Summary of feedback on the
Basin-wide environmental watering strategy
Murray–Darling Basin Authority
24 November 2014
Published by Murray–Darling Basin Authority.
MDBA Publication No 43/14
ISBN 978-1-925521-15-2 (online)
©Murray–Darling Basin Authority for and on behalf of the Commonwealth of Australia, 2014.
With the exception of the Commonwealth Coat of Arms, the MDBA logo, all photographs,
graphics and trade marks, this publication is provided under a Creative Commons Attribution
3.0 Australia Licence.
http://creativecommons.org/licenses/by/3.0/au
The MDBA’s preference is that you attribute this publication (and any material sourced from
it) using the following wording:
Title:
Summary of feedback on the Basin-wide environmental watering
strategy
Source:
Licensed from the Murray–Darling Basin Authority, under a Creative
Commons Attribution 3.0 Australia Licence.
Author:
Murray–Darling Basin Authority
Editor:
Kerryn Molloy
The MDBA provides this information in good faith but to the extent permitted by law, the
MDBA and the Commonwealth exclude all liability for adverse consequences arising directly
or indirectly from using any information or material contained within this publication.
Cover Image: Cormorants nesting in Barmah Forest, NSW. Photo: Keith Ward.
Acknowledgement of the Traditional Owners of the Murray–Darling Basin
The Murray–Darling Basin Authority acknowledges and pays respect to the Traditional
Owners, and their Nations, of the Murray–Darling Basin, who have a deep cultural, social,
environmental, spiritual and economic connection to their lands and waters. The MDBA
understands the need for recognition of Traditional Owner knowledge and cultural values in
natural resource management associated with the Basin.
The approach of Traditional Owners to caring for the natural landscape, including water, can
be expressed in the words of Darren Perry (Chair of the Murray Lower Darling Rivers
Indigenous Nations) —
‘The environment that Aboriginal people know as Country has not been allowed to
have a voice in contemporary Australia. Aboriginal First Nations have been listening
to Country for many thousands of years and can speak for Country so that others can
know what Country needs. Through the Murray Lower Darling Rivers Indigenous
Nations and the Northern Basin Aboriginal Nations the voice of Country can be heard
by all’.
The use of terms ‘Aboriginal’ and ‘Indigenous’ reflects usage in different communities within
the Murray–Darling Basin.
Contents
Introduction
Consultation process
Consultation outcomes
1
1
2
Overall feedback and main challenges
2
Feedback on and changes to expected environmental outcomes
3
Feedback on and changes to water management strategies
5
Feedback on and changes to roles and responsibilities
8
Feedback on and changes to identifying annual environmental watering priorities
8
Feedback on and changes to measuring success
9
Feedback on and changes to future work
9
Social and economic matters
9
Indigenous values and uses
10
Corrections
10
Other matters
10
i
Introduction
This report provides a summary of feedback on the draft Basin-wide environmental watering
strategy (the strategy).
The strategy details approaches to managing environmental watering to help achieve
environmental outcomes from the Basin Plan. It also explains how we will identify Basin-wide
annual watering priorities to give effect to the strategy.
Consultation process
During the strategy’s preparation, expert advice was sought. This included:
•
detailed input from the Basin Plan Implementation Committee (an inter-jurisdictional
committee with representation from all Basin governments) and its Environmental Watering
Working Group
•
workshops held with environmental water practitioners
•
technical assistance from numerous consultants, experts and scientists.
The draft strategy was released for review by interested parties. This process included:
•
a public comment period from 21 August to 26 September 2014, with submissions
accepted via our website, by email, post and in person (see next two points)
briefings to peak organisations, representing:
o
o
o
•
Aboriginal Nations
farming and irrigation interests
conservation groups
additional briefings to:
o
o
environmental watering advisory committees and water delivery customer service
committees where requested, e.g. Goondiwindi, Dubbo and Bourke
committees that we regularly consult with (the Basin Consultative Committee, the
Northern Basin Advisory Committee and the Advisory Committee on Social, Economic
and Environmental Sciences).
a range of public meetings (Goolwa, Murray Bridge, Renmark, Mildura, Shepparton,
Deniliquin, Griffith and Dirranbandi).
At the meetings (held in early September), MDBA joined with the Commonwealth Department
of the Environment, the Commonwealth Environmental Water Office, state governments and
local natural resource management organisations to provide updates. Information discussed
included not only the Basin-wide environmental watering strategy, but also the status of Basin
Plan implementation and the work of the various agencies’ programs.
All submissions received were considered, including some received after 26 September.
1
Consultation outcomes
Feedback was received from 41 respondents via submission. This was in addition to the
information provided at the meetings and briefings. This feedback was received from:
conservation organisations, agriculture industries and water providers, government agencies,
local councils, Indigenous organisations and individuals. Most respondents agreed to
publication of their feedback, which is available on our website.
Overall feedback and main challenges
Submissions received were generally positive and noted that the draft strategy:
•
was readable and logically structured
•
provided a framework for Basin-scale, long-term thinking
•
assists the community to understand what the Basin Plan will achieve with environmental
water
•
included helpful case studies.
Of the 41 submissions:
•
23 (56%) were supportive
•
5 (12%) were unsupportive
•
13 (32%) did not specify support or otherwise, although many sought some clarification.
The main changes that the MDBA has made are:
•
describing the basis for expected outcomes
•
listing the references that underpinned the work on expected environmental outcomes
•
describing the relationship between the strategy and water resource plans
•
providing more information on how annual priorities will be set, especially in very dry
periods
•
adding a case study on environmental watering undertaken with an Aboriginal community
•
changes that more clearly describe the healthy working Basin concept, how cultural flows
are treated, how water quality is treated, end-of-Basin outcomes, and what is meant by
managing to conditions;
•
adding vegetation condition data and important fish sites (as the draft indicated would
happen)
•
some corrections and improvements to text.
Several submissions raised specific matters about the content of the draft strategy and other
water reform matters. More detailed information about the feedback we received and the
MDBA’s response follows below.
2
Feedback on and changes to expected environmental outcomes
Most feedback supported the approach to quantifying expected environmental outcomes. A
high proportion of submissions (76%) addressed expected environmental outcomes directly:
•
•
•
two thirds expressed support for expected environmental outcomes
one third wanted more information or substantiation of the expected environmental
outcomes (including how they would be measured and the baselines from which they were
developed)
one submission sought the removal of expected environmental outcomes.
Of the submissions that supported expected environmental outcomes, 93% wanted outcomes
that were more ambitious and 96% wanted additional outcomes to be included.
Notwithstanding, a few people thought certain outcomes were too ambitious or may not be
achievable. Some people also expressed a view that certain outcomes were too prescriptive,
especially for managing in dry periods, or went beyond the scope of the Basin Plan. Some
people preferred numerical outcomes to percentages (where these were used) and some
sought interim targets to 2019.
People requested additional outcomes be covered in the strategy. These included for
seasonality of flows, Indigenous values and uses and for other types of biota.
Response:
•
Additional text has been added to clarify how the outcomes will be assessed in dry
conditions.
•
The expected environmental outcomes have not been amended given that the extensive
technical analysis undertaken in the preparation of the strategy shows that the expected
outcomes should be achievable through the implementation of the Basin Plan and are not
too ambitious. Similarly, the technical analysis suggests that more ambitious outcomes are
unlikely to be achievable.
•
Additional outcomes have not been included given the time available. However, the MDBA
will continue to review and update the strategy and the potential to include additional
quantified outcomes will be explored as part of this process.
Baselines and references
Many submitters asked for information about the work underpinning the expected
environmental outcomes and the baselines (or starting point) for measuring improvement in
the Basin’s environment. People said this was important to understand how we arrived at the
outcomes, and for monitoring and evaluating the effectiveness of the strategy.
Response:
•
Information has been included about the basis for expected outcomes, and a list of
references has been added.
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River flows and connectivity
People suggested including an expected environmental outcome for reinstatement of natural
patterns in seasonality of flows. Some people also requested that the MDBA identify important
constraints that will hinder achieving river flows and connectivity targets. There were
suggestions that the strategy be extended to cover smaller unregulated rivers.
Response:
•
Some changes have been made that reflect technical advice on the characteristics of
particular catchments.
•
The MDBA recognises the importance of natural patterns in seasonality of flows and
environmental watering will largely be undertaken consistently with these patterns.
However, most major dam releases will still coincide with irrigation demands and these are
generally the inverse of natural patterns in seasonality.
•
The strategy takes a whole-of-basin perspective. Long-term watering plans and water
resource plans will address local and regionally-significant matters, including details for
smaller unregulated rivers.
Native vegetation
Feedback included suggestions to focus more on non-woody and submerged plants, and to
include a target for increased native vegetation extent—in particular for woody riparian
vegetation communities in regulated and unregulated rivers. There was also a view that native
vegetation targets were particularly low for the Murray catchment in relation to the area of large
floodplain forests.
Response:
•
The data currently available at the Basin-scale for non-woody, submerged and other plants
are limited and do not enable meaningful outcomes to be developed.
•
The MDBA will continue to review and update the strategy as appropriate; and additional
quantified outcomes may be part of these considerations.
•
Targets for native vegetation have been retained because these are achievable whereas
targets for the full scope of the large floodplain would not be achievable.
Waterbirds
Some submissions questioned the validity of the quoted percentage decline in waterbird
numbers. Other people said the outcome for abundance of waterbirds should be higher,
suggesting that the population levels of the 1980s would be a more appropriate. Some of the
important sites for waterbirds identified in the strategy were questioned.
Response:
•
Text was added to clarify the assessment of waterbird decline in the Basin.
4
•
Some water storages identified as important sites for waterbirds were removed from the
listing in Appendix 4 and from maps. Although they are important sites of refuge for certain
species, it is not possible to actively manage them.
•
The waterbird abundance dataset is one of the most comprehensive long-term systematic
datasets available. However, it has limited coverage of the 1980s. Accordingly, it is not
possible to confirm the suggestion that population levels during the 1980s represent a
more appropriate abundance target than the 1990 level outcome which we expect can be
achieved.
•
If data in the future demonstrate that the current waterbird outcomes are overly
conservative they can be updated.
Native fish
Some people were concerned that targets were too high, especially in the northern Basin.
Contrasting submissions wanted higher targets given the severe decline of native fish and the
poor condition of many populations. Many submissions noted that external factors (other than
water management) can have a strong influence on native fish. Submissions also raised
technical matters, including future work.
Response:
•
The fish targets are unchanged in the final strategy given the technical analysis that
underpins the strategy indicates that the expected outcomes should be able to be achieved
through the implementation of the Basin Plan. Similarly, the technical analysis suggests
that more ambitious outcomes are unlikely to be achievable.
•
Additional text has been included to give greater recognition to complementary measures
that need to be undertaken in tandem with environmental watering to improve outcomes for
native fish.
•
Where submissions recommended technical amendments these have been included,
where appropriate.
•
Identifying outcomes for the native fish community as a whole has been included as a
matter for future work.
Feedback on and changes to water management strategies
Some people wanted more detail about how water will be used to benefit the environment.
Submitters said it was important to recognise that the northern Basin needs different watering
strategies. Specific strategies for the Lakes Alexandrina and Albert were sought by some
people, including improving variability of flows to support fringing vegetation and other biota.
Some people said the strategy should recognise the role of works and measures.
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Response:
•
The strategy has a long-term, Basin-wide focus. Consequently, it is not the place for
detailed prescriptions on the use of water at a regional or local scale. Long-term watering
plans and water resource plans will address specific local or regional strategies, as
appropriate. Rather, the strategy sets out quantitative outcomes and high-level watering
strategies that can be applied in the highly-variable climate of the Basin.
•
In some cases works and measures can improve environmental outcomes—these
activities are being pursued through different pathways, such as the SDL adjustment
mechanism. Additional text has been added to acknowledge that there will sometimes be a
role for works in the watering of some sites.
Managing all water
Some feedback explicitly supported managing all water available to benefit the environment
and achieve expected environmental outcomes. They said that the strategy should include a
stronger message about the need to use water efficiently. An alternative view was that the
strategy should be limited to managing held environmental water. It was suggested that river
operating practices might need to be reviewed and changed to facilitate and support the use of
all water. Another suggestion was to explore ‘pulsing’ consumptive water releases to provide a
more natural rise and fall in regulated systems—re-routing consumptive water through ‘needy’
ecosystems where possible.
Response:
•
The MDBA considers that it is vital that all water be managed to provide for the best
environmental outcomes. That is in terms of what is practical in the context of a healthy,
working river system—and this is clearly stated in the strategy.
•
However, it is not appropriate that a Basin-wide, long-term strategy address this in detail.
Rather, these will be matters for long-term watering plans, water resource plans and river
operators to address. There are currently opportunities to do this through various activities
related to the Basin Plan (for example the Constraints Management Strategy 2013–2024)
but it will also be ongoing activity which needs to be locally owned and implemented.
Influence of other factors and complementary actions
People asked for more information to be included about complementary actions required to
ensure the expected environmental outcomes are met (e.g. managing pest fish species or
stream bank stability). Many respondents said the strategy gave insufficient weight to the role
and influence of other natural resource management factors or the risks (such as climate) that
may influence achievement of the expected environmental outcomes. They said that these
factors and risks should be clearly stated. People said the strategy should provide a clearer
link to other Basin Plan implementation activities, including the Northern Basin work program.
6
Response:
•
Additional text has been provided that clarifies the importance of other factors and of
complementary actions and that their impact will be accounted for when the outcomes are
evaluated.
•
A rigorous technical approach was taken to identifying the expected environmental
outcomes. The technical analysis did not assume any changes in actions other than in
relation to the management of water. Accordingly, the expected outcomes do not
necessarily rely on complementary actions. However, outcomes will be improved if
complementary actions are undertaken; and conversely may not be achieved if there are
other factors driving a decline.
•
The Basin Plan is not permitted to play a role beyond water management. The strategy
was developed given the current levels of knowledge and in advance of the implementation
of other Basin Plan elements, including the Northern Basin review. Links to these other
elements of work have been clarified or improved where relevant.
•
Should new knowledge arise from these processes, it will be incorporated into future
iterations of the strategy or into long-term watering plans as relevant.
Meeting salinity and water quality targets
Several respondents said the strategy should be more explicit about how salinity and water
quality targets will be met through environmental flows. Also, that the strategy needed to more
strongly identify the relationship between water quality and river health, including water quality
throughout the Basin, not just at the end of the system.
Response:
•
The text in the explanatory box on water quality has been updated to clarify that water
quality and salinity management is dealt with in the Water Quality and Salinity
Management Plan (Chapter 10 of the Basin Plan). The strategy deals principally with
environmental watering.
Relationship of strategy to constraints
People said the strategy should be more explicit about the constraints that are preventing or
will limit achievement of the expected environmental outcomes. Other respondents said we
should not allow constraints to limit objectives and should consider an approach that allows
objectives to be revised upwards as constraints are addressed and watering opportunities
improve.
Response:
•
The MDBA developed a Constraints Management Strategy 2013–2024 to help guide the
work of identifying and removing or modifying physical and operational constraints.
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•
The expected outcomes and watering strategies outlined in the Basin-wide environmental
watering strategy are based on current constraints. Addressing constraints in the coming
decade is expected to improve the environmental outcomes achievable beyond those
outlined in the first iteration of the strategy.
•
As constraints are overcome, the strategy can be updated to take account of additional
opportunities.
•
Minor changes have been made to clarify these issues in response to this feedback.
Feedback on and changes to roles and responsibilities
Some people expressed concern about the number of agencies involved in different roles and
consequent risks to planning and management of water for environmental benefit. The
potential for duplication was also raised as a concern. Some people sought more detail on
roles and responsibilities.
Feedback also sought strategies for better coordination, consistency and cooperation among
jurisdictions and water managers, including stronger guidance on use and accounting of
planned e-water across the Basin.
Response:
•
Australia’s federal system of government means that there will continue to be multiple
players in water management in a Basin where six jurisdictions have responsibilities.
•
The details of agencies involved in environmental watering varies considerably across the
basin. MDBA felt that to specify these to a greater detail, than currently provided, would be
unwieldy and inappropriate, at this time.
•
The role of the strategy is to set out the required outcomes and high-level strategies to
achieve them. Day-to-day coordination of environmental watering will be undertaken by
those who hold and manage water and who must have the capacity to respond quickly to
opportunities.
•
Long term watering plans and water resource plans, to be developed by States in the
coming years, will detail local coordination and cooperation strategies relevant to each
region for the use and accounting of both held and planned environmental water.
Feedback on and changes to identifying annual environmental watering
priorities
People asked for more detail about how MDBA sets annual environmental watering priorities.
In particular on how priorities will be set in dry periods when environmental water is limited but
demand is great.
Response:
•
Additional content has been added on prioritisation in dry periods.
8
Feedback on and changes to measuring success
Some people expressed concern about the timing of expected outcomes relative to the date
when the sustainable diversion limit takes effect and the deadline for water resource plans –
2019. Some submissions said that a lack of a rigorous monitoring framework will make it
impossible to assess whether outcomes are being achieved; or if they are being achieved
efficiently.
Response:
•
The MDBA has published a Basin Plan evaluation framework that explains the monitoring
and evaluation methodology. References to this framework have been included in the
revised document.
•
The technical analyses underpinning the development of the expected outcomes modelled
progress towards achievement of the outcomes against a wide range of potential climatic
scenarios. This means that actual progress over a series of dry (or wet) years can be
gauged against the progress that would be expected for that climatic sequence. Text has
been added to clarify this assessment approach.
•
The targets to measure progress towards the objectives (set out in Schedule 7 of the Basin
Plan) are general and high-level. Targets to 2019 are ‘no loss or degradation’ of a range of
matters. The expected outcomes in the strategy are focussed on the long-term
improvement that can be expected (beyond 2019). Technical analysis (including the water
recovery progress to date) suggests that the outcomes should be achievable by 2024,
unless specified otherwise.
Feedback on and changes to future work
People asked for more detail on additional elements to be covered in future editions of the
Basin-wide environmental watering strategy.
Response:
•
The chapter on future work has been updated to provide a clearer indication of potential
future directions.
Social and economic matters
Several respondents said the strategy did not recognise the social and economic benefits of
river regulation; such as making it possible to manage flows to key sites while protecting public
and private third-party interests. A related comment was that the strategy had not taken full
account of the social and economic costs and benefits associated with meeting the expected
environmental outcomes, e.g. the costs and benefits of floodplain connectivity. Some people
said the strategy did not provide any reassurance that reliability and deliverability of water
entitlements and allocations will be maintained.
9
Response:
•
The purpose of the strategy is principally to guide environmental watering at a Basin scale
and over the long-term. Accordingly, it does not describe the detailed social and economic
benefits of river regulation. The Basin Plan explicitly took into account the social and
economic benefits of river regulation and consumptive water use in determining the
sustainable diversion limit. Water resource plans and other Basin state instruments
address entitlements, allocations and reliability.
•
The strategy recognises that environmental watering is undertaken in the context of a
healthy, working river system. The text in the explanatory box on a healthy, working river
system has been updated to more clearly reflect this context.
Indigenous values and uses
Feedback from Aboriginal people (and other submitters) said their experience and knowledge
had not been sufficiently used in the preparation of the strategy. They also sought more
recognition in the strategy of the value of environmental water to Aboriginal people—a case
study was suggested. Some people suggested including flow targets, expected outcomes and
associated watering strategies that take account of the cultural and spiritual needs of
Aboriginal people. Some also said that progress was needed to give effect to aspirations for
cultural water, to provide cultural flows, and to better integrate cultural and environmental
watering.
Response:
•
A case study has been included as an example of Aboriginal people’s involvement in
managing environmental water, delivering cultural benefits as well as environmental
outcomes.
•
Other sections have been re-worded to more clearly express the policy position, including
an explanatory box on Indigenous values and uses.
Corrections
In response to advice, a number of corrections and other changes to figures have been made.
Other matters
Feedback included comments about issues that are not related to the strategy. These
included:
•
state matters, such as the management of dams, weirs and barrages
•
trading of the Commonwealth Environmental Water Holder’s environmental allocations
•
the volume of water to be recovered for environmental purposes
•
more general matters relating to the Basin Plan or Water Act.
No changes were made to the strategy regarding this feedback.
10