Submission Guide: Barwon-Darling Floodplain Harvesting (FPH) Rules
Deadline: Friday 8 July 2022
The Barwon-Darling River was identified by the Natural Resources Commission as suffering ecological collapse during recent intense drought conditions. The 2012 Barwon-Darling Water Sharing Plan attributed 16.5 GL (gigalitre = 1 billion litres) to FPH extraction. This volume was used in the development of the Murray-Darling Basin Plan. The proposed new entitlements are above this volume. Extraction from the Barwon-Darling has breached the Basin Plan Sustainable Diversion Limit in 2019 and 2020. The proposed management of FPH in the Barwon-Darling must not lock in individual property history of use.
Key Submission Points (use your own words & additional points)
- VOLUME: The volume of FPH to be licensed is estimated to be 51.32 GL (or unit shares), as identified in the Community Assistance Report. This differs greatly from the figures used in the modelled scenarios. There is no confidence in the information provided for FPH assessment or proposed entitlement in the Barwon-Darling River.
- Do not support that new FPH licenses will keep extraction below the Plan Limit
- Do not support the rainfall runoff exemption – this is free water that must be accounted for
- ACCOUNTING RULES:
- Do not support 500% carryover – will cause loss of key flood flows for downstream benefits to wetlands, cultural values, groundwater recharge, basic rights, and town water supply.
- Support annual accounting with no carryover – there is no rationale for this causing larger entitlements other than faulty policy favoring history of use
- Support that initial allocation is 1 ML unit share or less depending on antecedent conditions
- Support that annual allocation is 1 ML unit share or less, as above
- Do not support any trading of FPH entitlement – it is likely to cause environmental and cultural damage – this fails to meet the requirements of trading rules
- FLOODPLAIN WORKS
- No works in Floodplain Management Plan Zone A and D should be licensed to take FPH
- No lagoons or natural drought refugia should be licensed to take FPH
- No FPH works licenses should be granted until all unapproved and floodplain ‘hotspot’ works are removed or modified.
- ACCESS RULES
- Support no access under resumption of flow rules – these must be stronger to protect higher end-of-system flows in Barwon-Darling tributaries: Border Rivers, Gwydir, Namoi, Macquarie
- Strongly object to no FPH access target of below 195 GL in Menindee Lakes until forecast of at least 4,000 ML at Wilcannia. This offers no drought protection and will cause ecological damage. A target of 450 GL in Menindee is needed with higher forecast upstream flows.
- PROTECTION OF ENVIRONMENTAL WATER: Rules must protect held environmental water inflows from Queensland and NSW northern tributaries.
- AMENDMENTS: Support strong amendment provisions for all FPH management rules to enable rule changes without triggering compensation
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