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									                                                                       Murray Darling Basin Authority
                                  Issues Paper –Development of Sustainable Diversion Limits MDB 2009


    Swan Hill Rural City Council response to the Development of Sustainable
          Diversion limits for the Murray Darling Basin Issues paper

Introduction

Our Mallee communities understand the intrinsic nature of the Murray River. Any
changes to water allocations will impact greatly on the diversity and prosperity of
our region. Resilience is a key character of the Mallee community, and this has
been clearly demonstrated by farming practices in this diverse landscape. Mallee
communities accept the need to change, they must be provided with extensive
transparent information. Only then will our community begin to understand and
accept a new system of water management in the Murray Darling Basin.

Swan Hill Rural City Council (SHRCC) is questioning the time lines allocated to
this Basin Plan, whilst Council accepts there needs to be set parameters to
ensure that the millstones are achieved. SHRCC is disappointed at the lack of
stake holder and community notification of this important issue paper release

Risk management has not been addressed in this issues paper. Risk
management issues are clearly entwined though out the Basin Plan. Current
integrated business practices consider risk management to be part of a holistic
management process. Effective asset management applies a logical and
systemic method of establishing an understanding the uncertainty or potential
deviations from what is planned or expected (A/NZS 4360:2004).

Water is a complex issue in the Murray Darling Basin (MDA) and any change to
management requires extensive community consultation and engagement at all
stages of the Basin Plan development. Completing the Basin Plan as such speed
appears to be driven by government policy that will compromise the ability of the
region to adapt to the changes. If this approach continues the process will be
responsible for the direct and hard hitting impacts on our community without any
time for people to adapt to the circumstances.’


Council has scoped our response around the questions asked in the paper and
remind the MBDA the North West Victoria region will be significantly impacted by
these proposed changes. And although we are typically resilient our communities
require extensive consultation and engagement though out the development of
this Basin Plan.

SHRCC is asking the MDBA to remember we are a diverse community and all
future documents must be in plain English and provided in templates that provide
the opportunity for multilingual community’s access to translated documents. This
will ensure all members of our community have the opportunity to understand
and comment on these changes to their livelihood.
                                                                         Murray Darling Basin Authority
                                    Issues Paper –Development of Sustainable Diversion Limits MDB 2009


SHRCC responses to questions from the MDBA Issues paper:

What are your views on the proposed approach to determining WRP areas
as set out in this paper? (Water Resource Plans WRP areas)

The Murray River is the state boundary between Victoria and NSW, historically
these states have addressed water issues separately and often there has been a
minimal whole Catchment approach to Riverine Landscape management. The
Basin plan provides the opportunity review the current Catchment Management
Authorities (CMA) processes.

   •   The existing CMA’s are state based and their functions are duplicated,
       rationalising of resources and processes would result in improved
       Catchment management and a significant reduction in bureaucratic
       processes.

   •   For example, explore the option of reviewing the Catchment Boundaries,
       and develop a federally administered Catchment Management Authority or
       similar for the whole of the Murray Darling Basin.

   •   Projected reductions in water availability and allocation will have
       significant impacts on the Catchment. The WRPS with a whole
       catchments focus will provide the opportunity to review plan and
       implement initiatives to rationalise water use and gain the projected
       savings required.

   •   The issues paper does not consider waterwise options to be a priority over
       a reduction in allocations. Changes to the allocation system will cause
       significant economic and social impacts, and should be considered as last
       resort.

   •   Alternative options to this have already been demonstrated by the
       Victorian Government Water Savings initiatives, -The modernising and
       rationalisation of the distribution system. The Wimmera Mallee Pipeline
       and the Woorinen Irrigation District Restructure projects. These include
       renewal of old distribution infrastructure i.e. piping and lining of channels,
       with modern systems to save water and improve efficiency.

   •    Rationalising the number of channels and infrastructure or modifying the
       level of service.

The Northern Victorian Irrigation Renewal Project (NVIRP) is a great example of
rationalisation and renewal. This is partially completed and the savings already
achieved have been used to meet the Victorian Governments commitment to
increasing environmental flows in the Living Murray Project and the Snowy River
Water Recovery project.
                                                                        Murray Darling Basin Authority
                                   Issues Paper –Development of Sustainable Diversion Limits MDB 2009




   The WRPS must provide the opportunity to implement similar water wise
   savings projects before SDL’s are determined. The NSW irrigation system
   upgrade is far behind Victoria and there are untapped significant savings to
   be captured with in the basin and the WRPS must identify and pursue these
   opportunities as a key objective.

Do you have any suggestions you would like to provide to the MBDA in this
regard

The socio-economic impact of access (or lack of access) to water has an effect
on communities on both sides of the borders. This is mainly applicable to Vic &
NSW as the southern NSW municipalities rely heavily on the Victorian towns and
cities as their main commercial base; i.e. Mildura with Wentworth Shire, Swan
Hill & Gannawarra with Wakool and Balranald. The Victorian municipalities
mentioned also rely on the economic input from the NSW towns / municipalities.

   •   The Riverine towns in the Gannawarra, Campaspe, Wakool and Balranald
       and Moira Shires to be in decline regardless of the proposed changes to
       land use practices.

Council is concerned reductions in allocation of water will be in direct contrast
with the current State Government Policy Directives that strive to support the
economic and sustainable development of Victorian Regional Communities.

   •   Gillespie & DCA Economics (VEAC, 2006) support Council’s contention
       that at an individual level there will be a range of potential impacts
       resulting from the loss of employment for individuals and their families.
       They include financial impacts, reduced future work opportunities, and
       reduced participation in mainstream community life, strains in family
       relationships and intergenerational welfare dependency.

   •   Similarly, the flow on effects to the value adding to the timber products
       industry has not been considered. This industry contributes over $900,000
       million (RMCG, 2009) to the regional economy and provides valuable
       opportunities to diversify the community skills base and cannot be readily
       dismissed.

   •   The adjacent NSW municipalities are also an important food source for
       Australian consumption and export.

   •   The 2005-2006 annual gross value of agri- production was $2.2 Billion at
       farm gate; this represents 10% of national and 25% of NSW total
       agricultural production. The region produces a wide range of summer and
       winter grains, crops, fruit, vegetables horticulture, viticulture dairy and
       livestock (RAMROC ,2009)
                                                                       Murray Darling Basin Authority
                                  Issues Paper –Development of Sustainable Diversion Limits MDB 2009




   •   Furthermore a socio economic review RMCG (2009) of the Municipality
       Wakool NSW (adjacent to Swan Hill) identified the level of socio economic
       impact will be linked to the volume of water that may be removed from the
       region. Irrespective of how the water is lost there will be significant
       regional impacts through the loss of agricultural production and flow on
       losses to the regional economy.

   •   Farm businesses that sell the water receive an injection of funds to help
       adjust to the changed circumstances. However, the flow-on impacts of a
       significant drop in the rural economy due to the loss of water will be
       pronounced but there is no adjustment support for those remaining in the
       region.

   •   The current buy-pack proposals will see the area face a significant change
       over a couple of years that would, under normal circumstances, generally
       occur over a longer time frame.


The CMCG, (2009) review considers that the surivability of the region is
dependant on the ability of the community to implement changes in practices
these would include:
   • Facilitate adaptation

   •   Support Services to the community

   •   Promotion and support to develop alternative enterprises, including higher
       value agriculture or industry to replace some the investment returns
       currently generated by irrigation water.

   •   Partner agencies in the region reinforces the requirement for a high level
       of community consultation to occur upon release of the draft Basin Plan
       i.e. enabling adequate time for regions to digest and understand the plan,
       identify how it will impact on each of the regions and determine what the
       implications are.

Extensive consultation and engagement must occur within all regions and be
open to all levels of concern from industry, community and government to ensure
that specific needs and regional issues are captured and incorporated into the
determination of the SDLs. And each region develops a sense of ownership and
commitment to the implementation of these plans.
                                                                       Murray Darling Basin Authority
                                  Issues Paper –Development of Sustainable Diversion Limits MDB 2009




What are your views on the proposed approach to treating interception
activities as set out in this paper?

Which interception activities are significant enough to be explicitly
identified in the SDL provisions?

The examples used in the document of forest plantations and farm dams have
positive environmental impacts on regions and whilst not advocating these
activities should be exempt from the SDL process, they need to have their
positive impacts on the overall regional environment balance out the “significant
impact” they may have on the Basin.

   •   If we consider the climate change scenario, and the need to capture
       carbon using large scale plantings, such proposals will not be taken up as
       readily by landholders. There are considerable advantages to planting
       plantations, especially in previously cleared degraded land that if left
       would contribute to erosion and sediment runoff. The large scale clearing
       and dry land farming practices have impacted greatly on the fragile North
       West soils, the drying times are encouraging farmers to consider
       increasingly sustainable crops/plantations that minimise impact on the
       landscape.

   •   This becomes a socio economic argument if Government Policy continues
       making staying on the land too difficult there will be increasing abandoned
       landholdings. Future carbon sequestration opportunities must be
       supported and encouraged not penalised by further prohibitive costs i.e.
       water access licenses.

Irrigation district modernisation programs in Northern Victoria are returning
considerable volumes of water to the Basin system. As this process achieves its
targets the emphasis on interception activities can potentially be reduced.

   •   There has been no mention of the urban setting and the potential impacts
       the Waster Sensitive Urban Design (WSUD). The townships along the
       Murray River System incorporate storm water retention basins,
       constructed wetland treatment systems, storm water capture and reuse,
       and aquifer storage.

   •   The issues paper does not address these innovative water management
       techniques and the questions need to be addressed. Will these activities
       be in the future Basin Plan? And will they attract a license fee payment?
       The region has been proactive in installing many of these types of
       systems and now will be penalised for such innovation.
                                                                       Murray Darling Basin Authority
                                  Issues Paper –Development of Sustainable Diversion Limits MDB 2009


Council’s concern is by including these storm water systems in the SDL program
innovation and motivation will be lost in future generations.

What are your views on the proposed approach to optimising economic,
social and environmental outcomes through SDL’s as set out in the paper?

Whilst the main thrust of the document is of an environmental nature, the
repeated acknowledgement of the socio – economic impact on regional and rural
communities recognised as a genuine attempt to strike a balance.

   •   It must also be stated again that any economic study needs to cross
       borders and that Local Government economic development units in all
       states would have data supporting the fact that we are all reliant on
       business patronage from communities across the border. The smaller
       towns in turn are also heavily dependant on the larger centers across the
       borders as their primary commercial centre.

The proposed approach is the most balanced way to ensure that no one
stakeholder is adversely affected ahead of another.

   •   In the Mallee region there are thousands of hectares of irrigated
       permanent plantings of almonds, grapes, olives, avocadoes and citrus
       which require a reliable annual allocation to maintain productivity and
       continuity of those plantings. The recent dry period and the associated
       reduced water allocations have seen thousands of hectares of perennial
       crops taken out of production. This has had a significant impact on the
       socioeconomic health of the region. It is therefore important that the
       proposed SDL mechanisms take into account the need for reliable annual
       allocations to support these industries.

   •   Tourism is a major industry for this region, which has not received much
       attention in the SDL issues literature. Any potential negative economic
       impacts resulting from the Basin Plan will need to be taken into account.

What is the best way to maximise input from particular communities of
interest in the time available?

There are many forums that facilitate discussion across regions of municipalities
in Victoria and NSW. The Murray River group of Councils and the NSW
equivalent (RAMROC) is an opportunity to allow Mayors and CEO’s from the
entire region to enter the discussions at the same forum.

   •   Councils and Shires that neighbour each other in NSW and Victoria
       regularly meet to discuss cross border issues and how to best assist each
       other in various matters of mutual concern (e.g. river crossing upgrades,
                                                                       Murray Darling Basin Authority
                                  Issues Paper –Development of Sustainable Diversion Limits MDB 2009


       health care, transport/freight and environmental issues) these forums
       could also be used as vehicle for communicating.

   •   Water Services Committees and various irrigation modernisation
       committees also need to be involved in the process as they represent a
       significant number of, and a cross section of the various stakeholders
       such as Torrumbarry Reconfiguration Asset Modernisation Scheme
       (TRAMS) and the Torrumbarry Irrigation District Water Services
       Committee

   •   Future community engagement plans and activities must take account of
       the health and wellbeing of communities and individuals alike. Particularly
       in the context of the difficulties and stresses people are under due to a
       combination of factors associated with climatic driven water availability
       and market conditions. Ad a seemly endless change management
       process driven by government at all levels.

Communication plans must be developed to the highest possible standard with
clear and consistent messages being delivered by all agencies involved in the
Basin Plan development and implementation.


Do you have any suggestions you would like to provide to the MBDA in this
regard?

All Councils and Shires are producing or have produced community plans across
their respective municipalities and the regular gathering of interested community
members could be utilised as an opportunity to communicate with sections of
affected communities.

   •   By utilising the resources available within Councils and Shires to contact
       and assemble sections of communities at forums such as community
       planning meetings and water services committees etc, but do not expect
       Councils and Shires to be the communicator.

The message being provided to communities must come from the MDBA.

Examples of Successful engagement strategies

   •   The Mallee environmental watering program instigated at a time of full
       irrigation allocation generated wide spread community support as
       demonstrated by significant donations of water by the irrigation
       community.

   •   When stage 4 water restrictions were enforced, concern and anxiety within
       the Mallee community followed. There were misconceptions surrounding
                                                                       Murray Darling Basin Authority
                                  Issues Paper –Development of Sustainable Diversion Limits MDB 2009


       environmental entitlements, the governing rules and rights and how this
       influenced irrigation entitlements. This contributed to negative media
       attention, frustration from the irrigation community and vandalism of
       environmental water delivery infrastructure.

   •   Extensive community engagement has been carried out over the last few
       years to gain support and acceptance of the environmental watering
       program on the founding principle that environmental entitlements were
       governed by the same rules and rights as other consumptive users.

Success of this program is due to the same treatment of environmental water
and irrigation water for seasonal allocation.

   •   Slowly the North West communities have developed a sense of ownership
       and empowerment surrounding environmental water. As a result Mallee
       CMA has been able to sustain an active water donation program with local
       irrigators during the dry times.

   •   The Basin Plan proposes to treat the environmental share of the Basin
       water resource differently to other forms of diversion.

   •   The Victorian water model states equal rules for environmental
       entitlements (treated as a consumptive user) as to other users. Over time,
       this model has generated understanding and respect from the community

Council is concerned such a command approach will jeopardise the community
support that has been built over time, by altering the foundations that underpin
the relationship – equality for all consumptive users.

SHRCC engaging the community

SHRCC has worked extensively with the community to engage our community,
Gone are the days of “telling” the community what will be happening. The
engagement process has included developing a transparent and open
organisation that has a proven record of listening and working for the community

This has been achieved by extensive use of media, developing and
supporting focus groups in urban and rural townships.

SHRCC proven engagement techniques include:

   •   Media Release - Summaries detailing what is in the regional WRP. Use
       plain English and the key multicultural languages of the community. To be
       published in the local papers Sentinel, Guardian, DSE Magazines Dry land
       and Horticultural Farmers editions.
                                                                        Murray Darling Basin Authority
                                   Issues Paper –Development of Sustainable Diversion Limits MDB 2009


   •   Providing invitations to attend a Community Forums in Swan Hill and or
       Robinvale. MDBA must implement best practice interactive community
       engagement techniques; provide an opportunity for the community to be
       heard.

   •   To maximise attendance provide: transport, meals and accommodation for
       key community stakeholders to attend. The Community Representative
       Groups are also another avenue to disperse information to remote rural
       and urban centers.

   •   The MDBA must remember the changes to entitlements will have
       considerable impacts on our resilient communities. Taking the MDBA
       communities on the journey explaining the each step and listening to their
       perceptions of what is the best way to manage this delicate bioregion, will
       ultimately result cohesive support of change.

Council strongly suggests that the Basin Plan consider maintaining and
developing further the strong existing community relationships which are based
on involvement and understanding of water management systems.

What are your views on the proposed approach for dealing with surface
water – groundwater connectivity as set out in the paper?

The approach to set separate SDL’s for groundwater and surface water appears
to be the most suitable way to ensure that quantities / volumes are not double
accounted.

   •   The issues paper concentrates primarily on rural surface water
       movements and the potential capture of these volumes. It needs to
       capture potential volumes that are generated from urban run off in larger
       rural centres and harvested for re-use. In some circumstances these
       volumes are significant and have a bearing on the figures stated in the
       section titled rainfall and hydrology (3.1.2).

There is a concern of the simplistic approach proposed to determine which
interception activities could have a significant impact on the Basin resources

Do you have any suggestions you would like to provide to the MDBA in this
regard?

There is potential for the approach described for determining the level of ‘take’ to
unfairly bias those who have meters where the level of take can be quantified.

The Basin Plan needs to clarify how these categories of interception that are not
currently metered or measured (for example Authorised interception of
                                                                         Murray Darling Basin Authority
                                    Issues Paper –Development of Sustainable Diversion Limits MDB 2009


floodplains or stock and domestic farm dams) will be quantified and monitored
particularly those that are currently unmetered or unregulated.

   •   The North West farmers are committed to longterm farming success by
       protecting the fragile soils of the region. This is demonstrated by the
       implementation of sustainable land management systems: these include
       stubble retention, improved vegetative cover and mulching. These
       systems increase the level of water interception and retention to prevent
       soil erosion and rising saline groundwater tables.

   •   The land management systems of the MDB include extensive revegetation
       (afforestation) activities. Extensive plantations and protection of remnants
       patches have been incrementally increasing over the last decade.
       Providing environmental benefits such as improving biodiversity values,
       fixation of carbon reduced soil erosion and reduced groundwater
       accession. This is particularly important in regions like the Mallee where
       annual evaporation is up to seven times greater than rainfall.

   •   The test of significance should also consider the evaporation rates within
       various regions as those with high evaporation rates has minimal
       contribution to groundwater recharge or surface water run-off, thereby
       minimising the significance of interception.

SHRCC strongly appose the inclusion of perennial plantings (such as orchard
and vineyards) may also be considered as another form of afforestation with
‘incidental interception’. If this was to be the case, irrigators may be required to
hold two forms of water access licenses and SHRCC considers this double
accounting.


What are your views on the proposed approach to setting and expressing
SDL’s as set out in this paper?

It is a particularly complex issue which the discussion paper acknowledges will
require more detailed consideration with stakeholders to refine the process.

Council currently is not in a position to comment on the proposed approach as it
would require substantially more time than is available, to study and discuss the
process to assist in making an informed comment.

Do you have any suggestions you would like to provide to the MBDA in this
regard?

In the North West region, as described in the CSIRO Sustainable Yields Project,
highlights the convoluted approach required when you consider the legislative
application and management of water extraction and use.
                                                                        Murray Darling Basin Authority
                                   Issues Paper –Development of Sustainable Diversion Limits MDB 2009




    •   This is further exasperated by the fact that the MDB Catchment includes
        three states, Victoria New South Wales and South Australia.

    •   MDBA needs to clearly identify the institutional arrangements that will be
        required for the interaction of each of the zones and the management of
        the SDLs especially when the implementation of their respective WRP is
        staggered from 2011 to 2019 (Victoria).

    •   This is an exceptionally long implementation period, and there needs to
        be specific measures to determine the impacts of the plan on economic
        and social wellbeing for each region.

SHRCC considers MDBA should conduct quarterly reviews ranging from broad
scale to a local scale. Using well researched current data set, will demonstrate
an understanding of the regions dynamics.

For example the need for water security during the irrigation season any changes
to availabity will impact on industry and our communities become evident.


Conclusion

In conclusion Swan Hill Rural City Council thanks MDBA for the opportunity to
provide comment on this important issues paper. The Murray River is the life
blood of this region. Council and the community wish to remind the MDBA of the
significant consequences this Basin Plan will have on our region.
                                                                      Murray Darling Basin Authority
                                 Issues Paper –Development of Sustainable Diversion Limits MDB 2009




References

A/NZS (2004) Australian & New Zealand Risk Management Standards A/NZS
4360:2004.

Gillespie & DCA Economics (2006) VEAC, River Red Gum Forests Investigation,
Discussion Paper, October 2006.

Moor, T. & Nichol M, (2006), Economic Contributions of the Timber and Related
Vale adding Industries to the North Central Murray Area, Latrobe University
Economic Development unit Bendigo, Victoria.

NRSWS, (2009), Northern Region Sustainable Water Strategy, Victorian
Government, DSE, 2009.

RMCG, (2009), Socio-Economic Impacts: Closure of Wakool Irrigation District (or
parts thereof) Final Report, RMCG Consultants for Business Community and
Environment. Bendigo. Victoria.

RAMROC, (2009), Riverine And Murray Regional Organisations of Councils,
www.ramroc.org.au/home/index.htm
                                                                    Murray Darling Basin Authority
                               Issues Paper –Development of Sustainable Diversion Limits MDB 2009




Appendix 1 Remplan impacts on regional employment North central Murray

								
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