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.
The Dubbo Photo News – 7/1/2021
Mel Gray – Convenor Healthy Rivers Dubbo and the Wambuul Alliance.
People love rivers, and I am no different. Growing up on a vegetable farm on the Clarence River and camping on the Upper Clarence every year, the river was central to our lives. After moving to Dubbo in 2011 to be close to my family, I became involved in river habitat regeneration and learnt about the challenges facing the Wambuul-Macquarie River and the Northern Murray-Daring Basin.
I saw a need for voices in the Dubbo community that spoke on behalf of the river. Healthy Rivers Dubbo formed in 2017 after the shocking revelations from the Four Corners episode “Pumped”. Our group held several events in Dubbo to promote equitable water management, including a Town Hall meeting at the Garden Hotel, and a rally through town. My involvement in water management grew. I joined several groups and committees involving water management, threw myself into submission writing and built a social media presence.
Running a busy freelance bookkeeping practice, I had a choice to make. There was much that needed to be done to understand the complexities of water management, and it would take time. I made the decision to restructure my practice so that I could spend as much time as possible advocating for rivers, while still maintaining enough bookkeeping work to meet my expenses.
Healthy Rivers Dubbo continued to evolve as a group, raising the profile of river management issues in the community and developing relationships with politicians and other river advocate groups in the Basin.
In 2018 plans were announced by the NSW Government to dam the Macquarie-Wambuul River again by building a large re-regulating structure at Gin Gin between Narromine and Warren. It wasn’t until November 2019 that WaterNSW consulted the general public and Healthy Rivers Dubbo was included in the consultation process.
Since then Healthy Rivers Dubbo has been overwhelmed by people and groups wanting to work together to oppose the project. It has been necessary for Healthy Rivers Dubbo to become the facilitator of a much broader “Wambuul Alliance”.
The future of the Macquarie-Wambuul River and the Ramsar listed Macquarie Marshes is at a cross roads. The gates on the planned Gin Gin re-regulating structure would be 8.5m high – that’s two and a half stories – and would back the river up for 32 km. It’s not surprising that the developer of the project and the Local Member for Dubbo are not being forthcoming about how enormous this structure would be. Once people learn the real nature of what is being proposed they are furious.
Many locals in the Mid-Macquarie area grew up camping and fishing at Gin Gin. The place holds generations of happy memories and cultural significance. If this project goes ahead, a popular camping and fishing site would be up to 8.5 metres under water, and a registered First Nations Site would be inundated.
There would be no coming back for river life including Murray Cod and Silver Perch after the loss of so much habitat. Recreational fishers would be packing their eskies and stocking up on supplies in other valleys, and not making the trip to the Macquarie. Kayakers would avoid traveling to the Macquarie if they knew a 32 km still weir pool lined with drowned red gums was ahead of them.
The internationally significant Macquarie Marshes have shrunk by up to two thirds since river regulation and over allocation. Despite being expertly managed with an ever shrinking bucket of publicly owned water, the fate of the wetlands would be sealed if the Gin Gin project went ahead.
The Wambuul Alliance understands the need for a sustainable irrigation industry and many recognise the potential for the Macquarie-Wambuul valley to be a food producing hot spot. However, right now there are serious problems in NSW with the rules that share water. The recent Independent Commission against Corruption (ICAC) review into water management in NSW found the government favours large irrigation over all others and the environment in ways that go against its own laws.
The decision to plough tens of millions of dollars of public funds into a project that will only benefit large scale irrigation to the detriment of all others who have cultural, social and economic reliance on the river is yet another example of the unwarranted bias from NSW water agencies that the ICAC report highlights.
Faced with the decision of whether to allow the river to be turned into nothing more than an irrigation delivery channel, many in the community have come together and dug deep to support the Wambuul Alliance and oppose the Gin Gin re-regulating storage project. It has been a privilege to lend a hand.
Submission Proposed legislative amendments for floodplain harvesting 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.
HRD supports the licencing and regulation of floodplain harvesting, however the impact of floodplain harvesting on the environment, First Nations communities and cultural values and downstream river communities must be assessed. HRD is pleased to have the opportunity to provide comment on the proposed legislative amendments for floodplain harvesting in NSW.
HRD objects to the four proposed amendments to the Water Management (General) Regulation 2018.
Floodplain harvesting (FPH) has had a significant impact on the resilience of the lower Darling-Bakka River, and of the tributary rivers that feed the Darling-Baaka where floodplain harvesting is concentrated – the Gwydir, Border Rivers, Barwon, Namoi and Macquarie.
Increasingly since 1994, FPH has denied significant volumes of water to floodplains, wetlands, aquifers, creeks and rivers. Denying these flows to the environment has resulted in landscapes being less resilient in dry times, and is a contributing factor to the Barwon and Darling Rivers ceasing to flow in November 2020.
Floodplain harvesting was mentioned as a contributing factor to the Menindee fish kills in the Independent assessment of the 2018-19 fish deaths in the lower Darling (Vertessy report) and the SA Royal Commission into water management in the Murray Darling Basin. FPH was identified as a factor to the Barwon-Darling River being called an ecosystem in crisis in the Natural Resources Commission review of the Barwon Darling Water Sharing Plan in 2019.
The significant and increasing impact that FPH has had on downstream environments, First Nations communities and critical human need requirements must be assessed before the hand out of several billions of dollars of tradable, compensable, mortgageable property rights in the form of FPH licences. As the Environmental Defenders Office and the Wentworth Group of Concerned Scientists recently published “…conferring permanent property rights to irrigators is a windfall transfer of public wealth that should be considered only once public good outcomes can be guaranteed.”
The recent NSW ICAC investigation into water management recommended:
That the DPIE publicly records:
• its water strategy, objectives and priorities for the use and management of NSW’s water resources in a manner consistent with the mandatory duty in s 9 of the WMA
• the need to ensure the water management principles in s 5, and in particular those that relate to sharing, as set out in s 5(3) of the WMA, are all given effect. Section 9 of the WMA should also inform relevant key departmental records, including agency policies, guidelines and role descriptions, concerning the management of NSW water resources.
The report highlighted what environmental stakeholders, graziers and communities along the Darling-Baaka have long understood – that the NSW DPIE Water (the department) make decisions that favour irrigation at the expense of First Nations cultural values, stock and domestic and critical human need requirements and the environment. ICAC found this bias comes from “a misguided effort to redress a perceived imbalance caused by the Basin Plan’s prioritisation of the environment’s needs”.
Environmental stakeholders have not seen any shift in this mindset from the department in recent times. An accidentally released email chain recently bought to light that members of the department have ‘regular catch-ups’ with NSW Farmers Association, NSW Irrigators Council and the Murray Darling Association. This sounds like a working alliance. Healthy Rivers Dubbo has only been involved in one environmental stakeholder briefing by the floodplain harvesting team.
The bias towards irrigation that informs decisions made by the department, as detailed in the ICAC report, is still evident in the four proposed rule changes to the Water Management (General) Regulation 2018.
1. Water Management (General) Amendment (Floodplain Harvesting Exemption) Regulation 2020
This regulation seeks to exempt floodplain harvesting works from the requirement under the Water Management Act 2000 (WMA) to hold a water access licence and water supply work approvals.
HRD strongly objects to this amendment and the exemptions it would provide.
No FPH works should be granted approvals exemption before the implementation of metering, the granting of licences and the rules for FPH are set in the relevant Water Sharing Plans.
Water that has been taken by FPH has been counted as environmental water for modelling purposes. All we know about the types of volumes that are taken is that they are significant, and that the environment has been denied these significant volumes for decades. HRD has serious concerns about the modelling and accounting of the long-term annual average flows to the environment in each NSW Northern Basin Valley. HRD believes the NSW Government has a responsibility to assess the volumes and impacts of decades of FPH on the rivers of the Northern NSW Murray Darling Basin.
2. Water Management (General) Amendment (Exemption for Rainfall Run-off Collection) Regulation 2020
HRD strongly opposes the granting of exemption to licence of rainfall runoff.
This exemption grants an unfair privilege to irrigation over other land holders, and again is an example of the misguided endeavours of the department to adjust their decision making to favour the irrigation over other stakeholders and the environment, as per the ICAC report.
The volume suggested as rainfall runoff exemption in the Border Rivers Water Sharing Plan rules was larger than the volume that was designated to be returned to the environment. This exemption makes a mockery of the FPH licencing process.
Currently rainfall runoff is accounted for as Planned Environmental Water and modelled as remaining in the rivers. Not licencing this water is an erosion of Planned Environmental Water, which is against the objectives of the Murray Darling Basin Plan.
Rainfall runoff from irrigation fields that is contaminated and kept and used on farm that is above the 10% harvestable right must be licenced.
3. Water Management (General) Amendment (Floodplain Harvesting Measurement) Regulation 2020
HRD is supportive of FPH works needing to be fitted with compliant metering, data logging and telemetry equipment and tamper-proof seals that needs to be fitted by a ‘duly qualified person’.
We object to a transition period for storages less than 1,000 megalitres or with infrequent use until 1st July 2022. All equipment must be installed and compliant by 30 June 2021.
We strongly object to a clause that allows the Minister to exempt an approval holder or a class of approval holders from the application of mandatory metering. If diversions cannot be measured and recorded, they should not have approval.
If metering equipment if faulty, no floodplain harvesting take should be allowed.
4. Water Management (General) Amendment (Floodplain Harvesting) Regulation 2020
HRD is supportive of FPH take being licenced, however the debt owed to the environment from decades of unmeasured significant volumes of take must be assessed before licences are handed out.
HRD is concerned about the modelling data that is being used to calculate the Border Rivers draft Water Sharing Plan rules. We have no confidence in the 94 ‘cap’ figures being presented, as there is no clear line of site to the accredited cap reports to the presented figures.
By their nature floods usually occur when the environment and downstream users are desperate for water. This will coincide with on farm storages being empty, and if the department has its way, account balances many times the face value of the entitlement. FPH licences should not be issued until adequate downstream targets and rules that protect first flush events are in place.
As of December 2020 the Barwon-Darling Rivers have ceased to flow at Brewarrina and Bourke. Substantive volumes taken by FPH in Feb and March 2020 played a part in the rivers having little resilience in warm dry times.
Overland flows in the Northern NSW Murray Darling Basin from December 2020 to 30 June 2021 must be allowed to pass for the sake of the Ramsar wetlands, aquifers, First Nations communities and cultural values, struggling native fish populations, stock and domestic needs and critical human need.
The NSW Government must manage water extraction under the core requirements of the Water Management Act 2000. This includes the water sharing principles and associated duties imposed on decision makers to uphold them (ss. 5 and 9 of the Act).
This exemption amendment has been disallowed twice already by the NSW Legislative Council. In the light of the findings of the recent ICAC report, it is time for the department to assess the decision making processes that continually shows an unreasonable level of privilege and advantage to irrigation over other stakeholders.
For more information contact
Healthy Rivers Dubbo
 Final report Review of the Water Sharing Plan for the Barwon-Darling Unregulated and Alluvial Water Sources 2012 September 2019
 Independent Commission Against Corruption INVESTIGATION INTO COMPLAINTS OF CORRUPTION IN THE MANAGEMENT OF WATER IN NSW AND SYSTEMIC NON-COMPLIANCE WITH THE WATER MANAGEMENT ACT 2000
Four changes are being proposed to the NSW Water Management (General) Regulation 2018 Act relating to Floodplain Harvesting.
These changes have already been disallowed by the NSW Legislative Council twice.
3. Do you support the proposed amendments to give effect to floodplain harvesting licence determination?
4. Do you support the proposed amendments to give effect to the Floodplain Harvesting Measurement Policy?
5. Do you support the proposed floodplain harvesting transitional exemption?
6. Do you support the proposed exemption for tailwater drains?
7. Attachments to support your submission.
Attach any additional information in document form – optional
If you’d like more information go to the Departments website here
If you’d like to email a more detailed submission to email@example.com download our simple submission guide here.
— THANK YOU —
The planned re-regulating dam on the Macquarie River at Gin Gin would be a death knoll for the internationally recognised Ramsar listed Macquarie Marshes.
Worried about the future of the famous bird breeding wetlands, some Mudgee locals had a chance to chat with Dugald Saunders MP about the fast tracked Gin Gin project.
Mr Saunders was happy to stop and hear concerns from locals about how the project would take water from the environment’s share and make it available for extraction.
Current estimates are that between 14,000 and 25,000 megalitres of water on average every year will be taken from the river upstream of the Ramsar wetlands as a result of the Gin Gin project.
This water is critical for the health of the Marshes.
The future of the 250 million year old Darling-Baaka River is being decided now as the NSW
Government develops rules about how much water can be diverted off floodplains before it reaches
Floodplain harvesting diverts water that either falls as rain or breaks over the river bank into private
dams with levee banks. Floodplain harvesting dehydrates floodplains, wetlands and aquifers, and was
identified by several reports as a key contributor to the mass fish kills in the Lower Darling last year.
Under proposed new licencing rules, the NSW Government wants to gift those who harvest water
from floodplains with an initial allowance to take five times their share of water. Further to that, the
river would owe those who harvest water from floodplains a full entitlement’s worth of water every
single year, whether it floods or not.
It would be close to impossible for the river to provide all of the water that it ‘owes’ water harvesters.
ICAC’s recent scathing findings on water management in NSW identify that there is a “lengthy history
of failure in giving proper and full effect to the objects principles and duties of the Water
Management Act and its priorities for water sharing.” The rules proposed for managing floodplain
harvesting in NSW prove that nothing looks like changing.
Quotes attributable to Melissa Gray, Convenor of Healthy Rivers Dubbo
“It is ludicrous for the NSW Government to pretend it is limiting the volume of water that can be
diverted from the floodplains. By the time a flood happens, these generous rules would mean the only
limit to the volume of water that can be taken is how much can be physically held, which is enormous.
“The impact that floodplain harvesting has had over the decades in dehydrating and weakening the
rivers, wetlands and aquifers of the Northern Basin needs to be assessed before the hand out of
tradable, mortgageable, compensable new property rights worth an estimated $1 to $2 billion.
“ICAC have confirmed what we in the Basin have known for a long time, that the NSW Government
department that manages water makes decisions about rivers that favour large irrigators over First
Nations People, grazing communities, recreational fishers, small irrigators and water security for places
like Dubbo, Walgett, Brewarrina, Bourke and Wilcannia – not to mention the environment.
“The Basin Plan asks governments to put the environment first. NSW Government water managers
have not been able to do that. Unless we ensure the rivers, wetlands and aquifers get enough water to
be resilient through tough droughts, we will all fail.”
For comment contact
0431 471 310
Download Media Release Here
Healthy Rivers Dubbo Submission Border Rivers Floodplain Harvesting Rules
Floodplain Harvesting diversions are not included in this article.
HEALTHY RIVERS – HEALTHY COMMUNITIES Terry Korn, Australian Floodplain Association.
There are few things more contentious than water! And this is very apparent at present as we debate the future of water management in the Murray Darling Basin.
Underpinning the debate is everyone’s concern for the future and what a changed water environment will mean for them and their family, their business and their grandchildren. Questions arise such as: Will it mean less food production? Will it mean more expensive food? Will it mean healthier rivers with more productive floodplains and wetlands and no net change in food production? Will communities survive? How can we manage with less water and how will we share the water in a fair and equitable way? Will future generations say we were wise, that we heeded lessons of the past, that we were considerate and caring about both people and the environment? So many questions and no easy answers!
I think it is important to step back to understand how this happened and make sure we do not repeat history, as so often happens. The Macquarie Valley is an example of the mismanagement of New South Wales water resources by a succession of governments and water agencies over the last 40 years.
When Burrendong dam was completed in 1966/67 the yield of the Macquarie River was assessed as 406000Megalitres (ML). That is roughly 406000 Olympic swimming pools. By 1978 the water users in the valley, most of whom were irrigators (agriculture uses about 80% of the allocated water), advised the Water Resources Commission (WRC) that the river was over allocated and an embargo should be placed on the issue of future water licenses. In 1979 the WRC introduced the embargo but at the same time raised the annual estimated yield of the river to 475000ML and continued to issue licenses so that permissible extraction rose to 497500ML.
Original licenses stipulated the area of land that could be irrigated but not the volume of water used. To remedy this anomaly, volumetric allocations were introduced. This system apportioned volumes of water (Megalitres/hectare) to a property and the property owner then decided how the water could be most productively used. Other valleys in NSW were allocated 6ML/ha but the Macquarie Valley was allocated 8ML/ha for irrigators on river schemes. For Off River schemes the standard 6ML/ha was agreed. By 1985 the total allocated water was 612000ML of which 452000ML was for riparian irrigators and 160000ML for off river schemes. As the revised estimated long term average yield of the river was 475000ML the Macquarie was now over committed by 137000ML more than the revised yield of 475000ML and 206000ML more than the original yield of 406000ML.
It gets worse! In 1985 allocations to existing licenses were increased by about 13000ML despites concerns and objections from stakeholder groups. From then to now the allocations for extractive use have risen to 738000ML for the Macquarie/Cudgegong system (the Cudgegong River flows into Burrendong Dam from the Mudgee area). An additional 160000ML was also allocated to the environment despite the fact it was obvious the already over allocated rive could not yield the 160000ML. The total allocation of regulated and supplementary flow water for the system is therefore now the grand total of 898793ML, almost double the revised estimated 1979 yield of 475000ML¹.
With such mismanagement the damage is widespread, indiscriminate and long lasting!
As the river became more over allocated and water was harvested freely from the floodplains, less and less water was available for overland flows and recharge of wetlands. Floodplains below Warren now receive fewer and smaller floods. The many floodplain graziers and croppers in the valley have had production reduced by 30-50% as a result. These are the industries on which valley communities were initially established and survived during the last drought when little or no water was available for large scale irrigation. They deserve better than that!
The significant irrigation industry suffers because the Macquarie Valley now has a 50% reliability of supply which is no better than chance. This is not a good foundation on which to base a high cost industry such as cotton, a major product of the valley. Nor does it provide surety for those families, businesses and communities who rely heavily on the irrigation industry. They deserve better than that!
And what sort of environment will we leave for future generations? Our wetlands which provide ecosystem services and support a great diversity of plants and animals have decreased in number and size. They have been radically changed by the fewer and smaller floods which are now the norm. The environment deserves better than that!
The question then arises: “How can we manage with the 475000ML of river yield so that it is shared in a fair and equitable way between industry and the environment without unduly impacting on local communities?”
This is where the debate now sits and the Federal Government has established the Murray Darling Basin Authority to develop and implement a plan for a basin which contains 22 other major river valleys. But do this task it must, otherwise in 15 years time we will face the same debate with even greater environmental damage and community adjustment.
The Macquarie River is so over allocated there is no easy solution and there will be impacts. Already progress has been made with the government buying water from willing sellers. It has secured more than 50% of what is required to service environmental needs in the valley. Further purchases need to be made and more savings will be made through changes to irrigation infrastructure.
I am confident the innovative irrigators of the Macquarie Valley will meet this challenge. It is essential that the non irrigation floodplain producers see justice through the restoration of much of their lost production. Running parallel with productive floodplains is a robust and resilient environment to support future generations. The sensible sharing of resources and resultant diversity of production will give us a healthy river. A healthy river will give us a healthy community!
¹ Note – all figures are from: Johnson W J (2005) Adaptive management of a complex social-ecological system: the regulated Macquarie River in south-eastern Australia. Master of Resource Science Thesis, University of New England.
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
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
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.