Attached is a submission guide for the Dungowan Dam project Environmental Impact Statement, written with contribution from the Tamworth Water Security Alliance.
Please use this guide to help you write a submission – due Friday 9th December
HRD
Dungowan Dam Summary Business Case
The proposed Dungowan Dam & Pipeline project is a National Party promise for the electorate of Tamworth. It is economically unviable and has been questioned by Infrastructure NSW and the Federal Productivity Commission.
The summary of the final business case passed by NSW Cabinet in March 2022 demonstrates bias and a lack of analysis of alternative options to secure Tamworth water supply under future climate change predictions.
Darling/Baaka sacrificed for northern irrigators
MEDIA RELEASE
Thursday 11 August 2022
Inland Rivers Network condemns the NSW Coalition Government and the Shooters Fishers
Farmers Party for sacrificing the health of the Darling/Baaka and its dependent communities
through poor regulation of floodplain harvesting in northern NSW.
Spokesperson for Inland Rivers Network, Brian Stevens:
‘The volumes of water handed out in new entitlements to allow the capture of rainfall runoff
before it enters rivers, and the capture of important medium flood flows, will continue the
destruction of the Darling/Baaka River.’
‘The rules gazetted in water sharing plans for the Border Rivers, Gwydir and Macquarie
Valleys allow for 500% accumulation of entitlement access and no triggers to stop access to
rainfall runoff and flood flows until Menindee Lakes are at a critical low level of 195 GL
(billion litres). The disastrous fish kills of 2019/20 occurred when Menindee Lakes held over
300 GL.’
‘The NSW Coalition and the Shooters Fishers Farmers Party have condemned the
Darling/Baaka to longer periods of dry riverbed with stagnant slimy pools. This decline in river
health started when floodplain harvesting exploded upstream during the 1990’s.’
‘The NSW Government has rewarded decades of unsustainable and unregulated water use with
new licences while conducting no assessment of the downstream impacts on Darling/Baaka
communities, native fish populations, groundwater recharge and important wetland areas.’
‘The future of the Darling/Baaka and its important connectivity with the lower Murray through
the Menindee Lakes is now under dire threat.’
Submission Guide – Floodplain harvesting rules for the Barwon-Darling water sharing plan
Submission Guide: Barwon-Darling Floodplain Harvesting (FPH) Rules
Deadline: Friday 8 July 2022
Email: floodplain.harvesting@dpi.nsw.gov.au
Documents available at: https://www.industry.nsw.gov.au/water/plans-programs/healthy-floodplains-project/water-sharing-plan-rules/barwon-darling
Background
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
- TRADING:
- 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
Contact: inlandriversnetwork@gmail.com for more information
Please include name, address and contact details. Identify if you want your submission published or if you want anonymous publication.
Tallywalka Creek in far west NSW flows for first time in a decade, as floodwaters trickle down
ABC Broken Hill / By Bill Ormonde 8 March 2022
For the first time in more than 10 years, a creek stretching 100km across far west New South Wales is full of water.
Key points:
- The 100km-long Tallywalka Creek has been dry for more than 10 years
- Floodwaters from heavy rain in northern NSW and south east Qld last year have made their way into the system, causing the creek to flow again
- Locals are rejoicing but would like to see more water on the floodplains along the lower Darling
Calls for Dungowan Dam Business Case to be Released
Inland Rivers Network President Beverley Smiles talks to Patrick Bell on ABC New England Monday 28th February 2022.
Questions about the cost of Dungowan dam are being asked by the community – how much will the Dungowan dam cost? Estimates are that it could be as much as $1 billion. That’s very expensive water!
Dams cause a lot of damage to rivers – Inland Rivers Network believes there are a lot better options for supplying long term urban water security for inland cities and towns such as purified recycled water, storm water capture and rain water tanks on every building in town.
The community needs to know – what alternatives have been costed, what cost benefit analysis has been done and what will happen to the price of water for Tamworth residents?
If the Government has nothing to hide, they will release the business case.
Media Release: Wealthy irrigators to be gifted water taken from downstream communities
MEDIA RELEASE
Wednesday 23 February 2022
Inland Rivers Network condemns new Water Minister Kevin Anderson and the NSW Government for moving closer to granting valuable floodplain harvesting licences, starting with the Gwydir and Border River Valleys, without any regard to the viability of downstream communities and river health.
The issuing of floodplain harvesting licences should be held off until a rigorous environmental, cultural and social assessment of downstream impacts is undertaken and fully understood.
Spokesperson for Inland Rivers Network, Brian Stevens:
‘NSW is one step closer to legalising floodplain harvesting without conducting any comprehensive assessment of the impacts of this water capture. Floodplain water flows should provide water for the Barwon-Darling/Baaka River, for wetland systems, for Aboriginal cultural values and for groundwater recharge.’
‘Downstream communities are being sacrificed by the NSW Government in favour of their wealthy irrigator supporters who have had free unlicensed access to floodplain flows for over 30 years. They are now to be gifted large water entitlements worth many millions of dollars.’
‘Inland Rivers Network agrees that regulation of floodplain water extraction is long overdue, but the NSW Government is planning to issue licences for a large volume of floodplain harvesting based mainly on information provided by the irrigators themselves. Without a comprehensive assessment of downstream impacts, this regulatory process is locking in the ongoing degradation of the NSW Northern Basin rivers and communities.’
‘The call for rigorous impact assessment of floodplain works and flood extraction has been loud and clear across many stakeholder groups in the Murray-Darling Basin but the NSW Government chooses to ignore a fair and just approach to water management in the state.’
Contact: Brian Stevens 0429 903 082
Download the Media Release here:
Bureaucrats assessing Dungowan Dam must follow the law
Published in the Northern Daily Leader – Tamworth
1st January 2022
Deputy Prime Minister, Barnaby Joyce, seems to be blaming bureaucrats in NSW for delaying the Dungowan Dam (NDL 19 December 2021). He maintains that politicians have said that Dungowan Dam is going to happen and that ‘government is run by the people represented by politicians.’
Has Mr Joyce forgotten that elected governments make laws and bureaucrats are paid to implement those laws?
Large impactful infrastructure, like dams on rivers, must be assessed under state and federal law. In NSW there is the Environment Planning and Assessment Act, Water Management Act, Fisheries Management Act, Biodiversity Conservation Act and at the Commonwealth level there is the Water Act, Murray-Darling Basin Plan, Environment Protection and Biodiversity Conservation Act – to name a few.
In early 2022, construction of the new pipeline between Dungowan village and Calala water treatment works will commence. This is the ‘shovels in the ground’ project that will help to save water and improve Tamworth water security. The process to assess a new dam on the already stressed Peel River must be conducted carefully and consider the many adverse impacts. Meanwhile, less expensive, more sustainable alternatives must be considered to give the best value for public investment.
It is time that the proposed Dungowan Dam stopped being used as a political football during a federal election campaign.
Inland Rivers Network president Bev Smiles
2021 Annual Report
Download Inland Rivers Network’s 2021 Annual Report
Earth First | Raising Wyangala Dam wall will not solve all problems
Bev Smiles
December 13 2021
A larger Wyangala Dam cannot solve all problems and will create many new ones.
Inland Rivers Network continues to question the rationale behind spending up to $2 billion dollars of public money on raising the Wyangala Dam Wall when the purpose of the proposal is unclear.
With the current floods in the Lachlan Valley there are conflicting calls for this proposal to provide both increased water security and improved flood mitigation.
These competing roles require different dam management and water sharing arrangements. Increased water security requires a full dam while improved flood mitigation requires lower levels.
The recent high rainfall events in the upper Lachlan catchment from August to November have demonstrated that the proposed larger dam would not have prevented the floods at Forbes.
Analysis of inflows to Wyangala Dam since it first filled in August, based on real time inflow reporting on the WaterNSW website, shows that the proposed larger Wyangala Dam would have filled and spilled in early October.
Also, analysis of inflows to the Lachlan River from tributaries below the dam showed that Wyangala Dam releases from a larger dam would still have occurred at the same time the increased tributary inflows from the Belubula River, Boorowa River and other swollen water sources below the dam entered the Lachlan River upstream of Forbes.
The proposed increased capture of 650 billion litres of water would not have solved impacts of flooding at Forbes and downstream during these highly unpredictable large rainfall events.
Inland Rivers Network looks forward to the release of the next stage of the draft Lachlan Regional Water Strategy that will consider the impact of climate change on the region and prioritise a range of water security options.
The NSW Government has announced that alternative water security options will be considered in the final business case for a larger Wyangala Dam.
This is a welcome step in the assessment process for this very large and impactful proposal.
While the recent floods have been disruptive and damaging to settlements and crops on the floodplain, the rainfall has been recuperative for the natural environmental following the recent intensive drought conditions.
Depleted soil profiles and groundwater sources have been replenished.
Native fish have good breeding conditions and the best waterbird breeding since 2016 is occurring in the Lachlan wetlands.
The Listening to the Lachlan Conference in Forbes in February will discuss many of these issues.
Inland Rivers Network president Bev Smiles
Inland Rivers Network 