To:Mr Craig Knowles, Chair, Murray-Darling Basin Authority
From: EFN, Friends of the Earth, Goulburn Valley Environment Network, Inland Rivers Network, Nature Conservation Council of NSW, National Parks Association of NSW, National Parks Australia Council, and The Wilderness Society
Made: 29 April 2011

We'd like to congratulate you on the energy and enthusiasm you've shown in getting out and talking to Basin communities on the ground since your appointment as the Chair of the Murray Darling Basin Authority.
There have recently been a number of developments in the reform process which we would like to provide some feedback on. In particular, we note the following:

  • There have been media reports that State Governments have been asked to consider a figure of 2,000 GL for return to the environment.
  • There have been indications that the dates for compliance of state water resource plans with the Basin Plan will all be aligned at 2019, which represents a very substantial delay for states such as NSW and Victoria.
  • The concept of 'localism/regionalism' has been given considerable attention in relation to Basin reform by yourself and the Ministerial Council.
  • The concept of cultural flows being returned to Indigenous Traditional Owners is still not widely canvassed and has not received much attention.

We believe that the scientific credibility of the Basin Plan is paramount to both meeting the requirements of the Water Act 2007 and achieving a firm basis for implementation. We have not as yet had a clear view from the MDBA as to what scientific methods are currently being applied to derive sustainable diversion limits, and/or what changes have been made to the methods utilised in the Guide.
We recognise that the scientific expertise on these matters is spread widely across academia and government agencies, and would like to ensure that expertise is applied in the most effective and transparent way possible. Therefore, we recommend that:

  • A Basin Plan scientific advisory committee is urgently established to ensure that the best available science is used in the production of the final Basin Plan. The Water Act 2007 provides the statutory basis for establishing such a committee.
  • The advice provided by CSIRO in their submission to the Guide to the Plan is utilised to improve the science underpinning the final Plan, and CSIRO are actively engaged in the process.
  • The most recent scientific work on salinity and the health of the Lower Lakes and the Coorong is implemented in the final Plan.

Transition processes and timeframes
We understand that there is a natural tendency for Governments to seek to align the dates for water resource plans across states to comply with the Plan. However, that does have real consequences for delivery of water to the environment and for final implementation of reforms.
Whilst we are very supportive of a fair adjustment process for affected communities, we are concerned that there is a drift occurring towards a major change in dates, without any explanation of what this means for the transition or for the ultimate application of the Plan. For example, if water resource plans are delayed to 2019, and temporary diversion provisions are then applied at that point, it could mean that substantive implementation of the Plan would not begin until at least 2024.
Therefore, we would like to request that a clear and detailed proposal is developed in relation to how the transition will be managed for state water resource plans and released by the MDBA so that stakeholders can provide a considered response to it.

It is well recognised that the primary driver for the development of the Water Act 2007 by the Federal Government was because the cumulative effects of decades of parochial interests and decisions made at state, regional and local levels had undermined the health of the Murray-Darling Basin, leading to the need for Commonwealth intervention.
Therefore, environment groups are very concerned about the recent revival of undefined 'localism' as the answer for the Murray-Darling Basin. In Attachment 1 we have provided a briefing on the issue and set out a number of recommendations and principles that we would like to see adopted if the concept is pursued. We would greatly appreciate an opportunity to discuss those principles with you prior to decisions being made on these matters.

Cultural Flows
Environment groups support the concept of cultural flows for Indigenous Traditional Owners in the Murray-Darling Basin. We believe that the Basin Plan can provide a vehicle for recognising and delivering cultural flows for Traditional Owners. We would like to encourage the MDBA to work with Traditional Owners and experts in the field to develop a substantive proposal for incorporating cultural flows into the Basin Plan. We understand that the Basin Community Committee has considered this issue, and hope that you will give their advice due attention.

Return to Submissions page

Original Site Design: Brown Ink