To: Draft Western Region Sustainable Water Strategy

Made: May 2010

EFN represents farmers in south-east Australia interested in sustainable farming in a social, environmental and economic sense. We represent mostly commercial farmers very concerned about the impact of climate change on farms, people and landscapes, loss of farm biodiversity and the loss of farmland and relatively natural areas to urban expansion. In particular, we encourage strong greenhouse gas mitigation and adaptation to climate change. We strongly support State and Federal Governments developing market mechanisms that reward those landholders providing ecosystem services such as retention and protection of biodiversity on farms and carbon sequestration.

Overall Comments:
EFN values the approach of the sustainable water strategies. We feel that they not only are a logical way to develop both sustainability and equity in the utilisation of water but they also serve as a powerful framework for what farmers need to consider, and do, at the property level.

Climate change will continue to impact severely on future rainfall, runoff and recharge events. Hence any allocation of resources for any purpose other than environmental purposes will need to be extremely conservative to avoid unforseen detrimental consequences. Historically water resource allocation has favoured development first and the environment last.  When making future decisions about allocation of such a scarce resource, the broad-scale health of groundwater systems and rivers should be given priority.

For example the projected savings from building the Wimmera Mallee pipeline is about 103 000 mega litres (ML) with 80 000 ML to go to the environment. These figures are based on historic rainfall and runoff data and are extremely unlikely to eventuate. In which case the water allocated to growth should be forsaken and all savings allocated to environmental protection of major streams and ground water reserves.

The health of many major waterways in western Victoria is dependent on base flows of mostly saline groundwater. (Examples are the Hopkins River, Fiery and Mt Emu Creeks.) For this reason it is imperative that any activities that could affect groundwater levels of unconfined shallow groundwater systems be monitored and controlled.

Our main concerns are:

  • Potential over-allocation of water resources especially groundwater (some groundwater resources are already over-allocated for commercial use). We suggest that no further allocation of groundwater reserves occurs for at least 20 years until we know more about climate change impacts in the region.
  • Impact of landuse change on groundwater recharge, shallow ground water use and runoff to streams and wetlands (eg large scale planting of blue gums, native vegetation for carbon offsets, canola, cereal crops)
  • Ensuring a fair share of water resources for environmental protection of streams and wetlands with predictions of further rainfall reductions over the next 50 years (eg water savings from Wimmera Mallee pipeline)
  • The impact of farm dams on catchment health especially where more intensive development occurs (eg rural residential development around townships such as Hamilton, Beaufort, north Ballarat, Ararat)
  • The determination of stock watering requirements, water collection options, water storage allowance, and related efficiencies. These all need to be related to the capability of different land types. The need becomes even greater in an environment of changing climate.
  • The impact of climate change, current farming practices and past drainage work on major stream and wetland health

Specific Comments

Chapter 4: Securing the Regions Water Resources
PP 4.1 Agree with recognising existing rights.
PP 4.2 Agree with recognising sleeper rights but suggest not renewing licences where water not used during licence period.
P 4.1 Agree with improving information share on climate change data.
PP4.3 Agree with improving local management rules.
P4.2 Agree with developing local management rules for groundwater and unregulated river systems.
P4.3 Agree with state wide guidelines for licensing of groundwater and unregulated supplies.
P4.4 Agree with developing Water Supply Management Plans.
P4.5 Agree with managing activation of sleeper licences by limiting water use or declaring Water Supply Protection Areas.
P4.6 Agree with market development and education actions.
P4.7 Agree with clarification of trade opportunities in unregulated systems but question why licences are issued if most streams are already at their sustainable diversion limits and with predicted flows to continue to decline.
P4.8 Question why any further allocation of water is considered as most streams and ground systems are already at or near their sustainable diversion limit. Sustainable diversion limits are calculated on historical flows which are outmoded.
Question for comment Page 80. Suggest a high reserve price for new licences, reflecting the environmental value of water. Why should any more licences be issued at all if waterways are already stretched to or beyond their healthy limits, and lower rainfall is predicted?
P4.9 Given the continuing impact of climate change we agree with the review of water supply demand strategies.
P4.10 Agree with review of “drought” response plans.
P4.11 Agree with review of Victorian Uniform Drought Water Restriction Guidelines: urban water authorities should be encouraged to trade water rather than relying on qualification of rights to secure water at the environment’ expense.
P4.12 Agree with water corporations assisting local government with integrated water planning.
P4.13 Agree with seeking highest community value use for recycled water. This may be putting it back into a waterway (currently against EPA guidelines).
P4.14 Agree that water corporations should work with local government to minimise potential health risks of grey water usage.
P4.4 Agree with managing stormwater to reduce flood risks as long as local waterways are not flow impacted. Disagree with using storm water as an alternative water source if it takes water from streams.
P4.15 Agree with Managed Aquifer Recharge if it isn’t taking additional water from streams and wetlands.
P4.16 Agree with DSE and EPA developing guidelines and licensing arrangements for desalination systems.
P4.17 Agree with improving connectivity of reticulated systems.
PP4.5 Agree with structural works to maximise benefits of environmental watering.
PP4.6 Agree with using consumptive water en route for environmental and social purposes.
P4.18 Agree with developing guidelines for 4.6.
P4.19 Agree with establishing a Victorian Environmental Water Holder.
P4.20 Agree with establishing management plans for the upper Wimmera, Gellibrand and Merri Rivers.
PP4.7 Agree with exploring opportunities to deliver multiple benefits through local planning.
P4.21 Agree with seasonally adaptive approach to river and wetland management.
P4.22 Agree with reviewing and changing environmental management objectives if climate changes dictate this.

Chapter 5: Improved Groundwater Management.
PP5.1 Agree with improved approach.
P5.1 Agree with revising Groundwater Management Units (GMU’s).
P5.3 Agree with seasonal reductions in GW use if necessary. Farmers need to know what their allocation is in a timely manner. These allocations need to be adhered to for the season.
P5.3 Agree with groundwater restrictions to protect groundwater reserves.
P5.4 Agree with setting management objectives for GMU’s.
PP5.2 Agree with the process outlined to reduce Permissible Consumptive Volumes (PCV’s).
P5.5 Agree PCV’S could increase under certain conditions.
P5.6 Agree with setting PCV”s for new GMU’s.
P5.7 Agree that groundwater dependent ecosystems be managed using a risk based approach.
PP5.3 Agree that climate change impacts be included in resource appraisals.
PP5.4 Agree that systems with high groundwater and surface water interactions have integrated management plans prepared.
P5.8 Agree that the above systems include those identified in the National Water Commission study.
PP5.5 Agree that intensive monitoring of groundwater where commercial use is high should be on a beneficiary pays basis.
P5.9 Agree that groundwater trading should be facilitated in intensive use systems.
P5.10 Agree that DSE should encourage development of arrangements with SA to trade and manage groundwater in the same GMU.
P5.11 Agree to carryover of groundwater entitlements providing no detrimental environmental impact.

Chapter 6 Accounting for all significant water uses.
1. Different sources of stock and domestic water should be managed as best suits each method. However there should be a consistent set of principles underlying any management rules. If rainfall and runoff continues to decline Government will need to manage stock and domestic water collection more actively. Programs to assist landholders rationalise and redesign stock water systems to minimise environmental damage and provide reliable water supply may be needed.

2. Current Government management of farm dams is inadequate particularly in closer settled semi urban areas. The impact of constructed large recreational lakes is also affecting stream flows and wetlands. For example Green Hill Lake at Ararat which was deepened, enlarged and had its outlet raised in the early 1980’s has reduced flood events on the upper Hopkins to almost zero and reduced annual river flow. This has exacerbated silting of high value habitat deeper waterholes containing platypus.

3. Regulation of farm dams is required as a matter of urgency in some areas.

4 & 5. Current management levels for saline groundwater systems for domestic and stock use is probably adequate but high use priority areas with better water quality should be managed more strictly (number and quantity regulated). There is an emerging issue of the use of small desalination plants and the consequent disposal of brine.

6. Groundwater use in urban reticulated water supply areas should be eliminated/banned or the overall pricing and restriction policies should be integrated. No double dipping!

Landuse Change

1. High water use activities should be regulated as to their size and placement in sub catchments to minimise impacts on the environment and neighbours. That is, they should be part of a catchment plan to deliver ecosystem services (eg salinity abatement and biolinks) for the general good not create environmental and social problems for many (minimal groundwater recharge and runoff to rivers).

2. Government should be able to target areas to control landuse. In fact the Catchment and Land Protection Act 1994 allows this to happen already but Government has chosen not to use these farsighted and substantial powers already at their disposal!
This legislation also caters for the relativity between public good and private good to ensure that the responsibility and benefits are adequately allocated.

3. When do we take action to regulate landuse? It depends on many factors including groundwater resource quality, recharge characteristics, stream flow impact, downstream effects, area of new crop in sub-catchment, etc. Changed flow regimes should be measured and monitored and significant changes to flow require regulation.  The concept of land capability and capacity for ecosystem service delivery should be a key plank in working through options for regulating land use.

4. If the existing landuse in a sub-catchment/aquifer is unsustainable then the unsustainable landuse practices should be identified and long term sustainable limits be set for landuse allowing planning permits to achieve sustainable levels over the long term.

Managing rural drainage

1. Drainage schemes have greatly reduced wetland habitat over large areas. A targeted ecosystem service approach by Government to encourage private landholders to restore and manage wetlands for biodiversity and other benefits is desirable.

2. Drainage schemes have altered regional hydrology in many areas causing land to salinise, erosion issues, increased flows into some areas whilst destroying major wetlands in others.

3. The need to maintain some drainage schemes will lessen with climate change reducing runoff and increasing evaporation rates.

4. We need a targeted approach to addressing past mistakes to increase the variety and extent of wetlands across the western region  concentrating where rainfall is predicted to be more reliable in putting water back into reclaimed wetlands.

5. The cost of maintaining drainage schemes should be met by those that benefit from them.

Peter Forster


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