Professor Richard Kingsford to speak in Dubbo

The proposed Gin Gin dam plans were slammed last year by the NSW Government as they “do not currently demonstrate value for money and an efficient, effective and prudent use of public funds.”

The proposal does not stack up economically, socially or ecologically.

Come along to the Pastoral Hotel on Wednesday 23rd June and hear from:

  • Professor Richard Kingsford, Wetland Ecologist
  • Tony Lees, Trangie Aboriginal Land Council
  • Beverley Smiles, President of Inland Rivers Network
  • and Garry Hall, Private Ramsar Wetland Manager

Wednesday 23rd June, 6.30pm at the Pastoral Hotel, Talbragar Street Dubbo.

Facebook Event

Media Release

Floodplain Harvesting Rules for the Macquarie-Wambool

Sunday 18 April 2021

SUBMISSION

Floodplain harvesting licence rules in the water sharing plans for the Macquarie Valley

Introduction

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 and present, and acknowledge that this land was never ceded.

HRD are pleased to have the opportunity to comment on the establishment of rules in the water sharing plan (WSP) for floodplain harvesting (FPH) in the Macquarie-Wambool Valley. HRD accepts that FPH in NSW must be licenced.

Before we detail our comments on the proposed rules, there are some critical issues with FPH in general that, as environmental stakeholders and First Nations allies, HRD is obliged to comment on.

Plan Limit and Cap

There is not enough evidence for the public to accept DPIE Water’s claim that total extractions in the Macquarie-Wambool are below the cap and the sustainable diversion limit (SDL).

In recent years, and coinciding with the latest round of FPH policy implementation, environmental stakeholder have started hearing water departments and agencies claiming that Cap limits and SDLs are definitions, not volumes as they were previously understood by the community as being.

We now are witnessing the volumes of FPH being added to the Cap limits, when previously FPH diversions have been considered as going to the environment.

Decisions made about reducing the volume of water to be recovered from irrigation for the environment in the Northern Basin in 2017 were made assuming the large volumes of water that have been taken by FPH were going to the environment.

The Macquarie-Wambool is an over allocated Valley. When Burrendong dam was completed in 1966/67 the yield of the Macquarie River was assessed as 406,000 ML. Too many licences have been issued, and now the total allocation of regulated and supplementary flow water for the system is around 899,000 ML[1].

There is simply too much demand on the Valley for the volume of licences, which is why reliability is around 30% on average and dropping. This low reliability goes a long way towards explaining why irrigators can’t access as much water as their entitlement.

HRD points to a recent report by consultants Slattery and Johnson that shows on farm capacity has increased by a factor of 2.4 times since 1994. This finding fits with our observations and local knowledge. We can see the increased levees as we drive west from Narromine. We know people who were flat out working during the 2017-2020 drought deepening on farm storages and increasing levees saying the land owner wants to hold 2 years water on farm when the drought breaks.

If on farm capacity has increased by 2.4 times since 1994:

  • those earthworks weren’t done for nothing
  • there’s been no increase in licences since then
  • the capacity must be mostly for storing water from FPH diversion, or from water theft

This increase of on farm storage has helped the industry leave a lot of water in their general security and supplementary accounts, as they preference filling up on free, unmeasured water from the floodplain. Not having to access the general security and supplementary accounts is a major reason why irrigators don’t access their full allocation – they don’t need to.

There is no evidence to substantiate the new Cap limit in the Macquarie, and no access to the accredited Cap model reports.

ICAC found that DPIE Water has a practice of favouring irrigation in “a misguided effort to redress a perceived imbalance caused by the Basin Plan’s prioritisation of the environment’s needs[2].

HRD considers that DPIE Water continues to treat First Nations rights to water and the environment like opponents to their endeavours by working out ways to increase Cap limits to suit extraction.

Environmental Outcomes

Macquarie Marshes:

NSW has a legal and moral responsibility to protect the integrity of the internationally significant Macquarie Marshes under the Ramsar Convention, Migratory Bird agreements, the Water Management Act 2000, the Water Act 2007 and the Murray Darling Basin Plan.

“The unregulated floods, particularly the significant large floods, are critical for sustaining this ecosystem of national and international importance[3]

The Macquarie Marshes have reduced in size considerably since growth in FPH diversions.

The Australian Government notified the Ramsar Secretariat in 2010 of a “likely change in ecological character of the Macquarie Marshes Ramsar site”, stating a range of reasons based on scientific evidence, including changes in the flow regime; change in the extent and condition of the wetland vegetation communities in the southern part of the Macquarie Marshes Nature Reserve; change in extent and condition of wetland vegetation communities in the northern section of the Macquarie Marshes Nature Reserve; changes in the ecological character of the Wilgara wetland and; changes in colonial waterbird breeding. [4]

Connectivity:

The Macquarie-Wambool River has provided 21% of flows to the Barwon Darling-Baaka Rivers over the long term. Unique in the Northern Basin, The Macquarie-Wambool, Castlereagh and Bogan Rivers are winter and spring fed systems, and provide flows to the Barwon Darling-Baaka when other monsoon fed systems don’t.

Records show that the Macquarie-Wambool connected to the Barwon (at a depth in the Lower Macquarie of at least 50cm) 9 years in 11 before Burrendong dam was built. Development of the valley means connection occurs 5 years in 11 now (as of 2017). Connections between major rivers represent important links for the movement of fish, transfer of energy, riverine biodiversity and providing a diverse aquatic habitat. [5]

HRD considers that DPIE is acting against its own laws by not applying the priority of use and cultural requirements in the Water Management Act 2000 to the application of FPH licencing and rules in the Macquarie-Wambool Valley by reducing allowable FPH diversions to secure environmental improvement for the Ramsar Macquarie Marshes, and increased connectivity with the Barwon Darling-Baaka Rivers.

Modelling

HRD strongly believes that the modelling used to determine FPH shares in the Macquarie-Wambool is not fit for purpose.

FPH licenced volume determinations will have a permanent detrimental impact on the environment, First Nations rights to water and basic landholder rights. The volume will also determine how large the wealth shift from the public purse to private and corporate hands will be when mortgageable, tradable, compensable licences are issued.

Climate change has not been factored in into the modelling, despite new robust climate/hydrologic datasets developed by DPIE last year for inclusion in the Regional Water Strategies (RWS). With these new datasets, DPIE has been able to come up with a ‘base case’ river system model.

The RWS states: “just relying on our historical data to make water management decisions no longer represents the best course of action and that we have an opportunity to put plans in place to make sure we are prepared and resilient if there are future changes in the climate.”

Against its own advice, DPIE Water have omitted climate change from FPH models. HRD will discuss the impact of neglecting climate change on FPH rule applications under “Discussion of Proposed Rules 1. Account Management”further down in the submission.

There is only a summary Review of NSW Macquarie River Valley Model Build, Scenarios and Environmental Outcomes report publicly available. The independent peer reviewers Alluvium only had access to reports, not the models themselves.

The Model Build Report identifies a lot of highly significant inaccuracies around the meters used to measure river diversions. There’s a lack of real data on floodplain harvesting volumes, despite the FPH policy being in some form of development since 2008. In the Macquarie there’s a +51% error rate/bias upstream of Narromine, which is extremely significant.[6]

In the Macquarie Cudgegong there is 10,254 ML of water being considered for tailwater/rainfall runoff exemption. HRD does not trust the modelling used to come up with that volume. If this significant volume of water is not brought into the FPH licencing framework, it won’t be counted towards the SDL. This form of take would not need to be measured, just ‘monitored’ for assessment under the risk assessment in the Water Resource Plan. Any volume of rainfall runoff harvested above the 10% harvestable right must be licenced.

Return flows aren’t assessed by the models used. Their only function is to attempt to calculate floodwaters captured, not those that return to the river or floodplain environment. There’s a strong chance water that returns to the river or stays on the floodplain is being assessed as FPH diverted volumes.

As stated by Alluvium: “We note the statements in the report that the uncertainty in individual FPH take estimates (leading to entitlements) is still significant and measurement data is needed to improve on that.”[7] This statement confirms that the inaccuracy of the volumes determined as eligible for FPH diversion are significantly incorrect.

For such a critical determination that will seal the fate of many people and much wildlife to be dependent on the use of models that are not up to the job HRD considers to be a negligent act.

Discussion of Proposed Rules

1. Account Management

HRD strongly supports annual accounting for FPH with no “carryover”*

HRD has heard DPIE Water trying to explain that the environment would be better off under 5 year accounting and 500% carryover and we strongly disagree.

DPIE Water is only looking backwards at flood behaviour up to 2009, when they know floods will change their patterns due to climate change.

From the Macquarie Castlereagh RWS, the Valley can expect “reduced frequency of floods, but when they do occur, significantly higher flood flows throughout the entire region, particularly during the summer-autumn period.”

And also from the same RWS:

“just relying on our historical data to make water management decisions no longer represents the best course of action and that we have an opportunity to put plans in place to make sure we are prepared and resilient if there are future changes in the climate.”

HRD considers that under future conditions, 5 year with 500% “carryover”* will lead to greater FPH diversions than 1 year accounting. We find it consistent with ICAC findings (that DPIE Water favours irrigators over First Nations rights to water and the environment) that DPIE Water are trying to tell us that the environment will be better off under 5 year accounting, when they are knowingly not using climate change predictions in their models.

*N.B. HRD rejects DPIE Water’s use of the term “carryover” to describe entitlements for water that does not exist. HRD asks that DPIE Water come up with another term, such as credit accounting.

2. Initial Available Water Determination

HRD strongly supports an initial AWD of 1ML per unit share or less

Alluvium state in their letter reviewing the modelling reports that: “We note the statements in the report that the uncertainty in individual FPH take estimates (leading to entitlements) is still significant and measurement data is needed to improve on that.

DPIE Water know that the volumes licenced are significantly wrong, therefore the precautionary principle must be applied and an initial AWD of no more than 1 ML per unit share be allowed.

FPH diversions have been denying First Nations rights to water and the environment benefit from first flush flows (particularly sharply felt at the end of a drought) for decades. By granting irrigators a generous 500% hot start, DPIE Water are neglecting their legal obligations under the WMA 2000.

3. Permanent Trade

HRD fully supports that permanent trade be restricted to management zones as proposed

While we would prefer FPH access licences not be tradable, we accept that it is a requirement under the Basin Plan that licences are tradable.

It is very important that trade be restricted as proposed:

  • No new works located in management zones A or D as specified in the (as yet un-gazetted) Floodplain Management Plan for the Macquarie Valley Floodplain 2021.
  • No modifications to works located in management zones A or D if the modification would result in an increase in capacity for that work.
  • No new or modified works outside management zones A and D if the construction or modification would result in an increased rate of take for works located in management zone A or D.

4. Granting or amending water supply works nominated by a floodplain harvesting (regulated river) access licence

No new approvals or modifications that increase diversions

HRD would prefer that DPIE Water were very clear that there can be no growth in FPH diversions, as we feel that is not the case through this consultation process.

HRD considers that:

  • no new works approvals should be issued for FPH in the Macquarie Valley
  • no modifications of existing FPH works should be allowed if the capacity of diversions would be increased
  • only maintenance of existing FPH works should be allowed if the maintenance means there would be no increased diversion of water
  • all licences works must allow floodwaters to pass without diversion or significantly slowing the flow for times when diversions are not permitted

5. Access Rules

HRD supports option 2 – prohibiting access until downstream flow targets are met.

There are no clear, measurable protocols that DPIE Water can enact to ensure the priority of use provisions in the WMA 2000 are applied.

HRD recommends end of system flow targets be introduced in the Macquarie Cudgegong regulated WSP. Access rules for FPH in the WSP should specify that FPH diversion may occur only after modelling of a flow event shows that relevant flow targets will be achieved.

Flow targets must aim to achieve:

  • Water sharing priorities under the WMA (ss. 5(3) and 9(1)), which include water for ecosystem health and basic landholder rights (stock and domestic; native title rights);
  • Environmental needs based on NSW Long Term Watering Plans (LTWP) Environmental Water Requirements (EWR);
  • Critical human water needs; and
  • Cultural rights and objectives in addition to Native Title rights.

6. Active Management

HRD supports the use of active management rules to protect 100% of HEW

HRD supports the proposed use of active management rules to protect HEW from FPH diversion when Held Environmental Water (HEW) being used to create an overbank flow in the management zone where active management applies.

However, the rules do not go far enough. HRD considers rules that protect 100% of HEW from diversion even when active management conditions are below 100% must be implemented.

HEW can be present in the system not just from planned releases from storages, but also under supplementary access. It is reasonable to expect supplementary HEW flows would be vulnerable to FPH diversion if the rules aren’t there to protect it.

7. Environmental Flow Rules

Active management rules must be extended to protect 100% of Active EWA

Just as HEW can be used to create overbank flows in the Gum Cowal, Lower Macquarie Upstream and Lower Macquarie Downstream management zones, so too can environmental water allowance sub account 1 (active EWA).

Active EWA and HEW are managed together in the Macquarie Valley, therefore rules that protect HEW must also protect active EWA.

HRD recommends extending the active management application that protects HEW so that active EWA is also protected.

8. Amendment provisions

HRD supports the proposed amendment provisions for the Macquarie Cudgegong regulated WSP.

Conclusion

DPIE Water have consulted with the irrigation industry regularly, and with environmental stakeholders rarely. HRD is concerned that the bias DPIE Water shows irrigation in the management of water in NSW, as reported by ICAC last November, is informing the granting of FPH licences and implementation of WSP rules.

The definition of Cap is being used as an elastic definition that provides the answer that suits the outcome desired.

By not reducing FPH diversions in the Macquarie, DPIE Water has sealed the fate of the declining Wambool River, Macquarie Marshes and Lower Darling-Baaka Rivers and the cultures, wildlife and communities they support.

Yours Sincerely,

Melissa Gray

Convenor

Healthy Rivers Dubbo


[1] 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.

[2] ICAC Investigation into complaints of corruption in the management of water in NSW and systematic non-compliance with the Water Management Act 2000 – November 2020.

[3] (Kingsford and Thomas, 1995; Thomas et al., 2011; Bino et al., 2015b; Thomas et al., 2015

[4] http://www.environment.gov.au/water/topics/wetlands/database/pubs/28-statement-of-reasons-3-2-notification-20100204.pdf

[5] Making the Connection: Designing, delivering and monitoring flows between catchments – making-connection.pdf

[6] Model Build Report Table 3.7

[7] Alluvium Review of NSW Macquarie River Valley Model Build, Scenarios and Environmental Outcomes reports relevant to Floodplain Harvesting Policy implementation

Floodplain harvesting to continue to devastate the Macquarie Valley

Floodplain harvesting is a form of water take that diverts water that either falls as rain or breaks out of the river bank during floods. The water is diverted into private dams using levee banks. It has been an unmeasured form of free water collection, believed to have increased since 1994 by almost two and a half times.

Floodplain Harvesting has attributed to dehydrated floodplains, wetlands, less resilient rivers and depleted aquifers. It has contributed to the rapid decline in size and health of the Ramsar listed Macquarie Marshes, and has been identified in several reports as a key contributor to the mass fish kills in the Lower Darling in 2019.

The NSW Government have been touting that by licencing the controversial practice, they are bringing water take back in line with the Cap Limit on extraction set in 1994, and returning some critically important flood flows to the ailing river systems of the west.

However the Macquarie-Wambool will be missing out on seeing any water returned to the valley, as the NSW Government – keeping true to their form of prioritising irrigation over everyone else – have somehow increased the Cap Limit to allow floodplain harvesting to remain at current levels.

It is bewildering that the Government can wave a magic wand and claim less water is being taken now than in 1994, when we can see the wetlands, rivers and fish dying in front of our eyes.

The NSW Government has legal responsibilities under the Ramsar Convention, Migratory Bird Agreements, the NSW Water Management Act 2000, the Commonwealth Water Act 2007 and the Murray Darling Basin Plan to ensure the resilience of wetlands, prioritise ecosystem health, and ensure water is available for basic landholder rights including Native Title rights to water.

It is not apparent that the NSW Government are acting in line with their legal requirements when it comes to water management, especially floodplain harvesting.

The Ramsar listed Macquarie Marshes needs flood water.

As the volume of water taken through floodplain harvesting has been growing, the size and resilience of the Marshes has been rapidly reducing.

Unregulated floods are critical for sustaining this ecosystem of national and international importance.

The Australian Government notified the Ramsar Secretariat in 2010 of a “likely change in ecological character of the Macquarie Marshes Ramsar site”, stating a range of reasons based on scientific evidence, including changes in the flow regime; change in the extent and condition of the wetland vegetation communities in the southern part of the Macquarie Marshes Nature Reserve; change in extent and condition of wetland vegetation communities in the northern section of the Macquarie Marshes Nature Reserve; changes in the ecological character of the Wilgara wetland and; changes in colonial waterbird breeding.

Keeping the connection is important

The Macquarie-Wambool River has provided 21% of flows to the Barwon Darling-Baaka Rivers over the long term. Unique in the Northern Basin, The Macquarie-Wambool, Castlereagh and Bogan Rivers are winter and spring fed systems, and provide flows to the Barwon Darling-Baaka when other monsoon fed systems don’t.

Records show that the Macquarie-Wambool connected to the Barwon (at a depth in the Lower Macquarie of at least 50cm) 9 years in 11 before Burrendong dam was built. Development of the valley means connection occurs 5 years in 11 now (as of 2017). Connections between major rivers represent important links for the movement of fish, transfer of energy, riverine biodiversity and providing a diverse aquatic habitat.  

It seems clear that the NSW Government is acting against its own laws by not applying the priority of use and cultural requirements in the Water Management Act 2000 when it comes to floodplain harvesting licencing and rules in the Macquarie-Wambool Valley.

Read Healthy Rivers Dubbo submission on the FPH rules in the Macquarie Valley

The miraculous Cap setting illusion – Floodplain harvesting limits in NSW

The NSW Government have come up with a new volume for the ‘Cap’ in the Macquarie-Wambuul Valley – and conveniently it will allow floodplain harvesting to continue at current levels.

The ‘Cap’ is supposed to be the volume of water that was being taken in 1994. That’s when communities and Basin Governments said enough is enough – too much water is being taken and the rivers, wetlands, aquifers, floodplains and estuaries are dying.

The line was drawn and agreed upon – we would not increase the volume of water we were taking from what was taken in 1994. That was the intent of setting the Cap.

A lot of work done to produce transparent, accredited Cap reports. But at some stage the accredited Cap reports were archived, never to be seen again, despite many requests.

In recent years water departments and agencies have started saying that the Cap is a concept, not a volume………… hey?

They say as they learn more about how much water was being taken, they can update the Cap…….. really? Was it really being taken then or have take increased since 1994?

Since 1994, the capacity of on farm dams to hold water has increased by a factor of 2.4. There hasn’t been any more licences issued, so it is very safe to assume that most of those dams were built to store water – free water – off the floodplains. Floodplain harvesting.

So to get this straight, the Government:

  • decided what the level of water take was in 1994 calling it the Cap,
  • then hid those accredited reports,
  • in the meantime on-farm capacity to hold water has grown by almost two and a half times
  • now the Government claim the amount of water being taken in the Macquarie Valley is less than the Cap
  • but that’s because they made up a new Cap

How did they arrive at the new Cap? Who knows. Not even the independent consultants hired to review the Government’s work got to see how that was done.

Doesn’t redefining the volume of the Cap contradict the very meaning of what a Cap is? You would think so.

They say it doesn’t matter to health of the river if they do that.

But volumes of water matter to the rivers. Water matters to wetlands, to fish, water birds, river red gums and to cultures and communities who only survive because of the river.

We are all being momentously ripped off.

Read Healthy Rivers Dubbo submission to the FPH rules in the Macquarie Valley

No Real Improvement – Water Management as Murky as Ever in NSW

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.

Water Register

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’ [1]

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. [2]

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.

Water Trading

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.

Conclusion

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.” [3]


[1] Interim Matthews Report – Independent investigation into NSW water management and compliance. Sept 2017.

[2] https://www.abc.net.au/news/2020-05-06/chinese-state-owned-companies-buy-up-water-in-murray-darling/12215548

[3] 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 future of western region water at a crossroads

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.

Contact healthyriversdubbo@gmail.com

Floodplain Harvesting in NSW- make a quick online submission

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.

Please make a quick online submission objecting to these changes here

3. Do you support the proposed amendments to give effect to floodplain harvesting licence determination?

No

4. Do you support the proposed amendments to give effect to the Floodplain Harvesting Measurement Policy?

No

5. Do you support the proposed floodplain harvesting transitional exemption?

No

6. Do you support the proposed exemption for tailwater drains?

No

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 floodplain.harvesting@dpi.nsw.gov.au download our simple submission guide here.

— THANK YOU —

Media Release – Old habits die hard in NSW water management.


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
the river.

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
Mel Gray
0431 471 310

Download Media Release Here

Healthy Rivers Dubbo Submission Border Rivers Floodplain Harvesting Rules

How the Wambool-Macquarie became over allocated – Terry Korn

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

Water for the environment working hard in the Wambuul Macquarie Valley.

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.

And success!

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.