To:Murray Darling Basin Authority
Proposed Basin Plan  Draft for Consultation 

Date : 14 February 2012

EFN supports the need for a Basin Plan and has been a contributor to the consultative process at all stages to date.

We are supportive of optimising socio-economic outcomes, but not at the expense of a healthy and sustainable Murray Darling River system. If the Basin Plan adopts a SDL compromised by socio-economic, and other constraints then the 2015 review must be open, transparent and with the ability to adjust this SDL both upwards and downwards.

We consider much of the socio-economic input to be based on unsubstantiated concerns and flawed methodology and fails to take into account on-farm productivity gains made during the past drought, from delivery and on-farm infrastructure up-grades and the much improved flexibility of water reform policies.

There is ample water with-in the Basin to achieve a strong Basin Plan that will both ensure the protection and restoration of water-dependant ecosystems and the functions of those systems and continued productivity and economic growth. We offer the following comments:

  1. The MDBA consultation process for the Proposed Basin Plan has been an improvement on past experience however many targeted regional meetings have been dominated by Industry groups and local politicians. It is important to understand the peer group pressure many minority groups have come under in local regional areas and in particular in open meetings with the MDBA.
    These groups need to be given the opportunity to openly discuss issues without the pressures and domination of vested interests.
  2. The Water Act 2007, its statutory obligations and environmental objectives have not been complied with by the Proposed Basin Plan.The degree of primacy afforded to the environment in the Water Act has been clearly compromised in Chapter 5 of the Draft Plan. The Water Act 2007 requires the Basin Plan to optimise social and economic outcomes after ensuring the protection and restoration of water-dependant ecosystems and the functions of those systems.
  3. The 2750 GL increased environmental flows proposed to achieve SDL in the Basin Plan appears to be an arbitrary figure.
    This proposed reduction in water available for diversion lacks the transparency needed for the community to clearly understand what constitutes the minimum science based SDL required to protect and restore the river system, and to what extent this figure has been discounted by social, economic and flow constraint considerations in the Plan’s development.
    Without this basic information and ability to track and judge the weighting given to these competing influences, informed community input has been made impossible.
    This is particularly true in the case of groundwater extractions.  Supporting data for greatly increased extractions is not available
  4. Socio-economic assessments
    There has been much comment about the negative impacts on the economy and social well being of the Basin if a large amount of water is reserved for environmental purposes, but this needs to be balanced by the considerable positive benefits, particularly long term.  For example, the full economic benefit of ecosystem services provided by the 18 Ramsar Sites to healthy rivers is believed to be in excess of $2.1bn. Regional economic benefits of improved flows, enhanced environment and infrastructure upgrades on regional economic and social activity should also be included in all assessments.
    The proposed 2015 Review should have the scope to revisit not just environmental outcomes of the Plan but also the socio-economic and constraint inputs in the Plans development that have resulted in a compromised SDL.
    The SDL must have the capacity to be adjusted up or down as the result of the 2015 review.
  5. Constraints should not be treated as barriers and pressure and incentives should be applied to the States to actively propose works or other measures to achieve necessary environmental flows.
    Central to the implementation of the Basin Plan in the lead-up to the 2015 review point is consideration of how existing river management arrangements and environmental works and measures could be addressed to improve the efficiency and effectiveness of delivering environmental water.
    Easements or other arrangements with landholders could increase significantly to allow high overbank flows which are necessary for achieving many environmental outcomes, particularly for floodplain and riparian health.
  6. Localism and adaptive management has been well accepted by most communities but does not absolve the Authority of leadership in the setting of SDL’s across the Basin.
    Local input will be a valuable input to the development of State Water Plans but the setting of SDLs must remain with the MDBA.
  7. Compliance provisions in the Basin Plan are weak.
    The concept of SDLs is an artifact and was developed to fit a legal framework ie the Water Act 2007. The concept does not reflect environmental reality in that the SDL should change in relation to annual flows not an average. The concept protects SDL’s at the expense of environmental entitlements in drying catchments suffering the effects of climate change and predicted lower inflows.
    Compliance provisions could further disadvantage environmental water deliveries.
    One major concern is that States will only be considered to be non-compliant with the SDL’s if they have exceeded these by more than 20% in a given year and if they do not have a reasonable excuse. There are two problems with this:
    Firstly 20% is a huge compliance buffer – a State could exceed its SDLs in every water resource area by 19% every year and still be compliant with the Basin Plan, and secondly if States exceed the SDL by more than 20% but have a ‘reasonable excuse’ they cannot be considered to be noncompliant.

We believe the Proposed Basin Plan as presented can be strengthened to ensure the protection and restoration of water-dependant ecosystems and the functions of those systems.

Irrigation productivity will continue to increase, with improved technology, the benefits of water reform policies, and infrastructure upgrades both on-farm and delivery, leading to growing economic growth across the Basin.
With storages filling and improving commodity outlooks it is hard to imagine a better time to begin the transition to a sustainable Murray Darling Basin for this and future generations.

The Basin Plan should not be further delayed,

John Pettigrew

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