To: Murray Darling Basin Authority.
Submission on the Northern Basin Review

Made: 16 February 2017

Critics of the Basin Plan would have us believe the plan is all about flows to the Lower Lakes in SA, but this ignores the benefits of achieving a base environmental health throughout the Basin for all industries and communities including the Northern Basin.
We have concerns with the Northern Basin review process, many of its assumptions and recommended actions to “offset” a recommended 70 GL. reduction of essential flows.
 The 390 GL for the environment was a compromised agreed figure based on scientific analysis and evidence that would improve the “likelihood” of a sustainable working river system with-in the Northern Murray Darling catchment. Even this 390 GL figure clearly fails to ensure Australia meets obligations under international treaties and arguably should be higher.
Socio-economics is a contested science which has in our view been called into question by the production of industry and regional sponsored studies that have not only “informed” the development of the Basin Plan but now seek to influence the implementation of the Plan.
Many of these studies are based on “business as usual’ assumptions and fail to take into account changing industries, technologies, and climate and irrigation practices.
We believe the Northern Basin Review has failed to not only address the above pitfalls but also failed to sufficiently address the economic benefits of floodplain grazing, recreational fishing and tourism and the wellbeing of downstream Northern Basin communities.
The Northern review appears flawed in that it has concentrated on perceived impacts to isolated communities and industries and failed to consider the total Northern Basin, its industries , communities and particularly aboriginal communities who have strong spiritual and cultural connections to the rivers and wetlands.
The Basin Plan came about and was predominately based on the need to return flows previously over-allocated to the Basins Rivers. The introduction of a “toolkit” of Complementary Measures as a substitute for these flows is in direct conflict with the intent and integrity of the Plan.  With past experience it is hard to believe that NSW who have failed to even develop shepherding rules for E-flows, would honour undertakings included in the toolkit. How could this be guaranteed?
 Any reductions of environmental water held in the Macquarie and the Gwydir Rivers have a significant impact on the future of the internationally recognised Macquarie Marshes and Gwydir Wetlands. These wetlands are listed nationally and internationally as important bird areas that support a diverse range of waterbird species and protection should not be reduced. Modelling used in the review overrides current experience and current volumes required to meet the Plans environmental targets.
The proposal to reduce the shared environmental flows to Menindee Lakes by over 100 GL has the capacity to impact on available water through to South Australia and the Murray mouth.
The risk of water quality degradation across the Basin as a result of the proposed 70GL reduction is real, and potential impacts will not only be restricted to the Northern Basin.  Any degradation of water quality resulting from reducing environmental flows appears to contravene Chapter 9 of the Basin Plan.
EFN members are concerned the integrity of the agreed Basin Plan has been jeopardised by the NSW Governments   Barwon-Darling Water Sharing Plan, adopted in 2012.This together with the NSW Governments failure to protect the Commonwealth Environmental Water Holder’s  (CEWH’s) environmental water flows,  undermine the Basin Plans ecological targets and needs urgent attention.
 This 2012 Water Sharing Plan appears to be based on localised greed and self- interest, with NSW irrigators receiving enhanced regulatory access and effectively increased diversions volumes.   This has not simply undermined the vision and intent of the Basin Plan, but has added to the environmental degradation of these rivers and further impacted downstream landholders and communities.      A further reduction of 70GL will add to this degradation.
We are repeatedly told that no individual diverter is to be adversely impacted by the implementation of the Basin Plan; however these recent changes to NSW water regulations have clearly had serious impacts to downstream communities and industries. The recent (2015-16) dry spell highlighted these problems, particularly in the Darling River.
EFN members are not in favour of the proposal to increase available groundwater for mining and gas extraction in the Eastern Porous Rock Groundwater area by 14.9 GL per year, or the 109.4 GL per year proposed for the Western Porous Rock Groundwater area
We support the current sustainable diversion limits for all ground water sources as agreed to in the Basin Plan
The Basin Plan identified the need to support those communities most affected and wisely Federal transitional funds were provided to Basin States.  We question how these funds have been spent by the States, where they were directed and their effectiveness.
Given the challenges of Climate Change already being experienced across the Basin, now is not the time to weaken our resolve to implement the Basin Plan as agreed, by Federal and State Governments in 2012.


Return to Submissions page

Original Site Design: Brown Ink