Submission in response to the “guide to the proposed basin plan”

17 December 2010

The Chairperson
Murray-Darling Basin Authority



Dear Chair,


Sustainable Population Australia (SPA) is a nationally-based environment group, and is the only environment group in Australia which campaigns on the need for an ecologically sustainable population.
We congratulate the Murray Darling Basin Authority (MDBA) for its attention to detail, the scientific and environmental basis of its recommendations and its stewardship in carrying out the intentions of the Water Act 2007.
We recall also the undertaking given by Prime Minister Gillard during the recent Federal election to implement the recommendations of the MDBA and we express our disappointment at the apparent backdown which has occurred.
The Guide states that the Authority “recognises that the impacts of the necessary adjustments fall on the current generation of farmers and irrigators, industries and communities”. However, the decisions that were made over decades by irrigators and the governments and authorities which encouraged them and gave them their permits were underlain with an assumption that was never overtly stated – namely that costs would be borne by future generations and the environment. The MDBA must give this equal recognition.
It is a matter of regret that the Act does not include consideration of population and this necessarily limits the scope of the draft guide. In one of the rare mentions of the word, the Guide says “Many of these challenges and risks are the direct result of the actions of successive governments over the history of the Basin. In retrospect many of these decisions failed to strike a long-term balance between meeting the needs of the environment and those of a growing economy and population”. Although the MDBA is necessarily constrained by the provisions of the Act, it is wise that this link is at least recognised.
The population living within the Basin continues to grow, as do the demands from the growing population outside the Basin which depends on it for water and economic return. With an acknowledged 10% reduction in surface water flows in the system, added population growth must seriously increase the predicted impacts. Being unable to take this into account in your deliberations prevents the MDBA from fully addressing the issue of ever-growing pressure on this river system.
Given that the MDBA clearly recognizes that population growth has been a significant causative agent in the degradation of the Basin, it hardly makes sense to reduce by 30% the amount of water available to industry etc and not expect a growing population to place even greater pressures on the system.
Sustainable Population Australia recommends that the MDBA advise the Federal Government that further amendments are required to the Water Act 2007 to allow the Authority to take into account population pressures on the Murray Darling Basin.
Primacy of the environment in decision-making
In the sensationalised media reporting that has occurred since the release of the Guide, very few people appear to have been speaking up for our precious river system. While loud criticisms have been made about the environment having primacy over economic and social needs, the Guide realistically recognises the long term nature of the plans that will need to be implemented and the ultimate impact that continuing environmental unsustainability will have if not addressed. SPA is pleased by the MDBA’s understandings.
The MDBA is required by the Act to “maximise net economic returns to the Australian community from the use and management of Basin water resources while protecting, restoring and providing for the ecological values and ecosystems services of the Basin”. The MDBA should operate from the perspective that the economy is a subset of the environment and that the latter will eventually fail without the survival and preservation of the former.
It is true that Australia feeds 60 million people, with much of that produce coming from the Murray-Darling Basin. But we have been doing this at enormous environmental cost. It is not even clear that we can provide for the existing 22½ million on an environmentally sustainable basis, particularly with the added impact of climate change.
The Guide puts it well when it states “The real possibility of environmental failure now threatens the long-term economic and social viability of many industries and the economic, social and cultural strength of many communities”. What separates the two ideas is time – the short term need to eke out a living, and the longer term impact that will inevitably occur as a consequence of environmental destruction, including such impacts as salinity and soil acidification which are already having a negative economic impact.
Sustainable Diversion Limits
The Guide presents three scenarios for sustainable diversion limits (SDLs) but the Authority has chosen the lowest of the three, which may well have been chosen to soften the reaction of irrigator groups. We are unclear as to why the medium or high scenarios were rejected by the MDBA. Those bargaining-up for the environment and future generations of water users do not attract the publicity that angry irrigators do but their – and our – concerns for voiceless animals, natural systems and future peoples whose livelihoods also depend on healthy rivers should not be ignored simply because they can be shouted down in the present.
SPA recommends that the MDBA should base their decisions not on lobbying power, but on the best available science, and with an increasing population this requires adoption of the high scenario.
The MDBA has used the average of 115 years of rainfall records in the Basin. SPA believes it ought to at least be the median, given that the Basin historically experiences drought conditions 60% of the time. Additionally, the rainfall and evaporation rates vary considerably throughout the system, so an average applied to the whole Basin might not be mathematically or scientifically correct.
Professor Mike Young of the Environment Institute at Adelaide University has suggested that the SDLs should be developed on a regional basis, rather than an average across the whole system, and SPA believes this to be a sensible suggestion.
Because of huge regional variability in rainfall and evaporation in the Basin and drought conditions being the norm, SPA recommends that the MDBA should consider basing the SDLs on medians rather than averages, and applying them on a regional basis rather than a one-size-fits-all approach.
Having said that, we are pleased that the SDLs will be applied to interception activities, which might help to redress some of the damage caused in recent years by forestry plantations in areas of rainfall not necessarily appropriate for that form of landuse.


Just compensation
But for some in the irrigation industry, the changes that were effectively mooted in the passage of the Act and pursued in the Guide will result in reductions and in some cases losses of livelihood. We draw your attention to the precedent of the timber industry in Ravenshoe, Queensland, when loggers had to withdraw from their lifetime jobs in that industry. As part of the nation’s decision that we should preserve old growth forests, retraining and compensation were provided by the Federal Government. It is important that irrigators who are placed in a similar position be enabled to exit the industry with some dignity, and that this will require just compensation.


Yours sincerely


Sandra Kanck
National President

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