Submission deadline: Friday 10 February 2017 5pm AEDST
The Murray Darling Basin Authority (MDBA) has conducted a review of the environmental water needs of the Northern Basin and recommends that 70GL can be handed back for industry extraction. This will put at risk the fish, birds, farms, communities and towns who depend on the Northern Basin’s rivers and wetlands.
The adopted Basin Plan is already a compromise with medium to high risk of failing to deliver on environmental targets.
The agreed Basin Plan requires that 390GL of water be recovered for the environment to prevent irreversible damage to our most important river system. The MDBA proposes cutting that figure to 320GL and implementing a suite of “toolkit” measures to supposedly ‘complement’ environmental water.
Instead of an evidence base, it seems a judgement-call has been made that will have damaging impacts for Indigenous communities, wildlife, downstream communities and the floodplain grazing industry.
Environmental science, hydrological modelling and socio-economic studies were undertaken to inform the Northern Basin Review but it is not clear how this new data was used to arrive at the '320GL + toolkit' amendment proposed by the MDBA.
For more detailed information go to:
For hints on writing a good submission see Background Information below
1. Northern Basin Review
- Object to the proposed reduction of environmental water recovery from the agreed & legislated volume of 390GL to 320GL, plus the “toolkit” measures. The 390GL volume is already a compromise and will not meet all environmental requirements.
(Problems with the “toolkit” measures are outlined in Background Information below)
- The Northern Basin contains important wetland, floodplain and riverine environments that are protected under environmental treaties to which Australia is signatory, including the Ramsar Convention and international migratory bird agreements. The Northern Basin also supports a diverse range of threatened and unique plant and animal species listed under state and national environment laws. The resilience of entire ecosystems will be harmed by the proposed reduction in water recovery.
- To achieve the environmental outcomes of the Basin Plan and meet commitments under the Convention on Biological Diversity, the Ramsar Convention and migratory bird agreements, environmental water recovery in the Northern Basin should be at least 415 GL. Failure to meet the core requirements of these international agreements would also constitute a breach of the Water Act.
- Object to the proposal to reduce current held environmental water in the Macquarie River by 12 GL and the Gwydir River by 6 GL. This will have a significant impact on the future of the Ramsar listed Macquarie Marshes and Gwydir Wetlands. It will also reduce the reliability of stock and domestic and Town Water Supplies on the Darling River.
- The proposal to reduce environmental water in the Macquarie River is particularly alarming as the Commonwealth Government notified the Ramsar Secretary-General in 2009 that the Macquarie Marshes were likely to experience a change in ecological character. It is therefore clear that the Marshes need more water, not less.
Impact on Menindee Lakes
- Object to the proposed reduction of shared environmental flows through the Northern Basin by over 100 GL. The impact of reduced environmental water on the Menindee Lakes has not been clearly considered.
- A reduction in flows to Menindee Lakes will impact on available water through to South Australia and the Murray Mouth. All water users on the Murray will have their reliability of access to water reduced (due to state water-sharing arrangements).
- Water Quality
- The risk of water quality degradation occurring as a result of the proposed reduction of water recovered for the environment has not been adequately assessed.
- Water quality degradation that will potentially occur as a result of reducing environmental flows contravenes Chapter 9 of the Basin Plan.
- The Darling River is particularly susceptible to blue-green algae outbreaks which impact on stock and domestic water supplies, local communities, the environment and recreational fishing
- Proposed reduction of water recovered for the environment will reduce water dependent ecosystems resilience to climate change, which is inconsistent with 8.07 of the Basin Plan.
- The current environmental flows in the Basin Plan do not take climate change into account. A further reduction will expose the environment and communities to an even greater level of risk.
- The cultural, social and economic benefits of a healthy river system have not been adequately assessed. This is of critical importance to communities and river dependent properties downstream of Bourke.
- Aboriginal communities have strong spiritual and cultural connections to the rivers and wetlands. The value of cultural flows has not been taken into account. Northern Basin aboriginal people overwhelmingly support an increase in the water recovery target to protect cultural values.
- Other economic benefits including improved floodplain grazing productivity, freshwater fishing and tourism have not been given sufficient consideration.
- The Federal Government has provided substantial financial support to State Governments in the Regional Economic Diversification Program - $32.5m to NSW and $15m to Queensland.
The economic analysis for the Northern Review has not reported on this investment aimed at helping regional communities adjust to the Basin Plan.
2. Groundwater Review
- Object to the proposal to increase available groundwater for mining and gas extraction in the Eastern Porous Rock Groundwater area covering north-east NSW between Goondiwindi, Tamworth and Dubbo by 14.9 GL per year.
- Object to the proposal to increase available groundwater for mining extraction in the Western Porous Rock Groundwater area covering south-western NSW between Broken Hill, Ivanhoe and Wentworth by 109.4 GL per year
- Support the current sustainable diversion limits for all ground water sources as agreed to in the Basin Plan.
A gigalitre of water (GL) equals one billion litres
The Northern Basin is the system of rivers in NSW and Queensland that feed into the Barwon-Darling River and flow to the Menindee Lakes
The Basin Plan received bipartisan support in 2012. It is a requirement of the Water Act 2007 passed by the Howard Government when Malcolm Turnbull was Water Minister.
The aim of the Basin Plan is to address the over-use of water. More efficient water dependent industries would allow water to be returned to the environment without causing economic impacts on communities and service towns.
The implementation of the Basin Plan is a $13b investment of public money to prevent irreversible environmental degradation of river and wetland health.
Much of this investment has provided direct private benefit to the irrigation industry.
Social, cultural and other economic benefits of a healthy river system have not been given the same level of attention as the extractive industries. Important research into indigenous cultural flows remains incomplete and was therefore not properly considered in the amendment decision-making process.
The outcome of the Northern Basin and Groundwater Reviews are proposed as amendments to the Basin Plan. Work by the MDBA indicates there is a high risk the current, let alone further reduced, water extraction volumes will fail to meet ecologically sustainable objectives set down in the Water Act 2007.
Available water for the environment should increase through amendments, not be decreased
Problems with ‘toolkit measures’
- “Toolkit” measures were proposed by the Northern Basin Advisory Committee to add value to the use of environmental water. They are NOT substitutes for water. Most of these tools are sensible natural resource management works that the States should be funding and implementing regardless of the Basin Plan water recovery target. However, States are reluctant to fund these works and are seeking Commonwealth funds for these types of projects.
- The “toolkit” measures are mostly complementary on-ground works with some policy tools. However, they are not enshrined in law and to that extent are mostly unenforceable. Most fall outside the MDBAs charter, which means they have no recourse if the States refuse to implement them
- The toolkit includes 2 assumptions that NSW has publicly stated are unrealistic and unachievable, and that they will not implement either strategy: the protection of environmental water in the Barwon-Darling system; and the coordinated delivery of environmental water from multiple tributaries. (Northern Basin Review - NSW Synopsis. NSW DPI, November 2016).
Hints on submission writing:
How do I make my submission effective?
- Make clear statements about whether you do or don’t support the proposed amendments. Often government agencies (in this case the MDBA) will record how many submissions received and how many were in favour or against a particular point. They will try to summarise responses into categories so the most effective way to have your submission count is to make it easy for the agency to record your views. We’ve provided some clear examples below.
- Include evidence or case studies or stories of how the issue is relevant to you or your group. Give specific examples of how unhealthy rivers and the lack of regulation has failed you in the past or currently, and how this amendment will personally impact you and your community. This is what makes a submission particularly persuasive. If you can, collect stories that support your argument from others in the community.
- Refer to past submissions you have done, or those that have been made available to you. Cite reports, but be sure to footnote appropriately. If something cannot be cited (something unofficial), append it or include an internet link to it.
- If you can, make recommendations, not merely suggestions.The more concrete the better. However if you don’t feel you have enough knowledge to make recommendations it is still valuable to make a submission outlining your concerns.
- If there are positive or good things to say, say them. There may be other stakeholders who will be attacking the MDBA, wanting to get rid of the Basin Plan altogether. So it is important to remind the MDBA about how positive the Basin Plan is, and how needed the MDBA is to enforce it.
What should I avoid?
- Avoid repeating back what is in the consultation paper or the Northern Basin Review. The MDBA wrote it and they know it. Instead, it is important to analyse and critique it.
- Avoid writing a thesis. Keep it short and easy to digest. If you’ve written a thesis on the topic, attach it.
- Consider your use of jargon. While the MDBA speak giggababble, the public do not. You may want your submission to be shared with the public to inform them of what this change in legislation will mean for them. The public often get turned off by language that is too technical, yet sometimes it is helpful for the MDBA to see more technical submissions. It depends on how you want to use your submission.
- Avoid spending three pages criticising the consultation process itself. If you have criticisms try to limit it to one paragraph, and keep the main game, the main game.
Thanks to Environment Justice Australia for the provision of these submission writing hints