To: Murray Darling Basin Authority.

Submission concerning proposed adjustment to the sustainable diversion limits

Made: 2 November 2017

The Environmental Farmers Network (EFN) has welcomed every opportunity it has had to comment on the development and now implementation of the Murray Darling Basin Plan. However on this occasion has found the task very difficult, as limited publicly available information on projects has made considered comment almost impossible in a limited consultation period.
The MDBA has failed to provide sufficient detail about the supply projects with many of the most basic details lacking (there is only a paragraph of information about each on the MDBA website). We do not know what environmental outcomes will be achieved or how they contribute to the Basin wide environmental watering strategy and its targets for water birds, fish and vegetation.
 It is almost certain that some projects will not come to fruition or underperform, and when reconciliation occurs in 2024, the offset volume will be less than proposed, requiring States to source water entitlements to meet the shortfall. This process has effectively pushed many politically difficult decisions surrounding water recovery out to 2024.
The SDL package should also include two other key elements, the sourcing of 450GL from efficiency measures and constraints management plans.  Neither of these has been progressed, with States showing no inclination to fulfil these agreed elements of the basin Plan.

Environmental works projects
The engineered delivery of environmental water to dispersed wetlands and floodplain in the group of Environmental works projects aim to improve the health of specific sites, but many of these projects fail to achieve genuine connectivity with the floodplain. The maintenance of the carbon cycle is critical to the long term health of flora and fauna dependant on these rivers.. This long term health can only be achieved by connecting river channels to the floodplain and allowing the return of flows. 

Operational rule changes and system enhancement projects
The efficient delivery of environmental flows was discussed and well understood during the development of the Basin Plan.  We understood close working relationships, and cooperation between Federal and State Authorities responsible for water deliveries to be essential for the ecological targets in the Plan to be achieved.
We believe “efficient delivery” is embedded into the Basin Plan and consider the majority of projects put forward to reduce the volume of water set aside for the environment as SDL operational rule changes and system enhancement projects as adjustment measures inappropriate.
Many of these proposed projects are simply best practice and should not be included in the package of projects..
The Hydro Cues project as an example is designed to achieve enhanced environmental outcomes by increasing environmental water holders’ ability to time releases of environmental water from dams with increases in natural flows caused by rainfall. We believe this to be clearly “best practice” and taken into account as a given in the development of the Basin Plan.
The Hydro-Cues project also highlights that environmental benefits, at least in part, will be dependent on the extent to which constraints projects are implemented. State government commitment to constraint management must be questioned with the Victorian Government’s “New Goulburn constraints project”, a project that confines flows in-channel and clearly fails to meet Basin Plan criteria.
It would appear most major decisions in relation to SDL adjustments have already been made with insufficient time allocated for genuine consideration of comments arising from this consultation process and the MDBA to present a final determination to the Federal Water Minister on 15 December 2017.
We are assured an adaptive management approach will be used in developing and refining projects included in the package of 37 SDL projects prior to reconciliation in 2024. The MDBA must ensure genuine consultation with stakeholders takes place over this phase.
EFN believe that, confidence in the Plan and the MDBA has suffered with allegations of theft, corruption and lack of compliance with-in State water bureaucracies, and with this, confidence in projects nominated by those States. Five separate inquiries are currently underway and the possibility of a judicial inquiry now is not the time to determine SDL adjustments and make recommendation to the Minister. 

The SDL determination process should be delayed.


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