Submission to the Department of Sustainability, Environment, Water, Populations and Communities

Transcription

1 Submission to the Department of Sustainability, Environment, Water, Populations and Communities Environmental Water Recovery Strategy for the Murray-Darling Basin February, 2013

2 Cotton Australia Cotton Australia is the key representative body for the Australian cotton growing industry. It helps the industry to work together to be world competitive and sustainable, and also tell the good news about the industry s achievements. Cotton Australia determines and drives the industry s strategic direction, retaining its strong focus on R&D, promoting the value of the industry, reporting on its environmental credibility, and implementing policy objectives in consultation with its stakeholders. Cotton Australia works to ensure an environment conducive to efficient and sustainable cotton production. It has a key role in Best Management Practices (MyBMP), an environmental management program for growers. This work has seen a significant improvement in the environmental performance of the industry, with huge improvements in water use efficiency, significant reductions in pesticide use, and millions of dollars invested into R&D. The Australian cotton industry directly employs thousands of Australians and this year will contribute over $2 billion to the Australia economy. Cotton Australia welcomes the opportunity to provide this formal submission to the Draft Environmental Water Recovery strategy. Cotton Australia is a member of the National Farmers Federation, the National Irrigators Council, Queensland Farmers Federation and the New South Wales Irrigators Council. Many of these organisations will also be making submissions on this draft strategy, and while Cotton Australia is confident that these submissions will reflect the views of Cotton Australia, if there is any divergence of views expressed then Cotton Australia s position is the one outlined in this paper. In addition Cotton Australia has a close relationship with a number of valley based industry and irrigation groups, including, but not limited to, St George Cotton Growers Association, Central Downs Irrigators, SmartRivers, Border Rivers Food and Fibre, Gwydir Valley Irrigators Association, Namoi Water and Macquarie River Food and Fibre Association. Many of these organisations will be making submissions, and Cotton Australia strongly endorses their concerns, and defers to them in raising catchment specific issues.

3 General Comments Cotton Australia must express its disappointment in the quality and depth of this draft strategy. As the document points out, in September last year 1577Gl of long-term water entitlement had been recovered, against the target of 2750Gl or 57%, yet this strategy has more in common with an initial discussion paper, than a well-defined strategy. In general, the language of this paper is broad, and if its purpose is to provide greater transparency and certainty to communities about the water recovery program, then this paper fails in all but the most-broadest terms. Given the considerable progress that has been made towards the required SDL reduction, and the considerable experience the Department has gained since it commenced water acquisitions in 2009, it is disappointing that this strategy does not have a much higher level of detail, and go some-way towards providing the levels of transparency and certainty for communities which was envisioned when the Standing Committee on Regional Australia recommended the preparation of this strategy. It is to be hoped that the final version of this draft, and future, regular strategy updates will provide a lot greater level of detailed, including specific information on activities planned for each catchment, using six month, yearly, three-yearly and five- yearly timeframes.

4 Specific Comment (Comments relate directly to the corresponding paragraph/section of the draft Strategy) Key Points In the northern Basin, the conduct of the Northern Basin Scientific Work Program also needs to be considered when setting water purchase priorities. The Government proposes to focus largely on the local component of water recovery in the northern Basin until this work program is finalised at the end of This approach is to be congratulated, but it needs to be recognised that the in- catchment requirement for many catchments has already been exceeded, yet there are State Priority projects which are still reclaiming additional water in these valleys. Further, it is extremely important that the purpose, breadth and detail of the Northern Basin Scientific Work Program be communicated to local and regional stakeholders as a matter of urgency, and details incorporated in updated versions of this strategy. For the time being, the Government will largely focus its surface water purchasing in the northern Basin on the unmet local environmental requirements in the Condamine Balonne, as well as groundwater recovery in the Upper Condamine Alluvium region. While this is welcomed, there is growing frustration among entitlement holders in both the Condamine Balonne and the Upper Condamine Alluvium that the Commonwealth has failed to seriously engage with them on developing a buyback framework particularly for groundwater entitlements and overland flow, despite repeated meeting requests. There is an opportunity to make significant inroads into the SDL reduction requirements in these catchments through the market, and entitlement holders and their representatives are keen for the process to commence. 4

5 B. Inquiry into the impact of the Murray- Darling Basin Plan in Regional Australia 10. In July 2012, the Standing Committee tabled a further report into certain matters relating to the Basin Plan. One of the recommendations in this report was that the Government release a water recovery strategy for consultation. This document presents that strategy as a draft for consultation. Cotton Australia strongly argues that the draft strategy falls along way short of the Strategy envisaged by the Committee and those that read its recommendations, and as previously stated in this document, believes that future versions must contain a lot higher level of detail including annual acquisition targets per catchment, and expected yield from specific infrastructure projects also on a catchment by catchment basis. 11. The Government welcomes comments from stakeholders on this document. Comments will be used to inform subsequent updates to the Strategy. Cotton Australia hopes that the next version of the draft Strategy will incorporate the level of detail requested in feedback on this draft. 2. PROPOSED APPROACH TO WATER RECOVERY 15. Water recovery from 2009 onwards contributes to the 2750 GL reduction required to meet the surface water SDLs in the Basin Plan. As at 30 September 2012, 1577 GL of environmental surface water recovery had been contracted in the Basin towards bridging the gap. This recovery included: 1094 GL of secured water purchases 316 GL received or scheduled for transfer under infrastructure works contracts 154 GL recovered through state government actions 11 GL gifted by the Queensland Government and 2 GL of other recovery. 5

6 There still does not appear to be a great deal of clarity around how much water has been recovered. For instance here it is suggested that 316Gl has been recovered from infrastructure, while further in the document a table listing infrastructure projects lists a total of 412Gls of recovery. It would greatly enhance clarity if a table, could on a catchment-by-catchment basis show details on the amount of water purchased; the amount of water actually transferred through each infrastructure project operating in that catchment, and the amount of future water expected to be transferred for each infrastructure project operating in that catchment. 17. The Basin Plan also includes SDLs for groundwater resources in the Basin. Under the Basin Plan, groundwater extractions only need to be reduced in the Upper Condamine Alluvium groundwater SDL resource unit in order to reach the SDL. Recovery actions which will bridge the gap to this SDL are yet to commence. As previously advised, Cotton Australia and the irrigators that it represents are growing increasingly frustrated on the lack of progress with and consultation on, the buyback program for the Upper Condamine Alluvium. It is Cotton Australia s strongly held position that a program developed in consultation with entitlement holders will have a much greater chance of acceptance and success than one developed by the Commonwealth in virtual isolation. B. Local and downstream component of water recovery 22. In the northern Basin, Australian and state governments have agreed to establish a program of work to be completed by the end of 2015 to review the basis for the northern shared downstream component and its equitable apportionment. This Northern Basin Scientific Work Program may include consideration of impacts of the northern Basin downstream component on the anticipated environmental outcomes of this recovery. The Strategy will be updated in 2016 to reflect the outcome of this program of work. Cotton Australia would suggest that the Strategy should be update in relation to this work more regularly than waiting till the work is completed in While in some cases, the impact on this Strategy by the scientific work may be speculative until the work is completed, updates will provide communities with some guidance on how the scientific work is like to affect the recovery strategy. 6

7 D. Future approach to surface water recovery 29. The Government s approach to environmental water recovery will be responsive to changing recovery targets due to developments such as: the distribution and volume of recoveries from infrastructure projects the operation of the SDL adjustment mechanism the final apportionment of downstream requirements between catchments. Cotton Australia accepts the above points, but the acknowledgement of them is useless unless future updates of the Strategy details the specific responses that have resulted from the above developments. Water recovery until For the period up to 2016 the Government s general approach will be to set the pace of environmental water recovery so that 2100 GL of environmental water would be acquired by 2019 if that pace of recovery were to continue to Water entitlement purchasing will be used only as a residual where the water returns expected from SRWUIP investments and other sources are not sufficient to reach this target. While Cotton Australia is supportive of the general principle espoused above, this section should provide specific detail on a catchment-by-catchment basis of the level of water recovery required, detailing how much is expected to be recovered through infrastructure projects and therefore how much is likely to have to be purchased on an annual basis. 32. In the northern Basin, the Northern Basin Scientific Work Program will investigate the shared downstream component and its equitable apportionment. The work program will be completed in In the intervening period, the Government intends to focus largely on the local component of water recovery in the northern Basin until the work program is finalised. This means that purchasing to recover the unmet portion of the northern Basin downstream component will not meaningfully begin until Cotton Australia is supportive of the above. Implementation of proposed approach to water recovery 37. The proposed approach to water recovery over the period up to 2016 gives communities considerable certainty over the volume of water purchasing which can be expected in their regions. 7

8 There can be no certainty unless specific recovery volumes are published on a catchment-bycatchment basis. 38. Pending the SDL adjustment outcomes in 2016, the need for further water purchases in the southern Basin is very limited. In South Australia no further purchase is required before In Victoria, the current negotiations to purchase water rights from the Wimmera Irrigation Area and the prospective return from a program of purchasing integrated with the implementation of the Goulburn-Murray Water Connections Program need to be factored into future purchase plans. When these two projects are taken into account, there is no further need for purchasing in Victoria before The volumes associated with these projects must be clearly stated. 39. In southern NSW there is still a need for water purchasing, but the amount of purchasing will be very modest compared with the scale of buyback over recent years. Again, unless specific recovery targets are published, statements like will be very modest have no meaning and will provide no certainty to communities. 41. Similarly in the north, the combination of contracted water recoveries and anticipated future infrastructure recovery is likely to be sufficient to meet the local requirements in most catchments in the northern Basin. The largest unmet local needs are in Queensland in the Condamine Balonne catchment. For the time being, the Government will largely focus its surface water purchase efforts on the unmet local environmental requirements in the Condamine Balonne. While Cotton Australia is generally supportive of the above statement, unless communities and other stakeholders can clearly see what recovery volumes specific projects have and are likely to deliver, it is impossible to determine whether it is the correct strategy or not. 43.Water purchasing will also be needed to bridge the gap to the SDLs in the Upper Condamine Alluvium groundwater region. This will be another priority for the water purchase program during the period before As previously stated entitlement holders are very dissatisfied with the level of engagement to date on this important recovery program. 8

9 44. Work has commenced to develop a strategic approach to groundwater recovery in the Upper Condamine Alluvium which will achieve the objectives of the Basin Plan. The approach will operate within the framework of current water sharing and compliance arrangements in that region. While work may have commenced, it has been in almost complete isolation from the entitlement holders, and such an approach leads to a heighten risk of program failure. 45. The Government is working with Queensland to progress a number of issues regarding legislative and management arrangements which will help provide certainty for groundwater entitlement holders and the Government. The Government s strategic approach to groundwater recovery will also include the most practical and cost effective arrangements for holding and managing, or retiring, the recovered groundwater entitlements. Cotton Australia understand that there are now no Queensland Government constraints to recovery of Condamine Alluvium entitlements, and therefore expects the development of this program to proceed quickly, and in full consultation with entitlement holders. 46. The Government will consult annually with Basin states on its approach to water recovery, taking into account developments such as the yield from infrastructure investments, the implementation of offset projects under the SDL adjustment mechanism and Basin states in-valley apportionment of the downstream component of the SDL reductions. This annual consultation will specifically consider the pace and distribution of water purchasing in each state to ensure these developments are appropriately considered when setting purchasing priorities. While this is admirable, progress needs to be fully reported against, and planned future recovery volumes published. Progress with irrigation infrastructure projects 57. The Australian and NSW Governments are also working together to develop a water saving project at Menindee Lakes through possible changes to infrastructure and the operating regime for the lakes. There will be public consultation as the project develops. While there is no doubt opportunities to improve the operation efficiency of Menindee, and this may result in some savings, projects at Menindee must be developed and carried out in a manner that enhances its capacity to be a critical water storage system. 9

10 Project State Priority Projects, state- led Vic - Northern Victoria Irrigation Renewal Project (NVIRP) package, including on- farm component Funds Committed (up to $m) Australian Government water savings (average annual yield GL)* Status Under way NSW - Metering Scheme, including pilot Under way NSW - Basin Pipes Under way NSW - Irrigated Farm Modernisation Qld - Healthy Headwaters On- Farm Water Use Efficiency (pilot and main project) Pilot complete. Main project contracted ($83m) Under way SA - Riverine Recovery Project Under way ($89m) State Priority Projects, Australian Government- led NSW Private Irrigation Infrastructure Operators Program SA Private Irrigation Infrastructure Operators Program Other Projects On- Farm Irrigation Efficiency Program Under way One project completed Under way (Rounds 1 and 2, $14.4m) Two rounds under way. Third round under assessment. River Murray Improvements Program (SA) In development Strategic Sub- System Reconfiguration Program 200 TBD Program design in final stage *These figures are indicative only - some elements may not yet be under contract and others include potential recoveries. This table does not include water saving from projects which have been agreed only in principle, unallocated SRWUIP funds or water savings from groundwater. 10

11 The totals in this table appear to be at odds with other reports in this document on the amount recovered (to be recovered) from infrastructure, once again highlighting the need to clearly report on a catchment-by-catchment, project-by-project basis. C. Review of river operations 67. For instance, the Australian and state governments are jointly reviewing the Murray- Darling Basin Agreement to examine options for more efficient river operation arrangements in the Basin. This review is expected to report in A River Murray System Operations Review is also underway. While Cotton Australia does not rule out supporting rule changes it is extremely wary of them, and will not support them if there are any uncompensated third party impacts. What type of water entitlements to purchase 74. Ultimately, a balanced portfolio of entitlement types will provide water to meet the environment s needs in a range of water availability situations. For instance, high reliability entitlements provide water in periods of low water availability and are therefore best suited to maintain base flows in rivers and protect drought refuges. Medium-to-low reliability entitlements may be the most cost-effective way to increase the size or duration of beneficial flood events to support vital floodplain ecological processes. However, their usefulness during drought is limited. Cotton Australia considers the last part of the above paragraph an interesting comment, given the lack of an environmental water plan, which could at least go someway towards comment on the usefulness of particular water entitlements when compared with others. How the Government s water purchase program has affected sellers 83. A survey was commissioned in late 2011 to gain a better understanding of the impact of water purchasing on irrigators. A summary of the survey results is presented in the following box. 11

12 While this survey may be of some interest in itself, Cotton Australia does not see it relevance as part of this Draft Strategy. Further, given purchases to date have been from willing sellers, it should be a matter of alarm not congratulations that only 80% have considered selling to the government was a positive decision. ends 12