Submission by Bob Richardson for Plug The Pipe

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Submission by Bob Richardson for Plug The Pipe Powered By Docstoc
					From: Bob Richardson

           Submission by Bob Richardson for Plug The Pipe

My comments will primarily be concerned with the North-South pipeline and the
associated modernization of irrigation infrastructure that the government has linked
by nominating a portion of “savings” from the modernization to be diverted to
Melbourne via the N-S pipeline.

Section 1 -Approval process for Food Bowl and Pipeline Expenditure
           •     An early prominent advertisement from the “Food Bowl Unlimited
           Group” depicted losses in graph form, of 900GL per annum from the
           channel system targeting savings of half the loss – 450 Gl per annum -
           under Stages 1 and 2 of the Food Bowl Modernisation Project.
       This has evolved with the government now targeting savings of 519.6[1] GL,
       including 225Gl from Stage 1 and 200Gl from Stage 2 of the modernization.
       Clearly, with losses over the whole system of only 370 Gl in 2007 and an
       estimated loss of less than 300 Gl for 2008, much of which is not recoverable -
       the Kerang Lakes; a Ramsar wetland - loses 70-100 Gl depending on the
       season – such savings are mathematically impossible to achieve.
           •     The Auditor General‘s report “Planning for Water Infrastructure in
           Victoria[i] released on the 9th April, 2008 highlights the absence of
           rigorously made estimates of water savings underpinning modernization
           and hence the N-S pipeline.
        The Attorney General's report includes the following para: 3.4.5 “Information
       provided on the food bowl project did not adequately explain the basis for the
       water savings estimates --- ------ At that time the supporting documentation
       consisted of the submission by the Food Bowl Alliance advocating the project.
       We found this documentation did not have the depth of analysis and level of
       rigour commensurate with a project business case.
       The Government formed the food bowl steering committee subsequent to the
       announcement of the Victorian water plan. The committee’s terms of reference
       focused on the arrangements and rules for implementing the project. The audit
       notes that the committee did not have a remit to verify the water savings
       estimates on which the project is based. ---- Also “---- a wide range of
       individuals and organisations raised concerns about the basis for the
       projected water savings” ----

       Despite the Attorney General’s Executive Summary -dot point 1.3 - including
       the request “DSE should publish the detailed analysis underpinning the
       estimates of water savings and costs for the food bowl modernisation project”
       and despite calls from groups as varied as the CWA, the VFF and a large
       majority of Municipal Councils; to date no verification has been provided.

           •     It should also be noted that in the governments rush to push through
           with the building of the North-South Pipeline, a planning approval process
   was adopted that did not permit querying the issues raised by the Auditor
   General - the “Terms of Reference for the Appointed Advisory
   Committee[ii] “(viz. “It must be noted that the strategic policy decision in
   relation to the intended allocation of water savings from the Goulburn-
   Murray Irrigation District is outside these Terms of Reference, and is
   not a matter for review”, confining the numerous presenters to the Panel
   Hearings to the pipeline route – the Panel making clear submissions
   outside this would not be formally received.

Viz: The (Project Impact Assessment- PIA) Panel in its report[iii] wrote

 ‐ “1.6 The Role of the Advisory Committee” ‐  
“At the outset of the hearings the Advisory Committee made it clear that all
submissions (and evidence) should focus on the tasks set out in Section 3 of the
Terms of Reference. In particular, the Advisory Committee noted that it could
not make comment or findings in relation to the policy decisions underlying
the Sugarloaf Pipeline Project”.

Though subsequently the Advisory Committee has acknowledged there was
widespread dissatisfaction with the terms of reference reporting (page 18)
------- “there was consistent and unrelenting criticism of the Terms of
Reference and the role of the Advisory Committee, with the key concerns

• The proposal should have been assessed as part of an Environment Effects
• The time allowed for reading the PIA report and making a submission was
• The work in the PIA was incomplete and did not allow for full consideration
of the project;
• Additionally, work is still being undertaken and is not able to be assessed;
• There is no Environmental Management Strategy or Plan to review;
• Submittors are not able to debate the proposed water savings, where they
come from and whether the project is viable and feasible; and
• Issues relating to the downstream impacts below Goulburn Weir could not

Accepting that these issues are outside the Terms of Reference, the Advisory
Committee acknowledges these concerns as raised by submittors”---------.

So whilst excluding submittors comments on what are clearly the policy
decisions underlying the Sugarloaf Pipeline Project - for example the measure
of savings - the Panel, despite the statement in the preamble to their report -
drew a number of conclusions which are contestable and relevant as to
whether the Panel members were adequately informed in making their
For example in relation to the Auditor General the Panel wrote ---- “Finally,
the project costing and benefits were strongly questioned by submittors,
especially after the Auditor General – Mr. Pearson’s comments on
(specifically) the Victorian Water Plan. Most of these comments however did
not represent the balanced remarks made by the Attorney General which
centred around the very short time frame for development of project elements
and a consequent lack of community consultation and information provision”.

Given the comments by the Attorney General, summarized in the executive
summary “DSE should publish the detailed analysis underpinning the
estimates of water savings and costs for the food bowl modernisation project”
the Panel should not have had it both ways – either the submittors remarks
should have been considered in their entirety, or the Panel should have
reported on the Attorney General’s comments more comprehensively.

Another area where the Panel has reported on policy in an area germane to the
quantum of actual savings – relates to groundwater recharge and to run-off ---
(Page 82) “The Committee does not accept the proposition put by Acheron
Valley Watch that the savings derived from the Food Bowl Modernization
Project should not be available to the Sugarloaf Interconnector Pipeline
because a portion of them contribute to the downstream environment. The
Committee accept that many of the losses from the irrigation system contribute
to groundwater recharge and to runoff. But, the consequences of these are not
necessarily positive for the environment. Rather, losses to evaporation and
evapotranspiration are incurred; the waters mobilise salinity and cause water
tables to rise”.
These  assertions  do  not  address  the  significant  return  flows  raised  by 
Acheron  Valley  Watch,  that  are  reinforced    by  CSIRO  research  in  the 
publication Water for a Healthy Country[2] “----A study looking at changes
to return flows from irrigation management changes in NSW and Victoria
since 1993/94, estimated a reduction of 90 GL/year[3]----. (Page 24) “
Environment Victoria [iv]refer to this CSIRO study in their response to the
“Our Water-Our Future Study of 19 June 2007, acknowledging that
conservatively 10% of irrigation water will be lost to the environment from
channel modernization and go on to say ----- “The Government must ensure
that the modernisation project increases the Environmental Water Reserves
for the northern rivers rather than undermining them. –“
Apparently the Panel were inadequately informed in drawing their
conclusion to the valid issue raised by Acheron Valley Watch, affecting
the level of savings from modernization - which to reiterate – savings,
that are central to the pipeline’s being – Minister Madden stating in his
referral[v] to Federal Minister (Page 1) “Water for the Sugarloaf
Interconnector will be sourced from savings achieved through the
modernisation of irrigation infrastructure in the Goulburn-Murray Irrigation
District. Stage 1 of this program of irrigation modernisation works, known as
the Food Bowl Modernisation Project, aims to capture up to 225 GL
(gigalitres) of water that is currently lost due to inefficiencies in the
Goulburn-Murray irrigation systems”.
       Given all this, it reprehensible that these projects; particularly the North-South
       pipeline, were permitted to proceed without savings being quantified and the
       assessment independently verified. This failure is clearly detrimental to the
       farming community, the environment and ultimately the pipeline.
       One conclusion is obvious - there are no substantial savings from the Food
       Bowl Project as promoted, that would justify a major new customer,
       Melbourne Water being permitted to draw water from the highly stressed
       Murray Darling Basin to the detriment of the environment, critical human
       needs and food security.
       Clearly, the calculation of benefits is dependent on a reasonably accurate
       assessment of the net (water) savings from the channel and delivery system
       modernization – an exercise the government continually avoids with the usual
       spin. An example is the current advertising in the Melbourne media, emotively
       highlighting the government’s program of fixing “leaky old channels” to help
       secure Melbourne’s future water supply.

Section 2 - Benefits for Irrigators and their Communities
            •     There is much misunderstanding about the sources of funding -
            Stage 1of the modernisation - $100m is to be funded by the irrigators
            themselves, Victorian taxpayers, (this includes the rural community) are to
            contribute $600m, whilst Melbourne Water customers are listed to
            contribute $300m.
       Stage 2 of the modernization is subject to due diligence (whatever that means
       in the context of the processes so far) is understood to be funded 90% of the
       cost - up to $1billion by the Commonwealth Government.
       Despite this government advertising and media statements often portray the $2
       billion funding is all their own work. (It should also be noted the $1billion in
       Federal funds was promised by the previous (Howard) government).
       For all this, the benefits to irrigators and their communities remain ill-defined.
       I expect this will become clearer in submissions from those directly affected.
       Suffice to say the following are a number of issues, of which I am aware, that
       are of significant concern and indicate that some of the so-called benefits are
       far from positive.
            •     Plans for over 800 dairy farmers and 350 mixed farmers to exit
            from Irrigation Districts as disclosed in the Victorian Government’s Food
            Bowl Modernisation Project Draft Report released for public comments
            closing October 2007 are grossly inequitable and socio-economically
       In the final report released shortly afterwards, this virtual social engineering –
       stemming from the modernization of the main channels and leaving many
       irrigators located on the spur channels with insurmountable logistical
       problems to retain water, was not refuted and is seen to be carried forward in
       the Northern Region Sustainable Water Strategy.
            •     With regard to the NRSW Strategy, where the area subject to
            modernization forms the major part, the viability of vast areas of
            irrigated land are placed in jeopardy by the recommended “trigger
            point” to set aside reserve when allocations reach 30%.
       The reserve trigger is set at a ludicrously low level that in many more years
       than is necessary would see farmers with insufficient water supply, to ensure
       adequate crop and pasture growth – again this is primarily a device to protect
       the security of urban supplies (north-south pipeline), with scant regard to
       irrigators – with the smaller family orientated businesses most affected.
       The reserve measure is a further devaluation of farmers’ assets that are
       continually under attack; primarily from major urban interests, but also major
       corporate interests that have encroached on long standing “water rights”
       ensuring our food security. With no proposal to compensate for their growing
       losses; these farmers face gross injustice under the reserve proposal.
            •      There is concern that there has been poor targeting of modernization
            works with major cost blow-outs and unfair imposts on farmers from
            changes to metering. Assertions by the Plug the Pipe Group (currently
            2700 members); opposed to the North-South Pipeline, in a News Release
            dated 21st August “Brumby steals water from farmers”- included the
       “The cost benefit of replacing the old Dethridge Wheel has to be questioned
       with average cost of replacement in the Shepparton Irrigation District blowing
       out from $10,000 to $33,000. Much of the food bowl investment will be eaten
       up by non productive capital investment.”
       “farmers will receive less and more expensive water because of the metering
       changes. A more sensible approach would be to recalibrate the 18,000
       Dethridge wheels by 1.9% thereby making them fall into the National
       Standard and avoiding huge replacement and operational costs.”
            •      It is understood that only 1% of channels are to be piped in the
            modernizing process and that the main lining of leaking channels is a
            heavy black plastic. Traditionally leaking channels repairs have involved
            clay lining – a usually effective and relatively maintenance free process.
            Concerns have been raised that the plastic is unlikely to be durable, has
            occupational health and safety issues and will require a substantial degree
            of maintenance – a cost that would be borne by the irrigators.

Conclusion (Sections1 and 2)
      There is much validity to the conclusion the Government is using what has to
      be emphasized is a partial upgrade of a significant State Government owned
      asset (the Irrigation System) that produces the food that is essential for the
      people of Melbourne and beyond, as reason to take water from a highly
      stressed system.
      The North-South Pipeline and associated water grid, puts at risk the future
      security and investment in a real food bowl that contributes annually over $8
      Billion to the GDP of the State’s economy and is the source of the majority of
      the fresh, clean food and milk coming from our Supermarket shelves.
      For those in doubt that the pipeline is all about water security for Melbourne
      and its environs the following quote from the Project Impact Assessment for
      the North-South pipeline, drawn up largely by the proponent, Melbourne
      Water is very telling --- “The Sugarloaf Pipeline[4] will contribute 75
      GL/year to Melbourne supplies. This will also allow Melbourne’s storages to
      recover more quickly to restrictions and may allow increases in environmental
      flow releases in the Yarra and Thomson Rivers” ---

Section 3 - Environmental costs
           •     With the emphasis on the North-South Pipeline as the keystone of an
           ever expanding urban pipeline grid sourced from the Goulburn and Murray
   Rivers the environment as well as the farmers are losers. With savings to
   be divided 1/3 each to the North-South Pipeline, 1/3 to the environment,
   1/3 to farmers and with urban interests served in the pipeline having a
   priority, there will be very little water for increased environmental flows
   despite the massive expenditure and government hype. (In fact the
   proportion of “environmental water savings” may struggle to compensate
   for water previously out-falling to rivers).
   •      Physical environment costs. A major cost of the North-South
   Pipeline is the environmental damage to more than 70 kms of picturesque
   landscape extending from Killingworth/ Yea to Yarra Glen. This is a major
   tourist area and route that is seriously blighted. The loss to the property
   owners ascetically and as an adjunct to their farm businesses; to tourism
   and the general public’s ascetic appreciation of the area, is very

The Panel report (page 61) describes the effect in terms of area ----- “the lack
of available information for planning has serious implications for protection
and management of ecological values along the pipeline route, and further
surveys should be completed prior to construction. The area of native
vegetation to be removed, calculated at 121 hectares, includes 10 hectares in
the north, 65 hectares in the central area (including a 30 metre wide strip
through Toolangi State Forest) and 45 hectares in the south. DSE native
vegetation mapping used by the Alliance indicates the need to achieve 200
habitat hectares of offsets across three bio–regions”.

 This is an environment that cannot be replaced, a point made by several
submittors to the panel summed up by the statement page 61-----providing for
offsets elsewhere would not solve local fragmentation, connectivity or
diversity loss. --- considered it essential to focus on biodiversity as a whole
and not just endangered species. --- opinion was that a “critical network of
corridors” must be maintained for habitat connectivity and species diversity.

As is clearly seen by the works in progress, any ameliorating measures
included in the approvals governing the works, are seen as near worthless.
This is an indictment of the Panel process (used by the government to
circumvent the more rigorous and encompassing EES process) and the process
of Federal Government approval under the EPBC Act.
The Panel’s involvement in this process should be highlighted - despite
referring to the lack of available information for planning and despite some
excellent presentations by environmentally qualified submittors as outlined
above – the members have effectively endorsed the Victorian Native
Vegetation Management Framework, that has seen the CEO of Melbourne
Water announce the purchase of a treed area many kilometers distant near Mt
Bulla to replace trees knocked down in the Toolangi Forest adjoining the
Melba Highway on the pipeline route – an absurd and farcical situation.
                   Other environmental “losses” include further damage to the
environment of the severely degraded Goulburn River[vi] from drawing water
in times of low flow.
                           Additionally there are potential losses in the tourist industry
         from a depleted Lake Eildon used to augment the water supply of Melbourne
         and other major urban areas.
                           The extent of green house gases generated by the electricity
         required to pump the 70kms of pipeline crossing the divide is also a
         substantial “cost”.
                           There is also an emerging “cost” issue, the economic loss
         adversely affecting the region with any spare (electricity) power supply being
         consumed by the pipeline pumping stations. Pumping requirements are also
         seen as a threat to the reliability of the existing electricity supply currently
         serving a wide region around Yea.

[1] Includes Central Goulburn 1234 – 17.6Gl; Shepparton Modernisation 52Gl; G-MW
Reconfiguration 25Gl.
[3] Meyer, W. (2005) Irrigation in perspective. Technical Report, CRC Irrigation Futures, Murrumbidgee Irrigation
Area & Districts Land and Water Management Plan Working Group (1998), MIA and Districts Community Land and
Water Management Plan.

[4] (Melbourne Water -Sugar Loaf Pipeline) - Project Impact Assessment Report – Appendices B
Hydrology, Water Resource and Water Crossing Impact Assessment 168 Appendix 2-2 Page 13 - dot

[i] The Victorian Auditor General ‘s report  “Planning for Water Infrastructure in 
Victoria released on the 9th April, 2008

[ii] Sugarloaf Interconnector Pipeline Project – Terms of reference Page 3
[iii] Planning and Environment Act 1987

[v] Reasons for decision under Environmental Effects Act
Page 2

[vi] Murray‐Darling Basin Rivers: Sustainable Rivers Audit  A report on the ecological 
health of rivers in the Murray‐Darling Basin,2004–2007

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Description: Submission by Bob Richardson for Plug The Pipe