To: Environment and Communications Legislation Committee Secretariat

Inquiry into the Water Amendment Bill 2015

Date : 28 July 2015

We are concerned the proposed amendments included in the Water Amendment Bill 2015 put at risk the delivery of  sustainable diversion limits (SDL's) set through the Murray-Darling Basin Plan.

Our concerns are based on the availability of future projects and funding to achieve the required water savings to achieve the agreed SDL’s without maintaining the flexibility of water purchased directly from entitlement holders.

Government audits have repeatedly found the purchase of entitlements to be the most cost effective mechanism of water recovery. The current Government’s decision to cap buy backs is clearly an enforceable political decision, however should not be included in legislation which would remove management flexibility in a very much uncertain future.

Infrastructure upgrades and on-farm efficiency measures are becoming prohibitively expensive, as the market prices of water, both permanent and temporary escalate.

With current water prices many irrigators are taking the decision to self-fund on-farm efficiency upgrades and retain water entitlements for trading into the future.

This pricing trend will continue with the expansion of high value crops such as cotton into the Southern Murray Darling Basin.

Also of concerned is the Bills lack of clarity surrounding the calculation of the ‘long term annual average quantity of water that can be accessed’? What is the definition of this long term annual average quantity of water and does it align with the 1162GL water already recovered on The Department of Environment’s website.

Imposing a legislated limit on water purchase has the potential to severely compromise this and future government’s ability to ‘bridge the gap’ to the SDL's. 

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