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 INTRODUCTION IRN, NCC and ACF recommendations for additional targets and word changes are listed below. We believe they will enhance the scope of the clauses and their ability to achieve the ‘SMART’ objectives. Applying the ‘SMART’ principle is essential in developing an effective WSP. This means clauses are: • Specific − within the sphere of influence. − expressed in biophysical terms. • Measurable − clearly defined. For example, targets with percentages. Where qualitative words are used a definition should accompany them. − relative to an existing baseline or trend. • Achievable: − within the bounds of realistic resourcing, ensuring that monitoring, capability and commitment are available. • Relevant − consistent with relevant legislation and strategies. • Timebound − defined within a delivery date IRN, NCC and ACF recommend that where scientific knowledge is lacking, the Precautionary Principle should be applied to protect the water source and its dependent ecosystems. The development of adaptive Management systems and research to improve understanding of these ecosystems is essential to their management. ADAPTIVE MANAGEMENT Inland rivers in New South Wales have often highly variable and unpredictable flows. Changes to flow patterns can have significant ecological effects that may not be noticed for many years or even decades. Water management needs to be sufficiently adaptive to these natural and human induced changes, in order to maintain our rivers in an acceptable state for current and future generations. The 1994 Council of Australian Governments (CoAG) Water Reforms Framework states that “… environmental requirements … be determined on the best available scientific information available” (Attachment A (4)(d)). The CoAG Water Reforms Frameworks also states that “… jurisdictions would consider establishing environmental contingency allocations which provide for a review of the allocations five years after they have been determined”. Basing environmental requirements on the best available scientific information and regular review of environmental flow provisions is essential for ensuring that the Water Management Act 2000 objectives of protecting and restoring aquatic ecosystems are implemented. IRN, NCC and ACF are concerned that this Draft WSP does not contain adequate provisions for adaptive management. Section 42(2) of the Water Management Act 2000 allows WSPs to specify the circumstances by which a plan may be changed within its ten-year tenure, without attracting compensation to entitlement holders. IRN, NCC and ACF believe that there are a number of issues and processes relevant to the Murrumbidgee Regulated River Water Source that will impact upon water sharing, and must be incorporated into the Plan as they arise. In Part A Section 2, page 3 of the WSP guide it is stated that: “The Water Sharing Plan will become a statutory plan under the Water Management Act 2000 and be in effect for a 10 year period, thereby providing security of access for environmental water and for all water users during its term. Further to this, holders of water access licences will be able to claim compensation if water access is reduced during the term of this plan, as a consequence of variation to the bulk access regime established by the plan, for purposes not specified by this plan.” change made to the Plan during its term reduces the water available for extraction”. - 2 -
Inland Rivers Network and Nature Conservation Council submission: Draft Water Sharing Plan for the Murrumbidgee Regulated River Water Source – 14 June 2002 If it is shown that there is not enough water allocated for the protection of the environment, IRN, NCC and ACF believes there must not be any compensation due to the paucity of data regarding the nature of the watercourses and flow patterns, as well as the nature of the requirements for the environment. The WSP and the WSP Guide do not contain provision for flexibility in the face of possible reductions in available water, likely to arise from climate change or other catchment/landuse practices that may increase water use. Nor does it contain provisions for specified amendments relating to threatened species, flow provisions, environmental health water or the impact of a significant water quality incident. IRN, NCC and ACF are also concerned that flow rules to protect pools during the drier months are not sufficiently adaptive. It is imperative that flows be adaptively managed within the ten year tenure of the Water Sharing Plans as provided for by the Water Management Act 2000 Section 5(2)(h). Adaptive management provisions have been included in WSPs prepared for groundwater and unregulated water sources, and the environment groups can see no reason why they should not apply to regulated systems such as the Murrumbidgee River. Further, Clause 4 of the 1994 CoAG framework requires an adaptive management approach. Recommendations IRN, NCC and ACF recommend that: • Provisions for flexibility under Section 42(2) of the Water Management Act 2000 are allowed for in the Murrumbidgee Regulated River WSP without attracting the need for compensation in the following circumstances: − the Murray interstate flows process. − the needs of Ramsar listed wetlands and wetlands of national importance. − changes in water source hydrology as a result of catchment land use changes or climatic changes. − provisions for specified amendments relating to key threatening processes; threatened species recovery and threat abatement plans threatened species (in particular the Trout Cod recovery plan). − provisions for specified amendments relating to environmental health water or the impact of a significant water quality incident (such as salinity or blue-green-algae blooms). − monitoring and research programs (such as IMEF) − exercise of native title rights to water allocations for indigenous purposes. − future information about the social and economic impacts of changing environmental conditions. • Flows are adaptively managed within the ten-year tenure of the Water Sharing Plans as provided for by the Water Management Act 2000 Section 5(2)(h) without attracting the need for compensation. ENVIRONMENTAL WATER It is generally acknowledged by freshwater ecologists that water is the most critical component of healthy riverine ecosystems. The IRN, NCC and ACF is concerned that in spite of the extensive process of community consultation, there still appears to be a fundamental lack of understanding about the role of water in maintaining healthy riverine ecosystems. This is reflected in some of the recommendations from the Murrumbidgee Regulated River Management Committee in the Draft WSP for the Murrumbidgee Regulated River Water Source. All ecosystems require an input of energy to function. Land-based ecosystems derive this energy directly from the Sun through the process of photosynthesis. Rivers however, particularly those in the upper catchment, do not have enough green plants within them to supply sufficient energy for the requirements of aquatic animals (fish, yabbies, mudeyes, etc.). Rivers therefore have to rely on inputs of organic material in the form of leaves, bark, twigs and branches, from their riparian and floodplain zones. Some of this material either falls into the river or is blown in. Most however is carried in by medium to high flows (lateral or floodplain connectivity). Macroinvertebrates process this material, and they in turn, are eaten by fish. This is the most important reason behind the EPA’s River Flow Objectives 3-7. (River Flow Objectives 1-2 ensures that aquatic life survives dry periods and droughts). - 3 -
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Submission on Draft Water Sharing Plan for the Murrumbidgee River

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