Submission on Draft Water Sharing Plan for the Murrumbidgee River

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Inland Rivers Network and Nature Conservation Council submission: Draft Water Sharing Plan for the Murrumbidgee Regulated River Water Source – 14 June 2002 PERFORMANCE INDICATORS Minister’s Note: (Part B, p.27) IRN, NCC and ACF believes it is essential that performance indicators are established to monitor the outcomes of the WSP. These indicators should monitor the biological, chemical, physical, habitat components of each ecosystem. Performance indicators should determine the base line data which will be used to assess the adequacy and performance of the water sharing plans and in turn direct on-going adaptive management. The IRN, NCC and ACF support the Ministers Note in Part 17 requesting the development of performance indicators using those stated objectives. Specifically, performance indicators must be developed for the following factors: Threatened species The WSP must be consistent with the outcomes of the SWMOP. Long term outcome 1.3 states: The diversity and abundance of native aquatic plants and animals protected and improved, by addressing the cumulative impacts of water resource management on their habitats and lifecycles. The status and diversity of aquatic communities to be informed through, but not limited to, the following: • improvements in the abundance and diversity of invertebrate populations. • increase in native fish populations within their natural range, and reductions in the proportion of alien-to-native fish species. • increased colonial waterbird breeding opportunities. • improvements in the status of threatened species, populations and communities. Draft SWMOP Target 2 state: All water management plans to put in place appropriate mechanisms for improving physical habitats, and the diversity and abundance of native animals and plants with particular reference to threatened species, populations and communities. The Fisheries Scientific Committee, established under Part 7A of the Fisheries Management Act 1994, has made a recommendation to list the installation and operation of instream structures and other mechanisms that alter natural flow regimes of rivers and streams as a Key Threatening Process (KTP). Alteration to natural flow regimes can occur through “reducing or increasing flows, altering seasonality of flows, changing the frequency, duration, magnitude, timing, predictability and variability of flow events, altering surface and subsurface water levels and changing the rate of rise or fall of water levels.” The Fisheries Scientific Committee is also of the opinion that: “The installation and operation of instream structures and other mechanisms that alter natural flow regimes of rivers and streams adversely affects more than two threatened species, populations or ecological communities, or could cause species, populations or ecological communities that are not threatened to become threatened. Therefore, this process qualifies for inclusion in Schedule 6 of the Fisheries Management Act 1994 as a Key Threatening Process”. It should be ensured that the provisions within WSP are consistent with the Fisheries Scientific Committee, and this KTP. The WSP Guide identifies the Macquarie Perch, Murray Hardyhead, Olive Perchlet, Silver Perch, Purplespotted Gudgeon, Southern Pygmy Perch and Trout Cod as seven species found in the Murrumbidgee Regulated River Water Source and with a conservation status listed as either endangered or vulnerable under the Fisheries Management Act (NSW) 1994. The Macquarie Perch, Murray Hardyhead and Trout Cod are also listed under the Environment Protection and Biodiversity Conservation Act (Cmth) 1999. All of the species listed under the Fisheries Management Act (NSW) 1994 will have a recovery plan written for them within the ten-year life of the Water Sharing Plan. As the Fisheries Management Act 1994 has concurrence with the Water Management Act 2000 the WSP must, at the very least, acknowledge that these statutory - 10 -
Inland Rivers Network and Nature Conservation Council submission: Draft Water Sharing Plan for the Murrumbidgee Regulated River Water Source – 14 June 2002 documents will be coming on line during the life of the WSP. These recovery plans may identify the requirement for additional water in order to facilitate the recovery of these species, and this plan must be able to provide for such requirements. There is not sufficient reference to these species, key threatening processes, threat abatement plans and recovery plans in Part B of the WSP. This is concerning, because this is the only part of the plan that is statutory. Recommendations IRN, NCC and ACF recommend that: • The threatened species identified in the WSP Guide be listed as Schedule 9 of the Water Sharing Plan for the Murrumbidgee Regulated River Water Source. • Provision should be made within the WSP for additional water, as identified by a Threatened Species Recovery Plan, to be made available without the requirement to pay compensation to water extractors. • Minimum flow sharing should at the very least provide for passage of native fish over riffles, and past instream obstructions such as weirs or road crossings, particularly during breeding times. • Part B of the WSP acknowledges the relevant recovery plans and facilitates relevant implementation of threat abatement plans and recovery plans where threatened species, populations and communities occur. Flow arrangements should be consistent with threat abatement plans and recovery plans. • Part B of the WSP acknowledges Key Threatening Processes (KTPs) and reduce or ameliorate the impacts of KTPs wherever possible. Given the importance of threatened species recovery, this should exclude any potential for compensation to water users. • Threatened species considerations should be incorporated in Part 14 Performance Indicators, as part of the species presence and absence indicators. Water Quality IRN, NCC and ACF are concerned that no mention is made about water quality, the monitoring regime that will be carried out and the standards that will be applied in the monitoring program. IRN, NCC and ACF believe that water quality monitoring should be consistent with ANZECC guideline ‘trigger values’ as outlined in the SWMOP. Recommendations IRN, NCC and ACF recommend that: • Water quality should be monitored in accordance with ANZECC guidelines. Monitoring The Water Management Act 2000 provides for review of a WSP within the fifth year of its tenure so as to ascertain whether it remains ‘adequate and appropriate’ for implementing the Water Management Principles of the Act. In addition the Act provides for auditing of plans. The Integrated Monitoring of Environmental Flows (IMEF) inter-agency monitoring program commenced in 1998, with the first stage due for completion in 2003. IMEF data reported thus far has provided a useful basis for critically appraising the effectiveness and adequacy of current environmental flow rules. If the IMEF is to guide the delivery of environmental flows there must be sufficient flexibility within the ten-year tenure of the WSP. This could be most usefully achieved with a provision exempting Government for compensating water users for reduced allocations if the monitoring results clearly indicate a need to increase environmental allocations. - 11 -
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Submission on Draft Water Sharing Plan for the Murrumbidgee River

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