Submission To the Murray Darling Basin Authority On the Draft Plan 10th April, 2012

Submission To the Murray Darling Basin Authority On the Draft Plan
10th April, 2012

Preamble

The debate over the last year or so on the Draft Plan and its predecessor has revealed glaring flaws in both the Water Act (2007) and the Draft Plan.

So much so that if we are serious in securing better natural resource management in Australia we need to go back to the drawing board and repeal the Act.

I remain greatly concerned that as a consequence of misguided action by Government we will cause great socio-economic damage, unnecessarily limit future production, and do little or nothing for the environment.

I make these comments from the perspective of somebody who has followed the Basin debate closely, and has had long experience in water management particularly in my past role as Chairman and Chief Executive of Clyde Agriculture which was not only an irrigator but had extensive floodplain grazing and dryland farming operations.

Base Position
The Millennium Drought had a major impact on the Basin. (The renowned recuperative power of the Australian landscape has been demonstrated in its spectacular recovery since the drought broke.)

Water extractions were well controlled by the adaptive management approach embodied in the allocation process, guided by the Water Sharing Plans. 

Natural impacts from extreme drought are being incorrectly labelled as chronic ill-health.

At the top of the Murray and Murrumbidgee the Snowy Scheme is not being managed in a manner which optimises its original water conservation objectives. 

At the bottom, the Murray River has been deprived of its estuary by The Barrages and this has created serious environmental problems, and the call for ever more fresh water. The diversion of fresh water flows in the South-East of S.A. to the sea, flows which once drained to the Southern Lagoon of The Coorong, has also caused environmental problems.

Asking the CSIRO to come up with single figure Sustainable Diversion Limits (SDL's) for the rivers within the Basin reveals a fundamental misunderstanding of the nature of our inland rivers and their massive variability. To argue that these numbers are "averages" doesn't help, given the enormous spreads around the averages. In using absolute numbers as the MDBA has done, to prescribe acceptable extractions/diversions limits without relating these to actual flows (availability), is really nonsense. 

One has to wonder whether we are proposing to "throw the baby out with the bathwater' in moving to a centralised Commonwealth water management regime.

Our current water bureaucrats could do worse than study how the existing control system operates. It works rather well. 

Drought Induced Perceptions

In 1990 I toured China, Vietnam and Laos with a delegation from the NSW Department of Water Resources. The delegation included the State Minister, the Departmental Head and the Chairman of the MDBC. One of our objectives was to explain to our hosts how different jurisdictions could successfully manage a river-in their case the Mekong. The successful model was the MDBC which at the time was held in the highest esteem. How perceptions have changed!

More Conservation

If we had more dams, in the big wet events, we could store very substantial additional amounts of water, yet they would represent only a tiny percentage of the big flows. A consistent misunderstanding relates to failure to appreciate the magnitude of the water flows in these totally irregular, but surprisingly frequent events.

Toorale Station Lesson

The Government purchase and closing down of Bourke’s most productive property, Toorale Station in 2008, is a microcosm of the Basin Plan. If Toorale had continued to operate it would have reduced river flows in the Darling River past Louth in 2010/11 by 0.01%! 

In other words, great social cost, for no environmental benefit. 

2012 Outlook Conference

The MDB session at the recent Agricultural Outlook Conference disturbed me for a number of reasons-

• The opening graph showed no impact from the allocation system which dramatically reduced extractions during the recent drought.
• There was a broadbrush comment that MDB extractions were usually "around 10 to 11,000 GLS."
• There were many comments such as "recovering water" and "closing the gap" without it would seem an understanding that Government buying entitlements is simply changing ownership from the private sector to the Commonwealth Environmental Water Holder (CEWH).

Recognising the Difference Between ‘Entitlements’ and ‘Allocations’

According to the ABS, during the most recent years of the drought the allocation system guided by the very effective water sharing plans for each of the Basin's rivers, reduced extractions to-

(GL'S)

2005-06     7369
2006-07     4458
2007-08     3141
2008-09     3492
2009-10     3564

not around "10 to 11,000 GLS" as quoted at the Outlook Conference


Water entitlements without allocations amount to 'phantom water'. An 'entitlement' only grants the holder a share of 'allocations' when there are any. The entitlements held by the CEWH will apparently still attract allocations (when water is available) and nobody really knows what this new player (the Government) is likely to do with them.

So, we have a situation whereby before allocations are granted the water sharing plans call for a priority to 'critical human needs' and assessed ‘environmental needs’. Once these are met then allocations for 'consumptive' use are made. So, in what is proposed the CEWH gets a second bite, presumably mainly for environmental needs and becomes a player in the water market. This gives rise to some interesting conflicts of interest.
It seems to me that if the assessed environmental needs are not covered adequately under the water sharing plans, which I doubt, then it is those plans that should be changed. Not have the "dog's breakfast" that is now proposed.

Summary
I contend that the fact remains that we have confused the natural impact of a very severe drought with "ill-health" and invalidly blamed it on extractions. A situation which has been wonderfully and dramatically corrected in the time honoured manner by the flood flows of the last three years.

We should repeal the Water Act and begin the process anew along lines proposed by a former NSW Director General of Water Resources who has had extensive global experience in river management.

I have serious doubts of the wisdom in centralising control in Canberra. The former MDBC/Ministerial Council approach with all the tensions and debates between the States that water management inevitably involves, was once held up around the world as an example of how to do water management properly.

I can do little better than conclude with the words of Harvard Professor John Briscoe-

"My conclusion is stark. I believe that the Water Act of 2007 was founded on a political deception and that the original sin is responsible for most of the detour on which Australian water management now finds itself. I am well aware that unpredictability is an enemy and that there are large environmental, social and economic costs of uncertainty. But I also believe that Australian cannot find its way in water management if this Act is the guide. I would urge the Government to start again, to re-define principles, to engage all who have a stake in this vital issue, and to produce, as rapidly as possible, a new Act which can serve Australia for generations to come. And which can put Australia back in a world leadership position in modern water management."

J.D.O.(David) Boyd

10.04.12