can be included in the final SAP.

88 32 2.5.6 49 Table 7. The table does not indicate the contribution of private component. Or is this part of the on ground works. There is no indication here of the potential or suggested cost share in the activities listed. LCT

Please provide explanation and indicate if private component is included at all.

Described in Background Report 5. This can be added add into the final SAP as required.



89 32 2.5.6 50

It states … “cost share arrangements suggested by the various asset managers.” What are these cost share arrangements? Are they the same for private landholders and Local Government and Utility organisations and State Government?

DSE Reg


Provide a listing or indication of what the cost sharing arrangements were suggested by the asset managers.

Refer to comment 88

90 32 2.5.5 102

Five region-wide themes are identified. These themes are not clear in Appendix 3, which is where I would expect to see them in order to see how they translate into projects or investment There is only an R&D column. Where are the other region-wide issues addressed. LCT

Please address The region-wide themes are detailed in Background Report 4. This can be added add into the final SAP as required.

91 32 2.5.6 110

Point 6. ‘Using the cost share arrangement’. Re Table 7, there is no reference to cost share at all in the table. There is simply an allocation of expenditure on various pieces of work. Cost share refers to ‘who’ will pay for the activities based on principles like Duty of care, beneficiary pays etc. and is usually viewed as private vs public contribution.. LCT

Reference to cost share being represented in Table 7 need to be removed. A section dealing with how cost share is derived need to be included in the document

Noted.

92 33 Targets & Resource conditions

4

The introduction to target setting does not use the standard definitions as set out in the National Framework for Natural Resource Management Standards and Targets. Target setting also needs to take into account the National Framework for monitoring and evaluation

Use the agreed definitions and expand with additional interpretation if required. ie resource condition targets are for 10-20 yrs not 5-10yrs as stated. . CAS/DPI


Noted. At the time the SAP was being developed the National Framework was not finalised. This can be amended in the final SAP.

93 33 Table 7 103

This Table appears to be a summary of the program of investment that the plan proposes. However, the plan MUST describe in more detail what is being done for the investment in each priority area. It is critical to include a description of:

The key priorities in each target area

The outcomes for each area

The actions for each area.

LCT

Please address The key priorities are listed in Table 2, the outcomes in Table 2 and Table 4, and the actions in Table 3.

94 33 2.5.6 111 Table 7 – Why are the dollar figures not discounted? LCT Please respond These were presented as a real cost over time for implementation committee / RCIP use.

95 33 2.6 118 Why are there no targets related directly to biodiversity assets at risk e.g. areas of wetlands at risk? BNS

Please respond. There are several RCTs directly related to the waterway and wetland ecology (Background Report 6).

96 34 2.6.2 36

Resource condition targets identified in Appendix 4.

Many of the ‘targets’ identified here are not actually resource condition targets as defined by the National Framework. Many appear to be actions requiring implementation and thus belong in a different section of the report.

Reassess identified targets against required criteria. . CAS/DPI


Noted. The targets were set at a time when the National Framework had not been finalised. These targets will be adjusted in the final SAP.

97 34 2.6.1 51

The “aspirational target” is worded … “ Corangamite will – by ongoing measurement, monitoring and experimentation attempt to sustainably manage the region’s salinity (impacts).”

Firstly, “attempt to” is not very aspirational!

Secondly, there is no reference to facilitating and negotiating funding for salinity management as part of the aspirational target.

. DSE Reg

Please address, make required changes Review and restate the aspirational target in a more positive manner

The aspirational target was determined at a meeting of the key stakeholders, including the CCMA Board members. We are uncomfortable about changing CCMA / community-derived targets.



98 35 2.7 17

It is good to see that Community Education has been considered as an integral part of SAP and is one of the recommendations for future resourcing in the area – a community education officer. It is a valuable and cost effective way of engaging with stakeholders, forming partnerships and promoting community awareness.

The development of Community Education for SAP is well supported. . CAS/DPI

Nothing required Noted.

99 35 2.7 37

The title of this section does not represent its content. The text provides a discussion of implementation issues that need to be considered for effective delivery. Their inclusion is not a requirement for the plan and are more suited to internal implementation discussions, particularly as a number of the statements require further discussion and substantiation.

Remove sections 2.7.1, 2.7.2, 2.7.3

Documentation of Implementation structures is a requirement of plan endorsement. This section needs to outline the State and regional structural arrangements, which will facilitate implementation.

Identifies the need for a separate implementation group to be created. The CCMA Sustainable Agriculture and Land Management Implementation Committee currently have responsibilities for overviewing salinity implementation. Their existence is not discussed in the plan, and there is no justification provided for the development of alternative arrangements. . CAS/DPI


This section will be revised now the new Corangamite Regional Implementation Committee has been formed and Operational Portfolio Groups established

100 35 2.7 73

This section is not really appropriate for the final CSAP. These issues should be dealt with prior to preparation of the final document, whether they are completely resolved or listed as management actions is up to the CMA to determine. SI

Please resolve these issues. Refer to comment 99.

101 35 2.7 104 This entire section is out of place and should not be part of the final plan. The issues raised here, including the many recommendations, are supposed to be dealt with in the plan. LCT

Please address Refer to comment 99.

102 36

2.7.2

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2.9.2 &

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2.9.4

52

The second paragraph refers to the challenge of integrating salinity management into an often diverse range of other ongoing activities of an “asset / land managers” and achieving agreement / endorsement of coordinated action across the range of asset / land managers.

Then on pp 40 – 41, there is reference to the need for integration and collaboration with water resource management, environmental resource management and agricultural industry.

But there is little or no discussion of the roles of the CMA and State Government (DSE) in the event that this joint agreement and integration - coordination is not initially achieved. There is no mention of roles such as the regulatory role or the facilitator role or the mediator role or the influencer role that either or both the CMA and DSE could or should have.

DSE Reg

Please address – outline management process more thoroughly Include some coverage of the respective roles and approaches (eg regulation - facilitation – influence – funding assistance – technical advice etc) that the CMA and DSE should use in the event of one or more asset / land managers not wanting to participate in a coordinated approach to salinity management.

Will be expanded in Background Report 4 and final SAP.

103 36 80

Second paragraph. The recommendation looks at ‘sign off’ from key stakeholders in a target location to endorse salinity investment. This recommendation could go further than just endorsement as it takes more than a ‘sign off’ to achieve integrated delivery, such as through developing innovative approaches and alignment of projects. NV

Please repsond. Refer to comment 99.

104 39 2.8 38 Common implementation themes appear to be principles for effective implementation delivery and may be better presented as such. . CAS/DPI

Noted.



105 39 2.8.2 74 I strongly agree that delivery of activities should not be standardised over a region. Priority areas need to be targeted and addressed in the most appropriate way. SI

Please ensure that a targeted implementation approach is adopted.

This approach is recommended in the SAP 2.8.2

106 39 2.8 105 This is a good description of implementation issues and identifies some positive approaches to implementing the plan. Eg. Use existing delivery mechanisms LCT

No action required Noted.

107 40 2.9 39

Emerging issues.

This is not a core requirement of an action plan. Once again these are more appropriately suited to implementation discussions. In fact many of them are not emerging, but are long standing implementation debates. The issues discussed are within the capacity of the IC to act.

Any specific requirements need to be documented as ‘actions’ rather than recommendations. . CAS/DPI


Noted. The emerging issues are nevertheless important, but may be better discussed in one of the Background Reports. This will be expanded in the implementation role discussion in the final SAP.

108 40 2.9 106

This section again raises issues and makes recommendations. This is not appropriate for a plan- the plan is supposed to identify how the issues are going to be addressed. Eg. Making a recommendation and then saying its not costed into the plan does not make sense. LCT

Please address Refer to comment 107.

109 41 89

Agric. industry groups are identified as a key stakeholder in a partnership approach in salinity treatment but no where else in the plan is this group described or discussed (see Point 8 above).

Is this Southern Farming systems? DPI -Ag

A more sophisticated analysis of key stakeholder groups within the landholder community is warranted in the plan. The role of collective landholder groups in the strategic goals of the CMA should be identified & highlighted esp. with regard to any perceived scepticism about the contributions to salinity and the effectiveness of various treatment options.

Noted

110 43 45

There is emphasis on physical research and investigations but what about social research and investigations? At the end of all this we may know exactly where to make the landuse change, but if the private landholders (the greatest proportion of asset managers in the region) won't do it, what's the point?

Social research should be included as a component of the plan. CAS/DPI


Given the targeted asset manager consultation, no social research was described in the first three years. Once implementation has been undertaken, designed on the previous social understanding, new social research might be identified. Background Report 6 details several research projects.

111 43

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Is it appropriate for all steps in the process to be ‘re-run’ when new data becomes available or every 3 years as suggested in section 4? The CSAP will need to be reviewed and renewed every five years for Govt so perhaps this is the appropriate time for the steps to be re-run, particularly if they are resource intensive. Certainly the CSAP needs to be a ‘living’ document and adaptive management needs to be a key component of implementation SI

Please clarify how often it is anticipated for process to be re-run, given the requirement to review and renew the SAP every five years.

The SAP will be completely renewed each five years as required, but in the intervening times, steps 2 to 7 can be rerun within the target locations if required. This provides the opportunity to respond to new scientific data that becomes available which may create a need to reassess the treatment options, etc.

112 43 3 112

But what R & D is going to be done? There is no indication of the key R& D required. It should have been worked out what these priorities are, and they should form the basis of an R & D action program i.e. part of the SMP, not simply referred to as a reference. LCT

Please address The key R & D projects are detailed and prioritised in Background Report 6. This can be clarified in the final SAP.

113 44 4 40

The Salinity Plan recommends a review period of three years, rather than the standard government review period of 5 years. If the plan is a living document as described earlier in the text, why is a shortened review period required? . CAS/DPI


A review is not the same as a renewal. A review of the plan can be an ongoing process, whereas the renewal may require a reassessment of target areas. See also the reply to comment 111.



114 45 Appendix 1 Farm Forestry

16

Standard Values used in the Cost Benefit Analysis include figures for tree-planting works are very high. For example, establishment of high density tree planting is costed at $1650/ha and $3300/ha for tree planting for watertable reduction. It is unclear how these figures were calculated and why the latter is twice the $ amount of the former.

The current average cost for tree establishment, excluding fencing, is more like $1300/ha, assuming that all the works are contracted out. Usually at least some component(s) of site preparation and establishment of small-scale farm forestry, eg under 5 ha, is undertaken by the landholder.

The figures quoted in the analysis should consider the landholder undertaking works (savings) therefore costing may need to be revised. . CAS/DPI


This will be revised in Background Report 5.

115 47 116 Appendix 2 is a very coarse assessment – why weren’t state and regional criteria used e.g. bioregionally significant wetlands, bioregional status of VROTs etc. BNS

Please respond, provide explanation [including how this will be covered n the amended plan].

Bioregional boundaries do not necessarily co-incide groundwater flow systems which is the basis of the priority areas identification. One problem with the available data is that the consultants could not drill down into the VROT assets to investigate the species or its status.

116 47 117 Appendix 2 – was national status of VROTs considered? BNS Please respond. Refer to the reply to comment 115 above.

117 48 Costing 5

Costs outlined in Appendix 3 Technical Report 2, do not increase over time as they do in reality. The costs in Appendix 3 also do not include the dollars for phase down of current hot spot areas as recommended on p. 26 Technical Report No 6.

Increased costs (inflation) need to built into the Plan. CAS/DPI


Noted

118 49 Appendix 4 113

Most (22/42) of the resource condition targets set out in this appendix do not appear to be resource condition targets at all. They appear to only be actions to be carried out, in some cases that may determine a target. Lets not confuse the act of establishing targets, and of actually having a target that actions work towards achieving. LCT

Please address. – remove items that are not actually resource condition targets.

Noted. Refer also to reply to comment 96.

This can be amended in the final SAP.

Minor comments

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119 General Labelling 121

A general comment on standard labelling in reports.

Tables: labels go above the table

Maps / Graphs / figures: labels go below. CAS/DPI

Please edit or respond to comment

Not according to the Australian Government Style Manual (5th edition). This may be a State government publication rule.

120 Water management 123

Extension/training programs for groundwater and urban water managers not well outlined.

Resourcing and development of training programs for water management required. CAS/DPI


It’s probably not the CCMA’s role to train the water managers, but rather work with them to overcome the salinity related issues.

121 General 154 The plan addresses natural (or primary) salinity well. However it does not look at management options for these areas. NV

Please respond/ address

Management options for some areas are pending the outcome of the major investigation projects (eg. Lake Corangamite). In other areas (eg. Lake Connewarre) research is required to establish the exact nature of the treat to primary salinity assets.



122 General 155 Not clearly articulated what is the role of the community in monitoring. Does the community participate in this process. Not specific mention of this. CS


The Draft SAP proposes that the implementation be matched to the best provider as judged by the asset manager. This role will be performed by the new IC on a case by case basis.

123 General 156

Throughout the document and strategy there is a heavy emphasis on research as the key mechanism for addressing salinity and developing further knowledge. Is this the only mechanism? And what role does or can the community play in determining these agendas or even questioning the role of research. This is not discussed in the Strategy CS


Research is required to understand the salinity processes and exact nature of the threat to assets in the majority of target areas. In the Upper Moorabool and Lara target areas it is the only action that can be taken at present. In other areas it is a key requirement to match the actions with the threatening processes. All research projects are developed in conjunction with a coounity based implementation group. Where appropriate this questioning will occur.

124 3 Forword 122 It would be more appropriate for the SALMIC Chairman or Board Chair to present a foreword than the consultant. CAS/DPI


Noted. This can be addressed in the final SAP.

125 6 119

‘The rural population, despite farming more than two thirds of the land…is at best stale or falling..’

This statement infers that the rural population is comprised only of farmers. The rural population is in fact far broader than purely farmers.

Reword to provide more appropriate context. CAS/DPI


Noted. This can be amended in the final SAP.

126 7 Referencing 120

‘During the same period the regions primary industries are expected to adopt different agricultural systems such as cropping and forestry…..’

This statement needs to be referenced.

The statement needs clarification does different mean ‘ new’ or an expansion of existing areas. . CAS/DPI


Noted. This can be amended in the final SAP.

127 7 1.2 125 Paragraph 2 – this looks at the Murray-Darling Basin Commission benchmark, which the Corangamite region is not part of. A more appropriate comparison would be to the trigger levels presented in the latest ANZECC guidelines for fresh waters. SI

Please consider removing this reference and making the comparison with the ANZECC trigger levels.

Noted. This can be amended in the final SAP. The comparison with the MDB is nevertheless a valid one.

128 8 1.3 126 Secondary Salting sub-section, paragraph 2 – The sentence “groundwater systems have been relatively ‘full’” does not really make much sense. SI

Please explain this using more appropriate hydrogeological terminology.

Consideration will be given to rewording the sentence to make it clearer in the final SAP. However, the statement does make sense.

129 8 1.3 127 Secondary Salting sub-section, paragraph 2 – words such as ‘regolith’ should be included in a Glossary of Terms. SI

Please consider including a Glossary of Terms in the document.

Noted.

130 8 1.3 128 Secondary Salting sub-section, paragraph 2 – replace “mobilising” with “mobilised” SI Amend. Noted.

131 9 1.5 & 1.6 129 These sections would be easier to read if the lists were dot pointed. SI Please dot point lists using a bullet format.

Noted.

132 11 157 In the document where community is mentioned there is no discussion on how they obtained this information. CS

Please respond/ address The community structure was taken from the CCMA RCS which was under development at the time.

133 12 1.7 130 Paragraph 4, sentence 3 – delete “of” from “in some of rivers and streams” SI Amend Noted.

134 13 1.7 131 Paragraph 5 final sentence – replace “elevated” with “considered to be a high priority” SI

Amend Noted.

135 14 2 132 The use of the term “target locations” in reference to high priority areas may not be the best when the document also discusses other targets (management actions, resource condition, aspirational” SI

Consider changing from “target locations” to “high priority locations”

Noted. Consideration will be given to the terminology in the final SAP.

136 15 124 DPI Water Quality staff were not directly consulted in the investigations. Recommend involving CMA/DPI Water Quality and River Health program team in the future to draw on experience. . CAS/DPI


Noted. This was an omission in areas where water quality was the asset under threat. This will be rectified in the final SAP.



137 15 2.1 133 Final paragraph before start of Table 1, final sentence – this should refer to Figure 3. SI Amend Noted.

138 16 2.1 134 Table 1 heading – replace “as risk” with “at risk” Amend Noted.

139 17 2.2 135 First paragraph on this page – where research results from the CRC for Plant Based Management of Dryland Salinity considered? What about other research organisations (eg CSIRO) or national R&D programs? SI

The scope of the literature review should be expanded to include these other sources.

Noted. The range of options was largely sourced from the GFS report, which drew on the PUR$L and OPUS databases. This can be clarified in the final SAP.

140 17 2.2 136 Under Biological Treatments “shallow surface drains to intercept lateral flow of perched groundwater” is included. This is really an engineering option. SI

Please move this option to the engineering option list.

Noted. This can be clarified in the final SAP.

141 19 2.2 137 Figure 3 shows that there are no high priority areas along the coast. As there is no discussion of threats it is not possible to determine if coastal salt water intrusion into groundwater aquifers is a concern for this region. SI

Please respond.

The target area locations were determined using GSHARP. Hazards in the coastal areas threated assets in the Geelong-Connewarre and Lara region, hence they are target areas. Salt water intrusion was noted as a threat in the Lake Corangamite target area (Background Report 3).

142 20 2.2 138

Table 2

Upper Moorabool - Change Scenario is critical to determine as the reservoir is a water supply to the two major regional centers in the catchment.

Pittong – convert the 3 tonnes/yr figure into EC to be consistent

Justify the “perhaps double” comment regarding extending the life of roads in several of the target locations.

In general the “No Change Scenario” does not provide a good enough picture of what will actually happen if nothing is done – very general. Is the detailed information provided in background reports? The comment following the table on page 21 (“This table clearly highlights that salinity will have a significant impact on the region’s assets unless action is taken”) is not really substantiated by the information provided in the table. SI

Please consider providing more detailed information on the No Change scenario, or providing the reference to the detail, which is assumed to be in a background report.

Noted.

The Upper Moorabool does not have a change scenario as there are no actions to model as yet.

Converting the 3tonnes/yr into EC for Pittong is very difficult at present. Perhaps this will change in time for the final SAP. If so, it can be amended.

The ‘No Change Scenario’ is detailed in Background Report 3. Consideration can be given to providing more detailed information in the final SAP.

143 21 2.3 139

Paragraph 1 under this section highlights that most of the actions need to be taken by people other than the CMA. The paragraph should highlight the important role that the CMA has in fostering good partnerships between resource/assets managers in the region. SI

Please reflect this in the text. It is implicit that the CCMA has a need to foster partnerships. Consideration can be given to highlighting this in the final SAP.

144 21 2.3 140 The list of Assets Managers should be provided in a table along with a brief description of what asset they are responsible for. SI

Please amend list. Noted. It should be apparent, but will be considered in the final SAP.

145 21 2.3 141

The list of Assets Managers does not seem to be broad enough. For example DSE are only included in connection with Crown Land, however their role is broader than that. Other groups that really should be consulted with include DPI, DSE, SALMIC and potentially others that may not be assets managers but play are still important stakeholders in the management of assets.

Also how many landholders were consulted? How many, what was the nature of the consultation etc. SI

Please amend list and provide clarification.

DPI, DSE, SALMIC, CCMA Board, GHCMA and others were consulted through workshops and meetings.

Landholder consultation is documented in Background Report 4. A revision of Background Report 4 will clarify the asset manager and stakeholder consultation.

146 21 158 In the Strategy there is considerable discussion about engaging asset managers. This appears to be the major engagement strategy. Is this really an adequate community engagement approach? There is too much reliance on this approach. CS

Please respond/ address This process was endorsed by the CCMA as an appropriate consultation process.

147 22 2.4 142 This section may not need to be included in so much detail in the CSAP. It could be included in supporting documentation instead. SI

Please consider providing an abridged version of this section.

Noted.

148 25 2.4.6 143 Table 3 next actions refer often to “Commence resource condition monitoring”. This implies that there are currently no monitoring activities currently undertaken. SI

Please amend. There is no monitoring in some of the target areas. The action statements are correct.

149 26 2.4.6 144 Table 3 – under the asset manager’s suggested delivery agent listed in this table Engineering Consultants are listed several times, however the table does not list who the key organisation responsible for delivery/coordination of the action is. SI

Please provide an indication of who the primary organisation is responsible for the delivery of actions.

The CCMA is responsible for all actions in the SAP. It should be implicit since it’s a CCMA Action Plan. The SAP will be amended to include responsibilities.



150 26 2.4.6 145 Table 3 – in some instances one of the asset manager’s suggested delivery agent is “To be determined” however it is not clear for which “next action” this relates to. SI

Please amend/clarify.

Noted. It will be amended to read “To be determined by the CCMA implementation group”, and the table will use lines to make the connection between action and delivery agent clear.

151 30 2.5.3 146

The discussion regarding cost benefit analysis is confusing. Government requires that for its investment in a program that the costs (to Govt) are exceeded by the public benefits. The discussion here does not seem to reflect the reason why we ask for a CBA. Incentives are often offered for activities that have positive cost benefit ratios, as the private benefits may not warrant investment without the public benefits of the activity being contributed to by the Government. SI

Please make this section clearer.

Refer to comment 77.

152 30 159 “intangibles are to be valued through discussion and subjective judgements”. Here there is not mention of with whom and how this was undertaken. CS

Please respond/ address Noted. The discussion was conducted though workshops with SALMIC. The process will be clarified and expanded in Background Report 5.

153 34 2.6.4 147

Monitoring is required within priority areas, however it is still important to have a base level of monitoring in areas outside these priority areas to ensure that catchment condition and change can be adequately assessed over time.

Also aren’t all CMAs currently required to review monitoring programs (via NAP/NHT funding??). This should be reflected in these sections, ie that the CCMA is already facilitating data collation. SI

Please ensure that the monitoring program is inclusive of all areas, with greater emphasis on priority areas.

Please ensure that current region wide monitoring reviews are investigated.

Noted. Background Report 6 discusses the monitoring program. This will be clarified in the final report along with a discussion regarding the SAP’s role in catchment-wide monitoring and reference to the current monitoring reviews.

154 36 153

Second paragraph. The recommendation looks at ‘sign off’ from key stakeholders in a target location to endorse salinity investment. This recommendation could go further than just endorsement as it takes more than a ‘sign off’ to achieve integrated delivery, such as through developing innovative approaches and alignment of projects. NV

Please respond. Refer to comment 103.

155 36 160 The document mentions the endorsement by other stakeholders in the area. But there is no mention of how this was completed — that is the process undertaken. CS

Please respond/ explain & add text document

Noted. This will be further clarified in Background Report 4.

156 42 2.9.5 148

This section should make reference to existing climate change investigations, for example the CSIRO climate change predictions – see CSIRO 2001 Climate Change Projections for Australia www.dar.csiro.au/publications/projections2001.pdf

With respect to observed increases in river salinities over the dry years, statistical analysis can be undertaken to look at trends that are occurring with the influence of climate removed. This kind of investigation will enable the region to determine whether or not these increasing trends will continue when climate returns to a wetter period. SI

Please include climate change discussions based on existing work.

Please consider a management action that looks at salinity trends with the influence of climate taken into consideration.

Noted. The final SAP will be amended to make these changes.

The statistical trend modelling for stream gauging data was only partly completed at the time of the Draft SAP (Background Report 3). The final SAP will refer to this in more detail.

157 45 Appendix 1 149

Monitoring costs are repeated twice in the table of costs.

This table could include desalinisation costs if urban water supply needed to be treated prior to supply. SI

Please delete repeat.

Please investigate water desalinisation costs if considered appropriate.

Noted and will discuss with asset managers.

158 49 Appendix 4 150

The list of resource condition targets has many items that seem to be more appropriate to list as management action targets. For example, Upper West Moorabool no.1 – Establish the cause(s) of rising salinity trends in the Lal lal Reservoir by June 2005. This is clearly an investigation that sits within the MATs time frame and kind of action. Also the actions to establish end-of-valley-targets are management actions – perhaps this should be reflected in the RCTs list as “EoVTs to be determined – see management action”? SI

Please amend the RCTs to ensure that they are not MATs.

Noted. This will be revised in the final SAP.

159 49 Appendix 4 151 Upper West Moorabool no 2 RCT is to maintain EC in Lal Lal Reservoir below 700 EC – is this for 100% of the time or is it OK to exceed this at times? SI

Please clarify if this is 100% of the time or otherwise.

As implied, this is 100% of the time. If not, the RCT would have stated this.

160 52 Appendix 5 152 This table needs to include the units of measure (eg ha, number, km etc). SI Please amend table. Noted



Comments on technical documents, not specifically related to the SAP – Regional Draft.

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162 Perennial pastures TR 8 p 21

161

Technical Report 8 identifies revisiting the role of perennial pastures for recharge control as a high priority.

The comment surrounding this point should be expanded to incorporate the persistence of pastures as an important aspect for consideration in any further investigations. Persistence and management have a significant influence on potential effectiveness. . CAS/DPI


Intention / discussion will be expanded in Background Report 4.

163 20 TR 5

Lake Corangamite 162

There have been numerous reports re. – Management of Lake Corangamite, with another review in progress. Surely there is enough information to make a decision on the management of the lake.

A decision needs to be made one way or the other on drainage schemes and Lake Corangamite. . CAS/DPI


The CCMA did not consider that there was enough information at the time of the Draft SAP. The GHD review underway at the time has now been completed and the CCMA Board are considering the options. The SAP consultants are awaiting direction from the CCMA and will be included in the SAP if decisions are made.

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