SUBMISSION – HEALTHY RIVERS DUBBO
Water Trading and Water Ownership in NSW
Healthy Rivers Dubbo (HRD) is a grass roots community network dedicated to providing a strong voice for our local rivers, aquifers and wetlands in the Murray-Darling Basin for the benefit of wildlife, plants and people. We pay our respects to Elders past, present and future, and acknowledge that this land was never ceded.
Water is key to all life. It is the most vital of public resources. It is critically important that details about water trading and ownership are publicly available, free and easy to access from a single source.
HRD supports the development of a Water Register with a user friendly map application that links water access licence holders with all of the water holding/trading details listed as recommendations in the Interim Matthews Report:
‘Enable the public to readily access from a single source, all details of entitlements, including: name of holder; licence number; licence conditions; water entitlement; water allocations; meter readings; real time water account balance; and all trading activities’ 
To this list we would add that any convictions for water theft be listed as well on the site.
HRD objects to the NSW Government’s decision to only provide aggregated totals of water licence and extraction details at a water source level.
The updates to the WaterNSW Water Insights web site and the DPIE Water Trading Dashboard are of aggregated information that was already publicly available, although difficult to find.
There will still be charges involved in searching the NSW Water Access Licence register. It was reported in the media that it would cost approximately $558,600 to search the whole register. 
Listing water entitlements on the foreign ownership register administrated by the ATO should be compulsory, publicly available and linked to a public Water Register.
All water entitlement acquisitions by foreign investors should be approved by the Foreign Investment Review Board, with links to the report on the public Water Register.
As the public Water Register would list all access licence holders and their details that would include all members of parliament and their families.
Healthy Rivers Dubbo supports the establishment of a National Water Trading Exchange.
Water trading within catchments can exacerbate environmental problems. Extraction can be concentrated upstream, impacting downstream environmental and other water users downstream. A concentration of extraction can create salinity issues, or impact important wetlands.
The public need to have access to details of water trading within catchments, so that the impact of water trading is transparent.
HRD objects to only aggregated trading data being available at a water source level.
We believe it’s important for the public to know the identity of speculators and non-land holding traders who produce no agricultural output. Speculation in the water market pushes up pricing and increases water scarcity, which is a significant threat to the environment and communities in the Basin.
Water is essential to existence, it is a fundamental public resource. It is very important that the public have a clear line of sight to who is taking water, how much they are taking and trading, and if they have any convictions for water theft.
There needs to be a generational upheaval of water regulation in NSW, including much improved transparency. This need has been identified in many reports, including the Matthews Report.
The final Matthews report identified a risk that “certain important stakeholders” would put pressure on the process to maintain the status quo. HRD believes that is what irrigator groups have done.
We are witnessing the NSW Government continue to favour irrigation over First Nations and Environmental stakeholders:
“…the irrigator focus of the Department of Primary Industries – Water (DPI-W) was entrenched in its approach towards stakeholder consultation, which focused on the irrigation industry, while restricting information available to other stakeholders, such as environmental agencies. As a result, the policy-making process became vulnerable to improper favouritism, as environmental perspectives were sidelined from policy discussions.” 
 Interim Matthews Report – Independent investigation into NSW water management and compliance. Sept 2017.
 NSW ICAC report Investigation into complaints of corruption in the management of water in NSW and systematic non-compliance with the Water Management Act 2000.