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 This note also mentions that they are important to many users in the water source as additional supply. The draft plan proposes to continue to allow water users access to these flows. As far as the IRN, NCC and ACF are concerned, the priorities of the Act clearly determines how this water should be allocated. Under the Water Management Act 2000 the WSP is to determine the environment’s adequate share of rivers as first priority, basic landholder rights second, and the extractive regime last. We object to the reinstatement of Supplementary Access Licences (SALs) and strongly recommend that they be removed from the WSP. Recommendations IRN, NCC and ACF strongly recommend that: • Supplementary Access Licences (SALs) be removed from the Water Sharing Plan for the Murrumbidgee Regulated River Water Source. 1 ACCESS LICENCE TRANSFER GUIDELINES IRN, NCC and ACF are concerned that losses due to seepage and evaporation will be omitted from the total water transfer amount, and be borne by the environment. Part 13 Access Licenses Transfer Guidelines of the WSP are not clear about allocation of water lost through the transfer of water allocations. The Draft SWMOP defines the ‘extraction limit’ in the glossary as: A limit on the amount of water that can be taken from a river for licensed purposes and includes both the water pumped directly from the river or aquifer as well as those volumes diverted from the rivers via irrigation or other channel measured at the offtake point, and therefore includes the transmission loses associated with those diversions. Part 13 Access Licenses Transfer Guidelines are not clear about assessing the environmental impact of water trading within the Diversion Management Unit. Trade in water, up or downstream, and between various water sources can have a range of environmental consequences which should be investigated and assessed prior to trades taking place. Recommendations IRN, NCC and ACF recommend that: • The following Clause should be inserted after Clause 96: “The transfer of water allocations is to account for both the water pumped directly from the river or aquifer as well as those volumes diverted from the rivers via irrigation or other channel measured at the offtake point, and therefore includes the transmission losses associated with those diversions.” • The environmental consequences of trade-in water, up or downstream, and between various water sources be investigated and assessed in a transparent manner before transfers are begun. Minister’s Note: (Part B, p.25) 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 93 (not allowing any trading of supplementary water) because we do not believe that ‘supplementary water’ should exist and it must be taken out of the Plan altogether. • Clause 100 (restricting high security trading); and • Clause 101 (introducing limitations on general security temporary trade). 1 A less desirable solution, would be to quarantine these unregulated flows emanating from tributaries or dam spills (‘supplementary water’) during winter and spring and only allowing them to be pumped during the irrigation season. - 8 -
Inland Rivers Network and Nature Conservation Council submission: Draft Water Sharing Plan for the Murrumbidgee Regulated River Water Source – 14 June 2002 Recommendation IRN, NCC and ACF recommend that: • Clauses 93, 100 and 101 placing restrictions on water trading in the Draft WSP, be removed from the Water Sharing Plan for the Murrumbidgee Regulated River Water Source. SYSTEM OPERATION RULES Flows into the Lowbidgee District Minister’s Note: (Part B, p.27) The Minister’s Note on p.27 of Part B raises specific concerns about the Lowbidgee wetlands. IRN, NCC and ACF are also extremely concerned about the health of these important wetlands. Our primary concern is that the environment’s share of water, and the ecological requirements for the Lowbidgee Floodplain are not part of the WSP. Provision of water to the Lowbidgee District is contingent to irrigation requirements. The Draft WSP allocates the lowest priority water of all water in the water source to this region. At times this water is also of lower priority than water supply commitments to the Murray River. The circumstances and conditions under which water will be diverted into the Lowbidgee District to meet the environmental concerns of the river downstream of the diversion point are not specified at all by the schedule. Quite clearly, this aspect of the plan has not been developed in a manner that is consistent with the Act. Legislation and policy measures usually protect actual sites of wetlands from development but do not control threatening processes upstream. To protect wetland areas, policy and legislation for wetland conservation need to be applied to flow regimes. This necessitates the interaction of policies applied to the floodplain with legislation that governs the management of water. Until there is protection of the flow regimes that define wetlands and their biota, their long-term future, even if they have reserve status, cannot be guaranteed.” (Kingsford and Thomas, 2001, p.73). The Water Sharing Plan for the Murrumbidgee Regulated River Water Source backed up by the Water Management Act 2000 should be the policy and legislation that protects the wetlands of the Murrumbidgee River. It doesn’t. Kingsford and Thomas (2001, p.73) identifies two areas in the Lower Murrumbidgee floodplain protected under conservation legislation and policy. The Yanga Nature Reserve was primarily conserved for its Black Box woodland vegetation and 23 800 hectares of the Lower Murrumbidgee floodplain was protected from clearing. Their long-term prospects are poor because the flooding regime may not be sufficiently frequent to sustain the flood dependent vegetation that established in these areas. This water sharing plan must be the initial mechanism to establish the appropriate flow regimes coming into the Lowbidgee Floodplain Districts in order to sustain the floodplain vegetation established in these two protected areas. Recommendations IRN, NCC and ACF recommend that: • The Water Sharing Plan for the Murrumbidgee Regulated River Water Source must establish and protect appropriate flow regimes coming into the Lowbidgee Floodplain Districts in order to sustain the floodplain vegetation established in the Yanga Nature Reserve and the 23 800 hectares of the Lower Murrumbidgee floodplain protected from clearing. • The environmental health water needed to sustain the Lowbidgee floodplain must not be contingent upon irrigation allocations for the Murrumbidgee and Murray Rivers and must be articulated in this plan. • Environmental Health Water provisions must be stronger in relation to flows to the Lowbidgee area, including contribution of environmental flows from the Lowbidgee areas into the Murrumbidgee. • The WSP for the Murrmbidgee Regulated River Water Source recognises the connection and impacts of water extraction on this area. • The preparation of a Water Management Plan for the Lowbidgee region must be immediately commenced. - 9 -
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Submission on Draft Water Sharing Plan for the Murrumbidgee River

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