In June 2004, the Council of Australian Governments

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1 Buying back the living Murray: at what price? R.Q. Grafton and K. Hussey* In June 2004, the Council of Australian Governments approved the Intergovernmental Agreement on Addressing Water Overallocation and Achieving Environmental Objectives in the Murray-Darling Basin (IGMDB). The IGMDB sets out arrangements for a Living Murray that includes a budget of $500 million to return 500 billion litres of water per year to the Murray River by This article examines plans by the Australian government to purchase permanent water entitlements via water through efficiency request for tenders (WTERT) to support the Living Murray. The tender process will allow the Australian government to purchase water entitlements from individuals who agree to undertake water-saving measures equal to the amount of water entitlements they wish to sell. A potential problem with market-based water recovery to increase environmental flows is that it is not cost effective given the current water pricing arrangements and the rules for the tenders. First, the market price for water entitlements does not include the costs of use in terms of deteriorating water quality; and, hence, is overpriced where use imposes such costs. Second, the constraint in the tender process that requires water users to undertake infrastructure investments when selling their entitlements also unnecessarily raises the cost of water purchases, such that it is likely to at least double the cost to the Australian Government of purchasing water entitlements. Keywords: Living Murray, water entitlements, externalities, environmental flows, market-based water recovery When the well is dry, we know the Worth of Water. (Benjamin Franklin Poor Richard s Almanac, 1745, p.2) Introduction The Murray-Darling River system generates critically important water resources for Australia s agricultural sector. Using dams and water diversions, the river system provides water for irrigation in Queensland, New South * Quentin Grafton and Karen Hussey are with The Australian National University, Canberra. Quentin is at the Crawford School of Economics and Government, and Karen is at the National Europe Centre. quentin.grafton@anu.edu.au Wales, and South Australia. However, the environmental costs associated with altered flows are large and a review of the Murray-Darling s ecological condition concluded it was significantly impaired and no longer healthy (Jones et al. 2002). A number of policy initiatives have been adopted to address environmental concerns due to water use in the Murray-Darling River system. The most significant, adopted in 2004, is the IGMDB, which sets out arrangements for investing $500 million to return 500 billion litres of water to the Murray by This is to be achieved through a variety of initiatives including infrastructure improvements that are expected to deliver 231 billion litres of water savings at a cost of $170 million (MDBC 2006a). The success of these initiatives is to be judged from environmental improvements at six iconic sites along the Murray River chosen for their conservation, recreational, cultural and economic value. 1 To accelerate the process of increasing environmental flows, in April 2006 the Australian Government announced its intention to purchase water entitlements provided they arise from verifiable water efficiency improvements, and then to reallocate the purchased water back to the river system. This tender complements similar arrangements at a state level that have been called market-based water recovery. 2 In January 2007, the Prime Minister announced a National Plan to expand the market-based recovery approach for Water Security (Howard 2007). This plan includes $3 billion for purchasing water entitlements and structural adjustment over the next 10 years if all states agree to a proposed set of governance arrangements in the Murray-Darling Basin (MDB). This article examines the economics of the purchase of permanent water entitlements by the Australian 1. These sites include: Barmah-Millewa Forest, Gunbower Koondrock- Perricoota Forests, Hattah lakes, Chwilla Floodplain and Lindsay-Wallpolla Islands, Murray Mouth, Coorong and Lower lakes, and the River Murray Channel (MDBC 2005). 2. South Australia s Minister for the Murray, Karlene Maywald, is quoted in The Australian (21 August 2006) in a speech delivered on 21 August that her government has purchased 11 billion litres of water for environmental flows in the Murray River that was previously used for irrigation purposes. New South Wales has a water recovery package that involves acquiring parts of water entitlements, under certain conditions, at a cost of A$8.9 million to recover 9 billion litres (MDBC 2006b). 74 AUSTRALASIAN JOURNAL OF ENVIRONMENTAL MANAGEMENT Volume 14

2 Government under the WTERT. The contention is that this purchase is not cost effective because, one, the current market price of entitlements - and, hence, the amount that will be paid through the tender - does not account for the quality effects of water use; and, two, the requirement that water users undertake infrastructure investments to reduce water use as a condition of purchase unnecessarily increases the cost of marketbased water recovery. As a result, less water will be provided in the form of environmental flows than if water included a price for the loss of water quality from use, and if there were no water-savings constraints imposed on sellers of water entitlements. Water markets and the environment The Murray-Darling is the longest river system in Australia. It covers just over one million square kilometres, or around 14 per cent of Australia s land area, and drains parts of Queensland, the major part of New South Wales, a large part of Victoria and part of South Australia. Compared to other river systems of similar size, the Murray-Darling Basin is characterised by low average rainfall and very high variability in rainfall. The development of agriculture in the MDB has been associated with a range of environmental problems, some of which are specifically linked to irrigation while others reflect more general impacts of agriculture (Quiggin 2001). In July 2002 a detailed investigation of the environmental impacts of flow regulation on the basin was conducted. The expert panel undertaking the investigation concluded the river system could no longer be considered healthy and that returning the Murray River System to healthy working condition would require major improvements to river management more environmental water, improved habitat condition, improved catchment and floodplain management, and better water quality (Jones et al. 2002, p. 15). Over the last fifteen years, environmental studies have identified a number of significant threats to the Murray- Darling including land degradation, river water salinity, land salinity, water quality problems and loss of biodiversity 3. The MDB is particularly susceptible to river water salinity because the run-off from irrigation increases salt loads, and the use of water for irrigation reduces total flows. A Salinity Audit undertaken by the Murray-Darling Basin Commission (MDBC) in 2000 concluded that under current policies: the average salinity of the lower River Murray (monitored at Morgan) will exceed the 800 EC 4 threshold for desirable drinking water quality in the next years. By 2020 the probability of exceeding 800 EC will be about 50 per cent. (Murray-Darling Basin Ministerial Council 2000: vi cited in Quiggin 2001, pp ) Other impacts also relate to water quality, in particular turbidity, and eutrophication resulting from excess nutrients such as fertilizer runoff. 5 In addition, the manipulation of the Murray-Darling s flow regime, and the reduction in the volume of water flowing into wetlands, has had a major negative impact on the population and diversity of the river s biodiversity. Another concern is that water savings in irrigation may, in some cases, reduce return flows and thus lower existing environmental flows. This is because some water savings only reduce apparent water losses in irrigation that return to the hydrological system, rather than true losses that arise from evaporation and transpiration that reduce the amount of water available for other uses or the environment (Productivity Commission 2006, p. 24) 6. A reduction in environmental flows in turn reduces the capacity of the river to dilute pollutants in the water, thereby exacerbating water quality further. Concerns over environmental flows have led to a number of intergovernmental agreements on water reform for the Murray-Darling, most recently the Living Murray Initiative. Externalities, trading and water pricing Water use in the MDB poses costs for the environment in terms of resilience to shocks, biodiversity, habitat losses, etc. These are called negative externalities because the costs imposed on those that benefit from the environment are not considered by those making water-use decisions. These water-use externalities come in two principal forms: costs imposed on others from reductions in quality (increased salinity, greater turbidity, higher phosphate levels, etc.), and costs from reduced water flows (biodiversity losses in wetlands, reduced fish numbers, tree die-offs, etc.). Overcoming water-use externalities does not imply there should be no water use, but it should be economically 3. Gippel and Blackham suggest the impacts due to water diversions can be divided into hydrology; geomorphology and water quality; and ecology. For their detailed analysis see Gippel and Blackham (2002) 4. The EC unit is a measure of electrical conductivity, commonly used to indicate the salinity of water. 1 EC = 1 micro-siemen per centimetre, measured at 25 C. 5. See Dwyer et al. (2006) for further details on the externalities associated with irrigation. 6. Young et al. (2002) estimate that over the next 20 years water-use efficiency savings in irrigation may reduce net flows by as 723 billion litres per annum. June

3 efficient to account for both the private costs of water delivery and the external costs imposed on others from use 7. Competitive water trading helps to achieve this outcome because it allows water to be traded from low to high value uses. However, there are at least two reasons that currently prevent water trading from leading to an economically efficient outcome. First, water entitlements in the MDB are denominated as gross flows or diversions rather than net flows the gross diversion less the return flows to the hydrological system. Given that different uses generate different return flows, those users with the highest water efficiencies 8 should, but currently do not, pay more than users with lower water efficiencies because they impose the greatest environmental costs in terms of reduced flows (Young and McColl 2003). Second, different uses also impose different environmental costs in terms of their impact on water quality such as extra salt loads, increased turbidity or higher phosphate levels. At present these extra costs, in terms of water quality, are only, at best, partially accounted for when water is traded, and primarily in terms of salt loads at a regional rather than individual level. As a result, water users that impose high environmental costs in terms of water quality (such as higher salt loads) are currently paying too little for their water; and, hence, using too much water relative to those who impose lower environmental costs in terms of water quality. Fully accounting for environmental costs of water use will lower the market price of water. Consider the case of an irrigator who receives a net return of $1,000 from the purchase and use of an extra million litres of water. The maximum price the irrigator would be prepared to pay for this water would be $1,000. If this extra water use by the irrigator also imposes $200 in environmental costs, and the irrigator were subsequently forced to account for this cost, the most the irrigator would then be prepared to pay for the water would be $800. In other words, the larger the marginal external cost of water use is, the lower the amount water users - who account for these environmental costs - will be prepared to pay for water; and, hence, the lower the market price of water. The difficulty in getting individuals to pay the full costs they impose on others from water use is that we currently lack a measure of the environmental costs (in dollars) of water use (Bennett 2005). Such information is required to be able to evaluate the trade-offs from increasing environmental flows that generate environmental benefits versus the economic losses from reductions in water use in irrigation. Valuing the environment As the environment is not priced, economists obtain values for its attributes (and hence the costs from reducing these values) through non-market techniques that frequently involve individual and household surveys to elicit values for a variety of environmental goods (Garrod and Willis 1999). Bennett and Morrisson (2001), among others, have obtained values for environmental attributes in New South Wales rivers. For example, on the Murrumbidgee River they found households value river vegetation health at $1.49 per household, the number of fish species at $2.36 per household, and the number of bird species at $1.59 per household. Van Beuren and Bennett (2004) also provide estimates associated with river restoration and estimate a value per annum per household of 8 cents nationally over a 20-year period for a 10 kilometre stretch of a river. Translating non-market values of environmental attributes into dollars per litre is difficult, and will vary spatially and over time because the same quantity and quality of water will have different environmental impacts depending when and where the flow occurs along a river. In the absence of such data, or a consistent environmental benefits index that translates costs of reduced water quality into a well-defined metric (Hajkowicz 2007), policy makers have eschewed applying environmental charges to address water quality issues. Instead, as in the Living Murray Initiative the focus has been on increasing environmental flows to the Murray River. Prices versus quantities If water use imposes external costs on others, these can be internalized or corrected by setting an appropriate price or charge per litre, or by restricting the quantity of water used. Setting an appropriate price or setting a quantity control on use generates equivalent outcomes in a first-best world with no uncertainty and perfect monitoring and enforcement. In the case of price approach, by making the marginal external cost explicit in the form of a per unit charge, water users are forced to consider the costs they impose on the environment, and thus have a financial incentive to change their practices. Under a quantity approach, limits are placed on the 7. See Freebairn (2003) for a discussion of economic efficiency and the allocation of scarce water. 8. We define water efficiency as the proportion of water actually used in a productive capacity from the total volume of water extracted. All else being equal, the more efficient is the water use the less excess water will be available via seepage or other means to return as flows to the hydrological system. 76 AUSTRALASIAN JOURNAL OF ENVIRONMENTAL MANAGEMENT Volume 14

4 amount of water than can be diverted by users to account for the costs they impose on the environment. In the second-best world that exists in the MDB, price and quantity approaches will likely result in different outcomes (Weitzman 1974). This is because the impact of an environmental charge on the water-use decisions cannot be known in advance because its effect on behaviour by users will depend on their individual cost structures. By contrast with fixed quantity limits of water use, a regulator is able to know with much greater certainty what will be the amount of water diverted, provided there is good monitoring and enforcement. Given the intention to increase environmental flows by 500 billion litres by 2009 under the Living Murray Initiative, it makes sense to use quantity controls to ensure this fixed target is achieved with a high a degree of certainty rather than use a price approach. Cap and trade mechanisms The use of quantity controls to achieve environmental goals has been applied in various management contexts, including the use of individual transferable quotas in fisheries and pollution permits to control emissions of sulphur dioxide and other emissions (Devlin and Grafton 1998). This approach called a cap and trade marketbased mechanism involves setting an overall limit on use or emissions, and then allocating individual limits among users or polluters that are tradeable (Grafton et al. 2004). Under a cap and trade approach, users can choose to meet their individual limits (emissions, catch of fish, etc.) by trading among themselves and/or by complying with their individual limits or allocations (abating pollution, harvesting fewer fish, etc.). This allows individuals who can comply with the controls at low cost to sell or lease their rights to users with higher compliance costs while still maintaining the overall cap. In turn, this permits higher compliance cost users to achieve their individual limits at a lower cost than if they were unable to purchase rights from others. In the MDB, there already exists an overall cap on water diversions and the individual limits on diversions are determined by holdings of water entitlements. These entitlements are a statutory right of access to water (Fisher 2006) that provide their holders with seasonal allocations of water based on inflows and storage levels in the Basin. The overall cap in the Murray-Darling Basin is appropriately called the Cap which is a limit imposed on diversions from streams in the Basin. The Cap is not a fixed quantity of water, but rather varies by season and is the volume of water that would have been used with the infrastructure that existed in , assuming similar climatic and hydrological conditions to those experienced in the year in question (MDBC 2002, p. 66). If water use generated environmental costs only in terms of reduced flows, then market-based water recovery (the purchase of water entitlements or their seasonal allocations) would be sufficient to achieve a desired environmental outcome, provided an adequate number were purchased and the purchased water allocated for environmental purposes. The problem is that water use imposes costs in terms of both reduced flows and lower water quality: the most important being increased salinity. In this case, one instrument (purchase of water entitlements) is not sufficient to address two externalities (Tinbergen 1950), and an additional instrument is required to address the water quality problem. As a result, market-based water recovery alone cannot address all the externalities associated with water use in the Basin. Water quality Existing approaches to improving water quality in the MDB have focused primarily on salinity, and include interceptions to prevent saline water entering rivers, limits on water trading into high impact zones, and levies on trade into higher impact zones that fund salt interceptions. However, there are no individual incentive arrangements to remove salt from the MDB (Productivity Commission 2006, ch. 9). As a result, the costs of water use, in terms of increased salt load or other undesirables and contaminants, are not fully accounted for in the market price of water, and the price is greater than what it should be. Until and unless the costs of reduced water quality are accounted for by water users -either through an additional cap and trade approach in terms of salt loads (Productivity Commission 2006) via environmental charges that vary by region and water (Dwyer et al. 2006), or by some other means (Heaney et al. 2006) - the purchase price of water entitlements under a tender system will be overvalued in an economic sense. In other words, if water users fail to pay the marginal external cost in terms of water quality, as is currently the case, the market price of water will ignore water quality externalities, and the price paid by governments for water to increase environmental flows will be more than it should be. Given that there are currently no water quality charges in the MDB set in accordance with marginal external costs or other approaches to adequately address these externalities, the price bid by water users in the WTERT must, necessarily, be inflated, and will not be a June

5 cost effective method of increasing environmental flows to the Murray River. 9 The policy context: the Living Murray Initiative In the past decade, environmental studies have assessed the extent of the damage in the Murray River system (Gippel and Blackham 2002; Thomson 1995). In particular, a key finding of a 2002 Expert Reference Panel (Table 1) on the Murray River system was that there would be a high likelihood of achieving a healthy working River Murray system if provisions for 3,350 billion litres of new environmental flow allocations were made. Anything less than 1,630 billion litres would be unlikely to return the river to a healthy status. The policy response to these findings was the Living Murray Initiative, established by the MDB Council in 2002 with the aim to create a healthy working river that assures continued prosperity, clean water and a flourishing environment (Department of Environment and Heritage 2004). In light of the Expert Reference Panel s recommendation, the aim of the Living Murray Initiative is to reallocate 500 billion litres per annum to the river from the expenditure of $500 million, commencing In addition to the reallocation of 500 billion litres, the Living Murray Initiative focuses on maximising environmental benefits for six significant ecological assets, and meeting specific ecological objectives and outcomes for each of these assets (Murray-Darling Basin Ministerial Council 2003). In 2004, CoAG reaffirmed the first step of the Living Murray Initiative and signed the IGMDB 11. As part of the IGMDB, the states are required to establish targets for investment and water recovery. In addition, three year Table 1. Final summary of assessment of flow option packages and the probability of success of each management option for the River Murray indicative targets are to be set for the amount of water to be recovered within each jurisdiction, recognising the differing opportunities within each, their relative share of water under the MDB long-term diversion caps established under the Murray-Darling Basin Agreement, and the watering regime under the Basin Environmental Watering Plan (Council of Australian Governments 2004). The Victorian contribution to the plan is 214 billion litres, the New South Wales contribution is 249 billion litres, the Australian Capital Territory commitment is 2 billion litres, while the South Australia commitment is 35 billion litres (Murray Darling Basin Commission 2005, p. 7). The IGMDB and its associated agreement, the National Water Initiative, are the latest developments in a long history of water reform in Australia that potentially offers significant improvement to the environmental health of Australia s water resources (Connell 2007; Connell et al. 2006). The plan includes investments in infrastructure and market-based water recovery through the purchase of water entitlements. Projects approved under the initiative are expected to deliver 240 billion litres at a cost of $179 million and, to date, eighteen feasibility studies for possible recovery of additional water have been funded (MDBC 2006b). Water through efficiency request for tenders A perceived lack of progress made by the parties to the IGMDB to reallocate water to the environment prompted the Prime Minister John Howard to declare the need to put a bomb under the process (Minchin 2006). As a result, in April 2006 the WTERT was announced and subsequently accepted by the MDBC Ministerial Council on 19 May 2006 (MDBC 2006c). The WTERT process is voluntary, and will be financed from a commitment of $ In addition, a failure to price water quality cost from use runs counter to the spirit of the National Water Initiative that states in Clause 65 (ii) that there should be full cost recovery for water services, including recovery of environmental externalities, where feasible and practical; 10. Comprising the following funding contributions: Commonwealth Government $200 million, New South Wales $115 million, Victoria $115 million, South Australia $65 million, Australian Capital Territory $5 million. 11. IGMDB was a subordinate document to the National Water Initiative agreed to by COAG in June AUSTRALASIAN JOURNAL OF ENVIRONMENTAL MANAGEMENT Volume 14

6 million by the Australian government for Living Murray water recovery, some of which has already been allocated for state projects. Water offered under the tender must be available as a permanent water entitlement, and be recovered through on or off-farm efficiency measures completed between 1 January 2004 and 30 June These efficiency measures must entirely offset the amount of water to be transferred to the government under the tender while maintaining productive capacity. The tender opened 1 November 2006, and closed 31 January Contracts for the successful tenders are to be finalised by the end of June 2007 while all water purchased under the tender must be made available no later than 30 June 2009 (Department of Agriculture, Forestry and Fisheries 2006). In addition to the tender, the Prime Minister announced on 25 January 2007 a National Plan for Water Security that includes up to $3 billion over 10 years to address the problem of over-allocation in the Basin and will include the purchase of water entitlements to increase environmental flows (Howard 2007). An important pricing issue under the WTERT is the Australian government requirement that water users tendering their water entitlements must do so to fund infrastructure that generates water savings. Over and above concerns that some irrigation water savings may contribute to reduced flows (Watson 2003), which runs counter to the Living Murray objectives, the water efficiency constraint in the tender also raises the cost of purchasing water entitlements by expenditure associated with generating these water savings. This is because in the proposed tenders water users will bid a price that must fully compensate them for any infrastructure costs they incur in generating water efficiency gains, plus the market value of their entitlements. In other words, because bidders in the tender need to be compensated for undertaking investments that generate efficiency gains, these extra costs must raise the price that will be paid by the Australian Government for permanent water entitlements. The extent to which the water savings constraint raises the price that the Australian Government will pay for water entitlements under the current tender will only be revealed after the tender process is complete. Nevertheless, economic theory suggests that the requirement for those participating in the tender must undertake water efficiency savings equal to the amount offered for sale should at least double the cost of the tender. This is because if entitlement holders were able to undertake water savings prior to the tender at a cost less than the market price of entitlements, they would - after allowing for the lumpiness of investments, the absence of credit constraints and information failures - have already made such water savings investments. To do otherwise would be to forgo the economic gains from making such investments, and then subsequently selling the surplus permanent entitlements or leasing the temporary water allocated each season to the entitlement. In other words, if investments existed that would generate permanent water savings at a lower cost than the market price of entitlements, then entitlement holders would already have made such investments prior to the WTERT as it would have been economically beneficial for them to do so. Entitlement holders bidding for funds to undertake future water efficiency gains under the WTERT will, therefore, need to cover the costs of water savings that are at least equal to the market price of entitlements plus the market value of the entitlement. The net result is that imposing a water savings requirement as a condition of sale in the WTERT is likely to at least double the Australian government s cost of purchasing water entitlements. Policy implications Despite CoAG advocating that water prices cover the costs associated with externalities, this has not been implemented yet in Australia, except indirectly via water infrastructure service provision charges that are used to pay for actions to prevent environmental damage 12. A failure to correct for the external water quality costs from water use, and the imposition of a requirement that water users undertake infrastructure projects to generate water savings, will increase the cost of purchasing water entitlements over what should be paid by governments. The result will be less water provided for environmental flows in the Murray River for the allocated budget. As a result, the latest Australian Government initiative is not cost effective: an indispensable requirement of good economic policy. If cost effectiveness is an important criterion in evaluating environmental policies, then future marketbased water recovery, such as the $3 billion proposed for buying water entitlements in a National Plan for Water Security, should not include constraints on those selling entitlements to undertake water efficiency investments. Prior to further purchases of water entitlements, consideration should also be given to introducing irrigation charges that account for water quality, especially salt loads attributable to water use (Dwyer et 12. See Productivity Commission (2003) for further details. South Australia and the Australian Capital Territory also impose environmental management charges on the water consumed to fund management operations and catchment activities. June

7 al. 2006); or a cap and trade scheme for salinity and possibly other market-based approaches to internalise the external cost of water use on water quality. Until such mechanisms are implemented, and this may take several years, it would be more cost effective to achieve environmental flow targets by the purchase of seasonal water allocations or temporary trade as a substitute (Watson 2005). This is because water entitlements or permanent trade have capitalised into their price, the failure to consider the external effects of water use on quality. Seasonal allocations are also much more widely traded than water entitlements (Heaney et al. 2006; Grafton and Peterson in press). This may help reduce concerns that government purchases for environmental flows will affect the market price and sell at a much lower price (Quiggin 2006) 13. The purchase of seasonal allocations also avoids the possibility of purchasing sleepers (entitlements that have never been used) and dozers (entitlements that have previously been used but are not currently in use) that would not increase environmental flows (Grafton 2007). The key policy insight is that for the same amount of expenditure much more water could be returned for environmental flows if the water quality cost generated by water users was internalised, and individuals were not forced to undertake water efficiency measures to sell their entitlements to the Australian Government. Concluding remarks Australia faces important water challenges in balancing current water uses against the need to maintain environmental flows for non-market values. Perhaps the greatest of all water dilemmas exists in the Murray- Darling Basin where the river systems have been in decline in terms of their environmental attributes due to water use. To improve the health of the River Murray, Australian governments have agreed to invest hundreds of millions of dollars in various environmental initiatives, infrastructure investments and in the purchase of water entitlements with the aim of returning 500 billion litres of water to the river by To speed this process, and as part of the Living Murray Initiative, the Australian Government in 2006 pledged a $200 million cash injection to purchase water entitlements through WTERT that arise from water savings measures equal to the amount of water purchased. Unfortunately, the water through efficiency tender process is not cost effective because users do not currently pay a price for water that reflects the marginal external cost of use on water quality, and because purchases of water under the current tender for environmental flows are conditional on users undertaking water savings measures. As a result, the Australian Government will end up paying at least twice as much as necessary to achieve its objective of increasing environmental flows to the Murray River. The findings suggest that strategies to implement the Living Murray Initiative need to be changed to ensure the greatest possible amount of environmental flows per dollar of expenditure. Acknowledgements We acknowledge the helpful comments and suggestions offered by Daniel Connell and two anonymous referees in preparing this article. References Bennett, J Realising Environmental Demands in Water Markets. In: Brnnett (ed.) The Evolution of Markets for Water Theory and Practice in Australia, Edward Elgar, Cheltenham. Bennett, J. and Morrison, M Estimating the Environmental Values of New South Wales Rivers. Proceedings of the Third Annual Stream Management Conference: The Value of Healthy Streams, Brisbane, pp Connell, D Water Politics in the Murray-Darling Basin. The Federation Press, Sydney. 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