Wise use of publicly owned water for the environment in the 2018-2019 water year helped vegetation in the core 10% of the struggling Macquarie Marshes hold on through the extreme drought of 2017-2019.
The rains in February 2020 came just in time to provide relief to the burnt North Marsh reed bed – however some fumbling in NSW agencies meant that the first flows weren’t protected for the environment, and significant volumes of water were allowed to be pumped and diverted from the river.
As a result, parts of the Ramsar listed wetlands turned green with noxious weeds, looking healthy to the untrained eye – but only flood water can heal a wetland. It wasn’t until late April 2020, when the growing days were shortening, that flows finally reached the northern part of the Marshes and the Lower Macquarie.
The start of the new water year as of 1st July 2020 saw some water that had been allocated to customers in 2016 finally turn up in the dam and be available, followed by some more flows. Time to get some important flows into the valley for native fish recovery and vegetation in the Macquarie Marshes.
The first part of the flow was designed to support Gugabul- Murray Cod on the nest.
Despite a hiccup with the cold water pollution control curtain in Burrendong which sent chilly 12 degree water down the river, NSW DPI – Fisheries detected Murray cod larvae in the Trangie area in mid-October. Based on larval ages, hatching of eggs began at the start of October.
The timing and duration of flows to the Macquarie Marshes is also critical for the recovery of this internationally significant wetland system. Plants in core wetland areas typically need 2–3 months of inundation over the post-frost months to allow them to flourish. This gives them a better chance to out-compete weeds such as lippia and noogoora burr.
With the landscape becoming drier, river operations getting tighter and the volumes of water available to fill water orders rapidly decreasing, environmental water managers are doing an excellent job supporting aquatic life in Wambuul.
Setting objectives is a powerful tool for organisations. Over time, objectives create and reinforce corporate culture. The objectives of an organisation inform decisions management make around hiring and training staff. They are the force behind the motivation of the organisations’ employees.
As the operator of 42 dams across NSW supplying two thirds of the water used in NSW, WaterNSW has a critical role to play in the health and resilience of the rivers of NSW.
Every action WaterNSW performs affects the environment. The modification of rivers has had significant impacts on groundwater aquifers, floodplains, wetlands a well as the rivers themselves.
The culture within the state owned corporation when it comes to prioritising environmental objectives is therefore very important.
Compliance with the principles of ecologically sustainable development should feature highly in the principle objectives of the state owned corporation, not at the very end of the secondary objectives.
Read Healthy Rivers Dubbo submission to the review of the WaterNSW Act 2014.
You would be right to believe that critical environmental and human needs for water have the highest priority to access to water in the rules that manage the Wambuul-Macquarie River… on paper, yes, the environment has the highest priority. But in reality, on the ground, the rules are applied in such a way so that irrigation gets looked after first – even after last summers crippling drought.
Supplementary access was announced – when the first flows arrived in the Macquarie in mid February 2020, the peak of the first flows was allowed to be pumped. The critical environmental and human needs downstream were ignored.
Floodplain harvesting is enormous – the diversion of overland flows into private dams by levy’s – held back an unknown, unmeasured volume of water. So much water, that flows that began in February didn’t reach the northern parts of the burnt North Marsh reed bed until the end of April. Healthy Rivers Dubbo conservatively estimates from the pieces of information available that around 70 to 90 GL ( 1 GL = 1 billion litres) was taken from the floodplains in the Macquarie this year (for scale Dubbo uses 8 GL a year from the river).
Remember the summer of 2019/20 in the Macquarie Valley?
The sharp severity of the drought was unprecedented. The Warren weir was raised by WaterNSW stopping flows beyond. Downstream, the river rapidly dried up to a series of disconnected green pools.
Insurance populations of turtles and fish were rescued from the river and secured in hatcheries by environmental agencies. Despite commendable efforts from the recreational fishing community to rescue as many fish as possible, mass fish deaths resulted.
The Macquarie Marshes were parched. There hadn’t been any surface water in the core Marsh since January 2019. The impact of years of ‘tight’ river management was evident – there was far less water around, and it disappeared very quickly.
Critical human need and stock and domestic requirements were not being met along the River and creeks downstream of Warren. There was a shocking loss of wildlife as a result. Mobs of kangaroos perished, many 50 year old plus turtles died, and we lost some of the oldest mussels known to exist in our fresh water rivers. The loss of vegetation meant less habitat for many and varied water dependent animals, fish and birds.
The North Marsh reed bed (the largest reed bed in the Murray Darling Basin) caught a lightning strike in October 2019 and about 4,000 ha was burnt. The reed beds needed flood water ASAP. While the reeds shot up after some rain fall that summer, they were using what little precious reserves their rhizomes held, making floodwater even more critical to their recovery.
The Drought Breaks
The flows came in February 2020, entering the Macquarie in several events through the Bell, Little and Talbragar Rivers – all of which are downstream of Burrendong Dam.
Shockingly, the first announcement of supplementary access was made on the 20th February, leading to over 12 GL being pumped from the vital first flow peak. The peak of the flow was taken, that meant that the area of wetland that potentially could have been inundated by the first flow was greatly reduced.
The shape of the hydrograph matters. The same volume of water flowing down the river over longer period of time wouldn’t have had the same potential to inundate as many hectares as the water arriving in one peak flow. The value of the peak of the flow to the environment in this circumstance was exponentially higher than the same volume of subsequent inflows at lower daily flow rates.
From a combined total of 84 GL flow at the Baroona gauge near Narromine, by 5 March 2020, 22.3 GL of this first flow had been recorded at Marebone Weir, with only 7 GL reaching the northern Macquarie Marshes.
Some of the flow was diverted by WaterNSW to other streams to meet stock and domestic replenishment flows, and some was extracted under a supplementary announcement. Much of the flow also performed a valuable role of soaking into alluvial aquifers and soils, filling pools in the river and meeting riparian needs for stock and domestic supply under basic landholder rights. An unknown volume was diverted by levys, and even more water was prevented from entering the river from floodplain harvesting.
By 1/3/2020, not even 1,200 ha of the 4,000 ha burnt North Marsh Reed bed had been inundated.
Timing matters. The reed bed needed to get that flood water as early as possible, so they could take advantage of the warmer summer days and get some growth up to store energy in their rhizomes for winter. It was not until late April 2020 that flood water finally made it to the northern most part of the charred reed bed, and into the Lower Macquarie River.
Because of the delay in flows reaching all of the fire damaged reed bed, the requirement for environmental water in the Macquarie Marshes was still classified as HIGH as of autumn 2020.
Why was supplementary access allowed?
Supplementary access has the lowest priority of water access, and should only be allowed once critical human need, and stock and domestic requirements downstream had been met. The go ahead to pump and divert was given before critical human need, and stock and domestic requirements downstream had been actually met (only forecast to be met).
By tweaking a rule, allowing critical need to be forecast, the peak of the very first flow after the drought broke was given the highest priority. Lucky for everyone it rained again……
The critical need for water in Macquarie Marshes after the worst drought in recorded history was ignored by NSW DPIE Water, who even ignored their own environmental water management team.
How much water does floodplain harvesting take in the Macquarie?
Floodplain Harvesting takes water from the floodplain for free, the volumes are unmeasured and therefore unknown. Healthy Rivers Dubbo has put together some available information to conservatively estimate the volumes involved.
From the Macquarie’s draft water resource plan, we know the the total on farm dam storage capacity in the valley is about 175 GL. Disregarding storage of off river schemes, and being very conservative, let’s say on farm dam storage close to the river that could catch water from the floodplain is about 70 to 90 GL.
Water from drought breaking flows that started in February didn’t reach the northern most part of the Marshes until late April.
When a third supplementary access event was announced in April, there was a relatively small amount of water extracted, indicating that the on-farm dams were already full of water.
Of course, this is an estimate, as the government still does not provide this information publicly. It could be even more then that.
I’ll just leave this here… last permanent trades in the Macquarie were $1,900 a ML, temporary trades were $200 a ML.
To the untrained eye (or those with conflicting vested interests), this spring the Marshes look green and healthy – but without the early arrival of the flows, damaging weeds like lippia have taken hold. How much of the 4,000 ha burnt reed bed will come back? Yet to be seen.
The real impact of the drought breaking flows being held back will be a scar on the landscape for many years.
The Macquarie River re-regulating dam is an extremely expensive, environmentally destructive project that will only benefit irrigators from Burrendong dam to Marebone weir. Like all dams, this project will benefit those upstream, and leave those downstream to survive if they can on ever drier river beds and floodplains.
So how can the NSW Government and WaterNSW present this project to the public in a palatable way? Enter the spin doctors.
The community was told in community consultations (hosted by GHD and WaterNSW) in November 2019 that the licenced environmental water holders supported the project, as their accounts will have more water in them, and there will be a fishway on the project.
WRONG – the project will mean a lot less freely flowing water in the Macquarie, and a little bit more water in licenced environmental accounts. The severe and permanent loss of habitat and the change in flow regimes will have devastating impacts on wildlife including endangered and threatened iconic Murray Cod, and centuries old river red gums – this damage cannot be ameliorated by a fishway.
The overall impact to the environment will be significantly negative. It has since been confirmed that the Commonwealth Environmental Water Holders’ Office, NSW DPIE EES, nor NSW Fisheries have never publicly endorsed the project. We were lied to.
At another public consultation in November 2019, the public were told that the project would be good for the Macquarie Marshes, because they get too much water and the roots of the plants rot. This is a direct lie that feeds into the narrative in this valley about the Marshes getting ‘too much water’.
There has been a long running and toxic campaign in the Macquarie Valley to paint the picture that the Macquarie Marshes gets too much water, perpetuated by vested interests upstream.
WaterNSW take advantage of this biased, untrue story when it suits them.
Earlier in 2020, Adrian Langdon from WaterNSW presented the following misleading graph to the public at a drought update hosted by Dubbo Regional Council.
PROBLEM #1 It appears the 20% shown here as ‘other flows to the Marshes’ is actually essential requirements (or delivery water). Essential requirements is the water used to deliver orders.
For reference, this pie graph shows a typical proportion of the water resource that is considered essential requirements – it’s usually the biggest piece of the pie by far.
WaterNSW are very proud of how tightly they operate the regulated section of the Macquarie River, reducing the volumes used to deliver orders to under 3% of delivered volumes. It is extremely unlikely that over a whole year any essential requirements water reached the Macquarie Marshes.
PROBLEM #2: The 38% ‘Flood Water on Floodplain’ includes vast, unmeasured and undeclared volumes of water that is diverted by levies for free into private storage – or floodplain harvesting. Healthy Rivers Dubbo estimates the volume taken in the valley in 2020 through floodplain harvesting was staggering – somewhere around 90 to 130 billion litres.
WaterNSW representing essential requirements on a graph as ‘other flows to the Marshes’ is outrageous and misleading.
Technically, essential requirements are classed as a type of Planned Environmental Water (PEW). When the NSW Government and WaterNSW are trying to present the message to the public that irrigation only takes a certain % of water from a river system (17% in the case of the Macquarie), they are very happy to imply that all water that isn’t taken for irrigation goes to the environment.
The Mayor of Narromine Craig Davis and Dugald Saunders MP Member for Dubbo are among those who publicly perpetuate the myth that 17% of flows on the Macquarie go to irrigation, and 80% goes to the environment.
This assertion is harmful and factually incorrect.
According to the above graph “Where Water Went”, 10% was managed for the environment including the Macquarie Marshes.
It is also possible that the public incorrectly believe that 17% of flows go to irrigation every year. The water shares owned by irrigation is more than those owned and managed for the environment. If flood events were taken out of the longterm average of water taken for irrigation, the % would be more like 45 – 60%.
When it comes to justifying the Macquarie River re-regulating storage however, the NSW government, WaterNSW and even the Mayor of Narromine and Member for Dubbo are strong in their assertion that operational surpluses belong to irrigators, and need to be physically recaptured and re-regulated.
Without clear, uniform definitions of environmental water, the Government and industry can pick and choose the definition the want to use to suit the message they want to spin.
Submission Guide: Inquiry into the rationale for, and impacts of, new dams and other water infrastructure in NSW – focus on Macquarie River reregulating project.
This inquiry is into the following projects: Wyangala dam wall raising, Mole River dam, Dungowan dam, Macquarie River reregulating storage project and the Western Weirs project. This submission guide refers specifically to the Macquarie River reregulating storage project. Please make that clear in your submission.
Some types of environmental water and unregulated flows, including inflows from the Talbragar, Bell and Little Rivers, could be captured by this project. There should be consistent rules across the Murray Darling Basin that protect all types of environmental water from extraction.
b) The economic rationale for the project:
The public don’t know the estimated cost of the project, we only know it is at least $30 million dollars because it’s classified State Significant Infrastructure.
The final business case will not be made public, despite a public promise from the Member for Dubbo Dugald Saunders MP.
The volumes of extra water for general security customers, and the cost of the project will be in the final business case, those critical figures will not be available to the public.
The Member for Dubbo stated there would be “not one drop of water extra that goes to irrigation”, however increasing the volumes available for general security customers is an objective of the project.
There will be no high security town water licences held in the storage.
The extra water for general security will be coming from flows that are currently a type of environmental water. The environment will have much less water, even though there will be small increase in water available to the general security environment account.
Only general security irrigation customers will benefit from this project.
WaterNSW have had a legal obligation to construct a fishway at Gin Gin since 2011. The design has been done. WaterNSW should just install a fishway and reinforce the current Gin Gin weir instead of constructing a very large expensive new dam.
There is no sound socio economic case provided for this project.
The socio-economic impact of reduced flows downstream of Marebone weir will not be considered. Grazing, unregulated irrigation and tourism opportunities will be significantly negatively impacted by the project.
Towns like Warren and Carinda will be at an increased risk of the river running dry again.
Gin Gin is a very popular recreational site.
Unregulated, natural flows including flows entering the river from the Bell, Little and Talbragar Rivers are critically important for aquatic native animals and fish to breed, feed and migrate.
Natural flows carry nutrients, occur when the atmospheric conditions are just right, and are the correct temperature.
There will be drier conditions downstream, including the Macquarie Marshes. This will mean it will be a lot harder for the Macquarie River to connect to the Barwon-Darling Rivers.
The 30km weir pool will mean reduced water quality and increase erosion.
Marshes and migratory birds
The internationally significant Ramsar listed Macquarie Marshes are one of the most important waterbird breeding sites in Australia. Australia has a legal obligation to protect Ramsar wetlands.
A notice of “change of ecological character” was issued in 2010 because the condition of the Macquarie Marshes had deteriorated so much. The main reason for the notice was a change in flow regimes.
This project can only exacerbate the ongoing decline in the health of the Macquarie Marshes and therefore the habitat for 14 species of migratory birds, 10 colonial-nesting species, and a total of 233 native species of birds including 77 species of waterbird, some of which are listed as critically endangered.
The Marshes also provide habitat for 60 native reptile species, 11 species of native fish, 29 native mammals, 15 native frogs and 324 native plant species.
More details Professor Richard Kingsford submission to the EPBC referral here
Native fish and the riparian zone
The habitat of native fish listed as endangered and critically endangered under the NSW Fisheries Management Act and the Federal EPBC Act will be significantly impacted.
One of the last remaining significant Murray Cod breeding sites on the Macquarie is immediately downstream of the proposed dam.
The 30km weir pool would mean a loss of riffle zones, snag habitat, the inundation of spawning and recruitment sites. Details in the EPBC referral.
A 30km long weir pool of still water will cause Murray Cod eggs to sink and die.
The vegetation along the river, including centuries old River Red Gums, will likely drown due to extended periods of inundation.
The frequent fluctuations in water level will not provide vegetation or biofilm a suitable hold. Over time, this will mean the weir pool will not support a food web for native fish, reptiles, waterbirds or any other aquatic animals. Dr Martin Mallen-Cooper’s comments.
Transforming a moving part of the river to a still pool will suit carp and mosquito fish.
Fish passage at Gin Gin is very important and overdue. The compulsory fishway component of the re-regulating structure will not ameliorate the significant impacts the project would have on the habitat of threatened and endangered native fish and other aquatic animals.
Native Fish in the Macquarie River are already listed as an Endangered Ecological Community.
f) Other matters:
The project will likely have significant impacts on matters of national significance, and should not be assessed by the NSW Government who are the proponents of the structure, this is a clear conflict of interest.
The official document produced by the NSW Government that will inform the environmental impact statement for the Macquarie River re-regulating dam details the expected significant impacts on the habitat of threatened and endangered native species.
WaterNSW suggested in this document that the impact the project would have on the Ramsar listed Macquarie Marshes and on migratory birds would not be significant, however the Commonwealth Government disagreed, and found the expected impact will indeed by significant.
Here is a summary of the expected significant impacts taken directly from the document:
Change of flowing river habitats to pool habitat.
Loss of freshwater habitat types such as riffle zones due to inundation, and changes to flow regimes and water quality.
Impacts to aquatic habitats and riparian vegetation from the regular variability of water levels within the storage and the associated effects on river bank stability.
Loss or decrease of available recruitment areas, due to changes in available habitat.
Likely impacts to the structural elements that make up established habitat of vulnerable Murray Cod in the existing Gin Gin Weir pool, including potential spawning sites.
The new operational regimes may impact larval recruitment and the movement of fish in the locality.
Greater variability in the pool levels and altered fish passage opportunities at the location.
The alterations to important fish habitat in this locality and the potential operation effects on habitat and spawning for Trout Cod and Murray Cod may give rise to potentially significant impacts to these species.
Potential impacts to the aquatic environment are likely to be more marked with a more extensive pool created behind the reregulating structure than the existing weir, greater variability in the pool levels and altered fish passage opportunities at the location.
Potential direct impacts on threatened ecological communities within the project area may include inundation of vegetation as a result of impoundment.
Potential impacts to listed migratory species include:
• Loss or changes to habitat, including changing flowing river habitats to pool habitat
• Temporary displacement during construction activities
• Alterations to hydrological regimes
• Impacts to groundwater dependent ecosystems
• Impacts to aquatic habitats and riparian vegetation from the regular variability of water levels within the storage.
The Murray Lower Darling Rivers Indigenous Nations (MLDRIN) is a confederation of Sovereign First Nations from the Southern part of the Murray Darling Basin (MDB). The group currently includes Delegates from 24 Nations across Victoria, NSW, the ACT and South Australia.
MLDRIN understands that the construction and operation of the proposed Macquarie re-regulating structure will have significant detrimental impact on matters of national environmental significance, including a Ramsar wetland and Federally listed threatened species. The proposal will also have detrimental impact on places and species of profound cultural significance to Traditional Owners of the Wiradjuri and Wailwan Nations. We also wish to highlight that engagement and consultation with relevant First Nations has been grossly inadequate…..
… We wish to stress that the waterways and landscapes likely to be impacted by the Re-regulator project are of profound cultural significance to multiple First Nations groups. The referral documents indicate that consultation with these Nations has grossly inadequate and that erroneous understandings of First Nations people have underpinned engagement and project design.
MLDRIN is a peak representative body, advising the MDBA, as well as NSW agencies (including sections of the Department of Primary Industries and Environment) regarding appropriate consultation with First Nations on waterway management issues. MLDRIN has a formal statutory role under he Basin Plan to assess water resource plans prepared by State Governments. MLDRIN has received no formal notification or been engaged by the proponent on this project.
MLDRIN’s Wiradjuri Nation delegates have identified the Macquarie Marshes and Murray Cod as critical cultural assets. Existing issues with poor water quality, water extraction, regulation and pollution have already degraded these sacred values. The re-regulator project is likely to greatly exacerbate these impacts…..
…. MLDRN is also deeply concerned by statements indicating the likelihood of inundation of cultural heritage features around the Rocky Point area. The referral also indicates that ‘The nature of the recorded sites suggests that similar sites are likely to exist at other locations along the river and across the landscape.’ It is grossly inadequate to suggest that cultural heritage sites subject to induction and destruction can be substituted for other sites along the waterway. All cultural sites bear a unique testimony to cultural traditions and occupation of country and cannot be substituted.
MLDRIN is also deeply concerned that the 30km weir pool that would result from construction of the re-regulating structure will lead to inundation and drowning of ancient River Red Gums and other physical and biotic features of cultural significance In summary, MLDRIN is deeply concerned that this project will pose significant, new threats to a river system and associated features of National Environmental significance that are already critically stressed. The related cultural values are also likely to be significantly impacted, with poor First Nations consultation evident in the project design.
Introduction; water for irrigation, utilities and stock and domestic use
In the Macquarie Valley, tributary flows downstream of Burrendong Dam are considered part of the regulated supply for the purpose of meeting water orders or other commitments. If the tributaries are flowing their water is used, where possible, to meet demands that would otherwise be met from the regulated supply in Burrendong Dam.
A former water department regional manager in Dubbo once explained that it helped to think of a ‘notional dam near Narromine.’ From the position of maximising regulation and extractive use this makes sense. But it is a legacy of a time when other values of water were not considered.
Role of the re-regulating storage
The Macquarie River Re-regulating Storage (MRRS) Scoping Report states that;
The new re-regulating storage will improve water security, reliability and delivery efficiency in the Macquarie River valley. The re-regulating storage will be located downstream of Burrendong Dam, between the townships of Narromine and Warren (p 6).
WaterNSW and the consultants have said that the new storage will not regulate tributary flows.
The MRRS Scoping Report says otherwise. Section 2.1.1 points out that, under the current plan, some tributary flows will be regulated (my highlighting).
The proposed re-regulating storage would function as a storage that is capable of capturing surplus flow events and regulating them, as required, to reduce operational losses. The intent of the storage is to capture operational releases from Burrendong Dam that are surplus to operational need and to store them temporarily until required to supply subsequent water orders. Releases identified as surplus within approximately 6 days’ travel time from Burrendong Dam may potentially be captured.
The source of operational surplus flows released from Burrendong Dam can include the following:
Customer orders that are subsequently cancelled due to, for example, rainfall events occurring which negate the need for irrigation
Orders subsequently met by useful tributary contributory inflows
Releases in excess of those required to cover delivery losses (p 16).
This section cannot be interpreted in any way other than that tributary flows will be regulated by the new storage.
My summary of the Report is;
The purpose and operation of the storage will be to capture operational releases from Burrendong Dam and store them to meet orders. These releases include tributary flows downstream of the dam.
Statements that downstream tributary flows will not be regulated by the new storage are only true because they are considered by WaterNSW to be releases from Burrendong Dam.
A reasonable person would not call tributary flows into the Macquarie, downstream of Burrendong Dam, releases from Burrendong Dam. Flows from the Talbragar, Bell and Little Rivers, Coolbaggie Creek, and other smaller streams that join the Macquarie downstream of the dam do not come from the dam.
A reasonable person would be astonished by this notion. That the notion exists, and is the published position of the NSW Government, would be met with disbelief.
Operation of the weir
The term useful tributary flows, meaning those that can be used to meet orders, demonstrates the NSW Government’s priorities. There is no stated limit to the amount of water to be regulated from the tributaries. Flows will be regarded as useful, and will be regulated, if they can be used to meet orders.
The capacity to hold these flows in the new storage means that more flows will fit the category of useful, and more water will be regulated and extracted. It allows a blank cheque for regulation and extraction of tributary flows.
It is naïve to think that WaterNSW will not use the storage to regulate as much of the tributary flows as possible. It will be managed to maximise the amount of water extracted. The more water it can control the better the narrow financial argument for it will be.
It is likely that tributary flows will be deemed useful, and available for regulation by the storage, if they can be used to;
meet irrigation orders rather than using releases from Burrendong Dam,
restore flows to regulated sections of the river and creeks downstream of the weir,
provide regulated stock and domestic supplies,
provide stock and domestic supplies from unregulated flows.
In 1987 the NSW Government published a Regional Environmental Plan for the Macquarie Marshes that said;
The Audit found the WRC [Water Resources Commission] was ineffective in management of the State’s water resources, having difficulty in moving beyond its former role of rural supply authority. Broad water needs of the whole community, including the needs of the natural environment, were residual considerations to irrigation development and operations…The new Department of Water will be required to address cultural, scientific and aesthetic values as legitimate community needs in terms of water management.
Water is mentioned in terms of losses and surplus more than 60 times in the MRSS Scoping Report. The proposal by WaterNSW to build a new storage on the Macquarie River, and the language it uses, show that the perspectives and objectives of the NSW water agencies have not changed since the 1980s.
Government failure to address the broad water needs of the whole community has long been a serious problem. Community dissatisfaction with water management in NSW was a major factor in the National Party’s loss of the seat of Barwon to the Shooters, Fishers and Farmers Party. It is a lesson that hasn’t been learnt.
The building of a re-regulating storage on the Macquarie River, as a proposed action has been referred to the Australian Government Department of Agriculture, Water and the Environment for assessment against Matters of National Environmental Significance (MNES) (EPBC Act referral 2020/8652).
Matters of National Environmental Significance (MNES)
First, the referral acknowledges that the proposed action is likely to have a direct or indirect impact on the ecological character of the Ramsar listed Macquarie Marshes, but concludes that this impact is not significant. This is clearly wrong and contradicts the overwhelming scientific evidence for the management of the health of the Macquarie Marshes and scientific understanding of river flow and inundation regimes, the listed advice on the management of the ecological character of the Marshes as a Ramsar site, as well as the evidence presented in this submission.
Second, the referral acknowledges that the proposed action is likely to have a direct or indirect impact on nationally listed threatened species or their habitats or any threatened ecological community, concluding that this impact is significant. This submission supports this conclusion, based on the scientific evidence but points out the inadequacy of the proponent’s preliminary assessment in relation to the level of impact.
Third, the referral acknowledges that the proposed action is likely to have a direct or indirect impact on listed migratory species or their habitats but then concludes that this impact is unlikely to be significant. This is clearly wrong and contradicts the overwhelming scientific evidence for the management of the health of the Macquarie Marshes and scientific understanding of river flow and inundation regimes, the listed advice on the management of the ecological character of the Marshes as a Ramsar site, as well as the evidence presented in this submission.