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 • The current Supplementary Environmental Water must be changed to Class A Environmental Health Water (EHW), so that this water is assured for environmental purposes and in no way contingent upon irrigation allocations. EHW stored for managed release should be increased to 100 gigalitres (GL) per year, which is considered by environment groups to be the minimum amount required to maintain the health of the river and its wetlands. The groups envisage that the 100GL EHW volume would not necessarily have to be released each year, but should be able to be stored, and released contingent upon environmental triggers. There is significant ecological benefit in releasing some water following a natural ‘fresh’, with further releases after two weeks depending upon tributary flows. A regime such as this will ensure wetlands are adequately inundated further downstream. • An environmental flow sub-committee should be formed to oversee the management of environmental water. This could include representatives from local environment groups (such as the REC), DLWC, EPA, NPWS, State Forests, scientists and indigenous interests. They would consider tributary inflows in deciding on the timing and volume of water released and incorporate triggers and protocols for managed releases ensuring adequate environmental water. This could be included as an additional Schedule 9 to Part B of the Draft WSP. • Translucent release rules in the Draft WSP only apply to the area below Burrinjuck Dam to the confluence of the Tumut River. The environment groups believe that new translucent rules need to be developed which are simpler and have dam release triggers that are environmentally and hydrologically sound. • The Draft WSP has not put in place appropriate targets to provide for the recovery of threatened species, populations and communities and their future removal from threatened species listing. The objective to promote threatened species recovery is conditional in the Draft WSP, and there is a low probability that this will prevent the continued decline of populations. The environment groups recommend that Part B of the Water Sharing Plan include a schedule of threatened species and facilitate implementation of threat abatement plans and recovery plans where these species occur. Recovery Plans must be produced pursuant to the Fisheries Management Act 1994 within three years of gazettal and the WSP should be amended to be consistent with recommendations made therein. The environment groups recommend that the Draft WSP acknowledge Key Threatening Processes and reduce or ameliorate these impacts. • Schedule 8 flows, which determine when water is diverted into the Lowbidgee Floodplain District are totally inadequate in the Draft WSP and do not account for, or protect environmental water. Further, the seasonality required for ecosystem function is not considered. IRN, NCC and ACF recommend that Schedule 8 flows in this WSP for the Murrumbidgee Regulated River Water Source must make provision for environmental water flows and its seasonality into the Lowbidgee Floodplain Districts. • An environmental flow sub-committee should be formed to oversee the development of a water management plan for the Lowbidgee Floodplain Districts. This could include representatives from local environment groups (such as the REC), DLWC, EPA, NPWS, State Forests, scientists and indigenous interests of environmental water. • The Draft WSP has not established adequate flow rules and extraction limits in relation to interim targets 2 and 4 of the Draft State Water Management Outcomes Plan. The WSP must be consistent with these requirements. BASIC LANDHOLDER RIGHTS Native title rights Advice No. 14 to Water Management Committees outlines the Committee’s role with respect to Aboriginal issues and cultural heritage protection. The Committee’s role is to identify Aboriginal cultural and heritage values and provide recommendations on how to protect these in their area as far as they relate to water sharing. Therefore the plan must include: - 6 -
Inland Rivers Network and Nature Conservation Council submission: Draft Water Sharing Plan for the Murrumbidgee Regulated River Water Source – 14 June 2002 • consideration of the Aboriginal Heritage Information System register of sites and Aboriginal places. • habitat requirements for totemic and other culturally important species, including threatened species in the water management area. • consideration of contemporary Aboriginal needs and uses of water and related water resources. Whilst IRN, NCC and ACF are in full support of water allocations for indigenous purposes, we strongly oppose such water being taken from the environment. As such we believe that Part 5 ‘Basic landholder rights’, and specifically Clauses 27, 28 and 31, [a formatting error exists at this point as Clause 29 and 30 are not included] need to be strengthened in terms of their treatment of native title rights. Recommendations IRN, NCC and ACF recommend that: • The following clauses be included after Clause 31: − “A native title holder in relation to waters of the water source is entitled, under the provision of Section 55 of the Act, to take and use water in the exercise of native title rights.” − “Should native title rights that extend beyond those which are provided for in the Water Management Act 2000, or in this Water Sharing Plan, be found to exist in a court of law, this plan will be reviewed and amended accordingly under Section 42(2) of the Water Management Act 2000.” − “At the commencement of the Plan no native title rights have been granted for the Murrumbidgee Regulated River Water Source” − “The Plan recognises that the exercise of native title rights, as defined in Section 55 of the Act, may increase during the term of this Plan” − “Any granting of water allocations under native title rights must be allocated from the BEV for each flow class and cannot impact upon the agreed EHW allocations”. • Evidence should also be provided of having considered the Aboriginal Heritage Information System register of sites and Aboriginal places, or the habitat requirements for totemic and other culturally important species, including threatened species in the water management area. MANAGING ALLOCATIONS TO REGULATED RIVER (HIGH SECURITY) AND REGULATED RIVER (GENERAL SECURITY) ACCESS LICENCE HOLDERS Minister’s Note: (Part B, p.19) IRN, NCC and ACF support the CoAG concept of water trading which is that water should be used “to maximise its contribution to national income and welfare, within the social, physical, and ecological constraints of catchments” (1994 CoAG Agreement, Clause 5[a]). We believe that this facilitates the flow of water to the highest value uses where there are greater incentives to conserve water. As such, we oppose Clause 75(h), which places a constraint on temporary trade of water through the forfeit of carryover and access to supplementary water. Recommendation IRN, NCC and ACF recommend that: • Clause 75(h), which places a constraint on temporary trade of water through the forfeit of carryover and access to supplementary water, is removed from the Water Sharing Plan for the Murrumbidgee Regulated River Water Source. MANAGEMENT OF SUPPLEMENTARY WATER Minister’s Note: (Part B, p.22) IRN, NCC and ACF agrees with the Minister’s Note Part B, p.22 that unregulated flows emanating from tributaries or dam spills are potentially very important for the ecological functioning of the river system. These flows significantly impact on the environmental benefit of natural ‘freshes’ and dam spills, and should be omitted from the Draft WSP. These licences have been cancelled in the past and we see no reason why they should be considered again. Extraction from ‘freshes’ and spills will also diminish the effectiveness of stored environmental releases throughout the river system, particularly in the lower reaches. - 7 -
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Submission on Draft Water Sharing Plan for the Murrumbidgee River

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