MURRAY GROUP OF CONCERNED COMMUNITIES
Murray-Darling Basin Plan – Ministerial Council Comments
The Murray-Darling Ministerial Council (MinCo) provided their last formal feedback directly to the Federal Minister on M
onday, 27 August. The Minister has stated his willingness to continue to work with the state ministers to try to reach further agreement.
Documents provided to the Minister are:
1. Views of the Councils as a whole;
2. NSW and Victoria;
3. NSW;
4. Queensland;
5. South Australia;
The Murray Group of Concerned Communities review is focussed on the comments provided by the southern jurisdictions with regard to the interests of the southern connected Basin.
Consensus Comments
The MinCo consensus document reports an acceptance of an adjustable, plus or minus 5% of SDL, recovery target of 2,750GL per year.
The MinCo has again stated that the downstream recovery target should be apportioned and has requested the MDBA continue to work with the states to finalise a methodology.
The MinCo have requested clarification that at least 600GL of that recovery target is to be gained through existing committed Commonwealth investments in more efficient irrigation infrastructure. That is the amount assumed by SEWPaC to be recovered through the Water for the Future programs and funding including On-Farm and PIIOP programs, although this is not spelt out in the document.
The MinCo report outlines a salt export objective of a discharge of 2million tonnes of salt out the Murray Mouth each year calculated annually averaged over the preceding three years.
This discharge was previously a ‘target’ in the Draft Basin Plan and became an ‘objective’ in the altered Basin Plan but was an objective for each water accounting period. The three year rolling average allows more flexibility in the system.
MinCo also requests that the Water Resource Plan requirements clearly state that State water quality management plans are not required to specify measures to be undertaken to contribute to the achievement of the salt export objective. This indicates that the objective is not mandatory and is for monitoring and management purposes.
MinCo has expressed concern that the Water Trade Rules may present obstacles to water shepherding arrangements. They are calling for the Basin Plan to allow shepherding where there is no detriment to other entitlement holders.
MinCo again raised issues around jurisdictional implementation, mainly concerning funding and continued work with the states.
They have asked that the MDBA continue to work with the states to refine groundwater issue.
NSW and Victoria
NSW and Victoria have presented a joint position paper to highlight areas of importance to both states.
Key to their position that third party interests are protected and they have asked for it to be stipulated in the Basin Plan that there be no compulsory aquisition of land or easements which is an important criteria (to date there has only been protection from compulsory aquisition of water).
NSW and Victoria request that the Basin Plan be amended to show the values of the shared reduction targets in the southern basin are apportioned at the State level based on the proportion of surface water diversions with urban water use included in recognition that all extractions impact on river health.
According to their calculations the 971GL southern basin shared recovery target would be shared between states as follows:
• Victoria 425GL (43.8%)
• NSW 458GL (47.2%)
• SA 83GL (8.5%)
• ACT 5GL (0.5%)
If NSW distributes its share of the recovery target pro-rata of baseline diversions, the NSW Murray’s water recovery targets are:
• In stream target 262GL
• Shared recovery target 187GL
• TOTAL recovery 449GL
This figure is for the whole of the NSW Murray of which Murray Irrigation represents around 71%.
These figures are the total recovery figures from the 2009 baseline. According to the Commonwealth Environmental Water Holder website over 200GL has already been recovered through purchase and efficiency programs in the NSW Murray. That does not include transfers through the On Farm Irrigation Efficiency Program Round Two or the Private Irrigation Efficiency Program (PIIOP) if it is finalised. Combined these programs will transfer about 48GL.
Using these conservative estimates, the remaining recovery for the NSW Murray is around 187GL long term average annual yeild. The roll out of the On Farm Program Round Three would contribute to that amount.
Victoria and NSW believe that up to 650GL of offsets will be achieved through environmental works and measures and changes to river operating rules and procedures. They believe this offset should apply to the 2,750GL in the first instance. This would eeffectively cap entitlement recovery to 2,100GL.
The two states believe any shortfall in achieving 2,750GL should be met only through strategic purchase (eg. Nimmie Caira) or infrastructure programs undertaken in agreement with the jurisdictions.
They also believe that supply measure savings (before take) can be realised through assessing the “full benefit of Living Murray works and measures” and looking at alternative options for the Coorong, Lower Lakes and Murray Mouth. They specifically mention reconnection of the South East Drainage Scheme and changed operation of the Barrages.
They highlight that for water recovery for efficiency measures (after take) to be effective over the 2,750GL target, constraints need to be addressed and therefore no further recovery should take place until this is done. They make the point that any decision to remove or adress constraints constraints must only be taken with full consideration of third party impacts and stipulate no compulsory land and easement aquisition.
For these reasons, they are of the view that the proposed adjustment mechanism be applied so that supply offsets leading to a downward movement in the recovery target be assessed in the first instance (2016) and any adjustment upward only be applied once the “gap” has been achieved if excess water is gained through efficiency programs funded by the Commonwealth and constraints have been addressed (where practical).
NSW and Victoria want further clarification to ensure the Basin Salinity Management Strategy remains the key salinity management protocol and want it clear in the Basin Plan that the operation of salinity targets in Chapter 8 are not mandatory and have no third party impacts.
They have asked that the Environmental Watering Plan (developed with regard to State Watering Plans) include a delivery plan that addresses third party impacts. They acknowledge that environmental watering activities to date have led to negative third party impacts and they want this issue addressed in the watering plan.
The joint position paper raises the issue of the MDBA changing the benchmark model run to ensure it will be capable of underpinning the adjustment process. NSW and Victoria agree with the principle of refining the benchmark model to sit can be replicated to evaluate possible future adjustments; however, they demand that agreed policies and principles are implemented to ensure the benchmark is representative and a governance framework for its operation be developed.
The key remaining issue for NSW is the groundwater SDLs which they believe the MDBA have set too high in the western saline groundwater regions.
South Australia
Despite signing off on the whole of Council views, South Australia is reserving their final position until they are in receipt of the modelling of a recovery of 3,200GL with key constraints removed. In their individual comments they believe only a recovery target higher than 2,750GL will meet environmental outcomes and the requirements of the Water Act 2007.
They ask the MDBA to adopt a water recovery target greater than 2,750GL. They also believe that the “gap” must be met through purchase or infrastructure and other projects – no mention of environmental works and measures.
South Australia argues that the definition of supply and efficiency measures are inadequate and propose that water recovery through trade or transfer should also be considered to allow the adjustment mechanism to increase water recovery. They argue that the initial benchmark model must be higher to achieve environmental outcomes.
South Australia supports the three year rolling average calculation for the salt export objective but is also asking for key targets for the Coorong, Lower Lakes and Murray Mouth to be included such as minimum water level in the Lower Lakes and a salinity target for the southern Coorong of less than 100g/L.
South Australia also asks that the Basin Plan objectives be amended to “give priority consideration to key environmental concerns before optimising social, economic and environmental outcomes”
South Australia wants the constraints management strategy to be linked to the achievement of objectives and outcomes and a requirement for the MDBA to report annually on progress with implementing actions and measures to relax or remove constraints.
Documents provided to the Minister are:
1. Views of the Councils as a whole;
2. NSW and Victoria;
3. NSW;
4. Queensland;
5. South Australia;
The Murray Group of Concerned Communities review is focussed on the comments provided by the southern jurisdictions with regard to the interests of the southern connected Basin.
Consensus Comments
The MinCo consensus document reports an acceptance of an adjustable, plus or minus 5% of SDL, recovery target of 2,750GL per year.
The MinCo has again stated that the downstream recovery target should be apportioned and has requested the MDBA continue to work with the states to finalise a methodology.
The MinCo have requested clarification that at least 600GL of that recovery target is to be gained through existing committed Commonwealth investments in more efficient irrigation infrastructure. That is the amount assumed by SEWPaC to be recovered through the Water for the Future programs and funding including On-Farm and PIIOP programs, although this is not spelt out in the document.
The MinCo report outlines a salt export objective of a discharge of 2million tonnes of salt out the Murray Mouth each year calculated annually averaged over the preceding three years.
This discharge was previously a ‘target’ in the Draft Basin Plan and became an ‘objective’ in the altered Basin Plan but was an objective for each water accounting period. The three year rolling average allows more flexibility in the system.
MinCo also requests that the Water Resource Plan requirements clearly state that State water quality management plans are not required to specify measures to be undertaken to contribute to the achievement of the salt export objective. This indicates that the objective is not mandatory and is for monitoring and management purposes.
MinCo has expressed concern that the Water Trade Rules may present obstacles to water shepherding arrangements. They are calling for the Basin Plan to allow shepherding where there is no detriment to other entitlement holders.
MinCo again raised issues around jurisdictional implementation, mainly concerning funding and continued work with the states.
They have asked that the MDBA continue to work with the states to refine groundwater issue.
NSW and Victoria
NSW and Victoria have presented a joint position paper to highlight areas of importance to both states.
Key to their position that third party interests are protected and they have asked for it to be stipulated in the Basin Plan that there be no compulsory aquisition of land or easements which is an important criteria (to date there has only been protection from compulsory aquisition of water).
NSW and Victoria request that the Basin Plan be amended to show the values of the shared reduction targets in the southern basin are apportioned at the State level based on the proportion of surface water diversions with urban water use included in recognition that all extractions impact on river health.
According to their calculations the 971GL southern basin shared recovery target would be shared between states as follows:
• Victoria 425GL (43.8%)
• NSW 458GL (47.2%)
• SA 83GL (8.5%)
• ACT 5GL (0.5%)
If NSW distributes its share of the recovery target pro-rata of baseline diversions, the NSW Murray’s water recovery targets are:
• In stream target 262GL
• Shared recovery target 187GL
• TOTAL recovery 449GL
This figure is for the whole of the NSW Murray of which Murray Irrigation represents around 71%.
These figures are the total recovery figures from the 2009 baseline. According to the Commonwealth Environmental Water Holder website over 200GL has already been recovered through purchase and efficiency programs in the NSW Murray. That does not include transfers through the On Farm Irrigation Efficiency Program Round Two or the Private Irrigation Efficiency Program (PIIOP) if it is finalised. Combined these programs will transfer about 48GL.
Using these conservative estimates, the remaining recovery for the NSW Murray is around 187GL long term average annual yeild. The roll out of the On Farm Program Round Three would contribute to that amount.
Victoria and NSW believe that up to 650GL of offsets will be achieved through environmental works and measures and changes to river operating rules and procedures. They believe this offset should apply to the 2,750GL in the first instance. This would eeffectively cap entitlement recovery to 2,100GL.
The two states believe any shortfall in achieving 2,750GL should be met only through strategic purchase (eg. Nimmie Caira) or infrastructure programs undertaken in agreement with the jurisdictions.
They also believe that supply measure savings (before take) can be realised through assessing the “full benefit of Living Murray works and measures” and looking at alternative options for the Coorong, Lower Lakes and Murray Mouth. They specifically mention reconnection of the South East Drainage Scheme and changed operation of the Barrages.
They highlight that for water recovery for efficiency measures (after take) to be effective over the 2,750GL target, constraints need to be addressed and therefore no further recovery should take place until this is done. They make the point that any decision to remove or adress constraints constraints must only be taken with full consideration of third party impacts and stipulate no compulsory land and easement aquisition.
For these reasons, they are of the view that the proposed adjustment mechanism be applied so that supply offsets leading to a downward movement in the recovery target be assessed in the first instance (2016) and any adjustment upward only be applied once the “gap” has been achieved if excess water is gained through efficiency programs funded by the Commonwealth and constraints have been addressed (where practical).
NSW and Victoria want further clarification to ensure the Basin Salinity Management Strategy remains the key salinity management protocol and want it clear in the Basin Plan that the operation of salinity targets in Chapter 8 are not mandatory and have no third party impacts.
They have asked that the Environmental Watering Plan (developed with regard to State Watering Plans) include a delivery plan that addresses third party impacts. They acknowledge that environmental watering activities to date have led to negative third party impacts and they want this issue addressed in the watering plan.
The joint position paper raises the issue of the MDBA changing the benchmark model run to ensure it will be capable of underpinning the adjustment process. NSW and Victoria agree with the principle of refining the benchmark model to sit can be replicated to evaluate possible future adjustments; however, they demand that agreed policies and principles are implemented to ensure the benchmark is representative and a governance framework for its operation be developed.
The key remaining issue for NSW is the groundwater SDLs which they believe the MDBA have set too high in the western saline groundwater regions.
South Australia
Despite signing off on the whole of Council views, South Australia is reserving their final position until they are in receipt of the modelling of a recovery of 3,200GL with key constraints removed. In their individual comments they believe only a recovery target higher than 2,750GL will meet environmental outcomes and the requirements of the Water Act 2007.
They ask the MDBA to adopt a water recovery target greater than 2,750GL. They also believe that the “gap” must be met through purchase or infrastructure and other projects – no mention of environmental works and measures.
South Australia argues that the definition of supply and efficiency measures are inadequate and propose that water recovery through trade or transfer should also be considered to allow the adjustment mechanism to increase water recovery. They argue that the initial benchmark model must be higher to achieve environmental outcomes.
South Australia supports the three year rolling average calculation for the salt export objective but is also asking for key targets for the Coorong, Lower Lakes and Murray Mouth to be included such as minimum water level in the Lower Lakes and a salinity target for the southern Coorong of less than 100g/L.
South Australia also asks that the Basin Plan objectives be amended to “give priority consideration to key environmental concerns before optimising social, economic and environmental outcomes”
South Australia wants the constraints management strategy to be linked to the achievement of objectives and outcomes and a requirement for the MDBA to report annually on progress with implementing actions and measures to relax or remove constraints.
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