Amending the Water Allocation Plan for the River
Murray Prescribed Watercourse
2
Proposed conclusion of prior commitment
in the salinity zoning policy
This paper outlines the conclusion of prior commitment in relation to the salinity zoning policy and
how it has been incorporated into the draft Water Allocation Plan for the River Murray Prescribed
Watercourse (the plan). Background into salinity management and the options considered for the
plan are also detailed in this paper. The Board is keen to hear what you think of the draft plan.
What has been included
in the draft plan?
Why was this option
chosen?
How does this change
from the current plan?
What does this mean
for me?
How can I provide
feedback on this
proposal?
5-Dec-14
The River Murray salinity zoning policy has been incorporated into the draft plan,
with a six month grace period before the conclusion of prior commitment claims.
 Prior commitment was intended as a transitional policy. As the salinity
zoning policy has been in place for 10 years it is appropriate to conclude the
policy.
 This will free up salinity credits which were quarantined for prior
commitment claims that may not eventuate.
 The application process for new site use approvals will also become more
transparent.
 The current plan includes two principles around salinity management, but
the policy for implementing these principles has sat outside of the plan.
 In practice the salinity zoning policy has been operating since 2003,
including it in the plan will be more transparent to River Murray users.
 The prior commitment component of the salinity zoning policy will be
concluded following a six month grace period from the date of adoption of the
plan.
 After this period, prior commitment claims will no longer be assessed. This
will ensure there is no net increase in the volume of water authorised to be
used in the High Salinity Impact Zone.
 The River Murray salinity zoning policy will continue to be implemented
through site use approvals, and applications will continue to be assessed in
line with the salinity zoning policy.
You are invited to provide feedback on the draft plan until the close of formal
consultation on 27 February 2015.
Written submissions can be made:
Online: www.naturalresources.sa.gov.au/samurraydarlingbasin
Via email: [email protected]
By post: Peta Brettig, Senior Project Officer, River Murray WAP
Natural Resources SA Murray-Darling Basin
GPO Box 2834, Adelaide SA 5001
Or contact Peta to discuss: Peta Brettig 8463 6877 / 0439 824 477
Page 1 of 6
Key points
Related papers
The Salinity Zoning Policy was approved in 2003 to maximise potential for
irrigation development along the River Murray, while ensuring South Australia
can meet its obligations to the Murray-Darling Basin Authority (MDBA).
 South Australia is a signatory to the Murray-Darling Basin Agreement – Schedule
B and is obliged to maintain a positive balance on the salinity registers.
 Prior commitment provisions were a transitional arrangement upon the
introduction of the salinity zoning policy.
 As the Salinity Zoning Policy has been in place for 10 years, the draft plan
includes provisions to conclude prior commitment provisions following a six
month grace period from the date of adoption of the plan.
Paper 1: River Murray salinity zoning policy
Paper 3: Undocumented panel assessed prior commitment claims and salinity
management

Background
As groundwater discharges to the River Murray, it delivers large amounts of salt to the river channel. This is
a natural process but the clearance of native vegetation and irrigation has increased drainage to the
underlying groundwater, accelerating the movement of salt into the river.
The South Australian Government manages salinity in the River Murray at an acceptable level through salt
interception schemes and the Salinity Zoning Policy. The objective of the Salinity Zoning Policy is to
maximise the potential for irrigation development, while ensuring that South Australia’s balance on the
basin salinity management salinity registers remains in credit. These mechanisms help fulfil South Australia’s
obligations as a signatory to Schedule B of the Murray-Darling Basin Agreement
(Schedule 1, Water Act 2007 (Cwth)). Under this agreement, South Australia is accountable for any actions
that increase or decrease salinity impacts on the River Murray. This includes irrigation development.
The Salinity Zoning Policy establishes three salinity impact zones: high, low and high (salt interception).
Each of these 3 zones has rules relating to authorisation of applications for new irrigation developments and
uses a system of credits and debits to offset salinity impacts of irrigation development. In all zones, the
proposed water use must be fully offset before the site use approval is granted.
The exception is if an applicant can prove that they were financially or legally committed to a development
prior to commencement of the interim Salinity Zoning Policy on 30 June 2003, then the application may be
approved to proceed (this is commonly referred to as prior commitment). Prior commitment was included in
the River Murray Salinity Zoning Policy as a transitional measure to manage the issues arising from the
introduction of a new policy.
Current policy
Prior commitment ensured that entities that had made significant financial, legal or other commitment
to a development prior to 30 June 2003 within the high salinity zone could proceed with the
development.
There are three forms of prior commitment (Refer to Attachment 1 for further detail):
5-Dec-14
Page 2 of 6



Panel assessed prior commitment (PAPC): a process through which applicants can apply for an
exemption for new development citing significant financial, legal or other commitments at the time
the policy was introduced (30 June 2003);
Mature crop water requirement prior commitment (MCWRPC): a process where applicants apply for
an exemption on the basis of the Mature Crop Water Requirement of the permanent crops planted
prior to the introduction of the Policy; and
Maximum level of development prior commitment (MLDPC): this permits entities with annual crops
to apply for an exemption equal to their historical maximum area of plantings before 30 June 2003.
Proposed policy
The panel assessed prior commitment, mature crop water requirement prior commitment and
maximum level of development prior commitment are now considered no longer required due to:
 The diminished ability of entities to demonstrate a significant financial or legal commitment to a
development pre 2003 due to elapsed time;
 All commonly grown permanent crops planted during or prior to 2003 having reached maturity,
making the mature crop water requirement prior commitment redundant; and
 Most annual crop growers have returned to their maximum volumes (maximum level of
development) based on pre 2003 development levels and having taken action to increase their site
use approval to reflect the volume of water for irrigation required.
It is recommended to remove prior commitment provisions. There will be no net increase in the
volume of water authorised to be used in the High Salinity Impact Zone.
The conclusion of prior commitment will result in a simplified application process for irrigators. In
addition, salinity credits on the Basin Salinity Management Strategy salinity registers will no longer be
quarantined for potential prior commitment claims that may not eventuate and will be available for new
irrigation development in the Low Salinity Impact Zone.
It is proposed that water users in the High Salinity Impact Zone be advised of the proposed policy
change and given an opportunity to submit an application if applicable within a grace period, in which
they may apply to benefit from the exemption prior to its removal from the policy. A grace period of
six months has been incorporated into the recommended option below.
This approach will not impact on the trading of water allocations or entitlements, but will cap the
volume of water which may be applied in the High Salinity Impact Zone. This reflects the intent of the
Salinity Zoning Policy to ensure no net increase in salinity impact within the high impact zone. The
conclusion of prior commitment will also provide a greater number of credits for irrigation
development in the low salinity impact zone.
Once a panel assessed prior commitment claim is approved, the site use approval holder must apply to
increase their site use approval maximum irrigation volume to correspond to that volume approved as
part of their prior commitment (through the completion of an S2 form). There are a number of
outstanding panel assessed prior commitment claims which remain inactivated. These are discussed in
Paper 3, Undocumented panel assessed prior commitment claims and salinity management.
5-Dec-14
Page 3 of 6
Proposed conclusion of prior commitment
in the salinity zoning policy
OPTIONS
Change the prior commitment
claims policy and notify site
use approval holders that they
have 6 months to activate their
prior commitment claim
ADVANTAGES
Salinity credits are made available
to the general salinity credit pool
Appropriate time to conclude,
given it has been 10 years since
the salinity policy implemented
Consistent with the fact that prior
commitment was intended as a
transitional policy
DISADVANTAGES
Limits the amount of time site
use approval holders have
available to apply for a prior
commitment
Some people may want a
longer grace period
Prior commitment can be removed
from the plan, which will provide a
more transparent application
process for new site use approvals
Retain prior commitment
policy and review in 2019
Automatically cease the prior
commitment policy
5-Dec-14
Allows for development to proceed
in the high salinity impact zone if
the prior commitment can be
validated
Will reduce the area of
irrigation which can be
developed with the credits
available
Site use approval holders have the
option of applying for prior
commitment in addition to the
option of conjunctive applications
in the high salinity impact zone
Easy to administer
Claims will be increasingly
difficult to assess given time
passed
All credits in the general pool
would be available for use in the
low salinity impact zone
Does not allow people to
finalise their prior commitment
claim
Page 4 of 6
FEEDBACK
Feedback on the draft plan is invited up until 5pm, Friday 27 February 2015.
Written submissions can be made:
Online: www.naturalresources.sa.gov.au/samurraydarlingbasin
Via Email: [email protected]
By post: Peta Brettig
Senior Project Officer, River Murray Water Allocation Plan
Natural Resources, SA Murray-Darling Basin
GPO Box 2834
ADELAIDE SA 5001
Or contact Peta to discuss:
Phone: (08) 8463 6877
Mobile: 0439 824 477
5-Dec-14
Page 5 of 6
Attachment 1
Panel Assessed Prior Commitment
In the event an entity applies to vary their site use approval (SUA) for the purpose of a new
development, an assessment would be undertaken by a Panel.
Commitment to the development needed to have taken place by the applicant before 30 June 2003
and a significant part of the commitment needs to have taken place after 1 July 2001 and proof of this
commitment must be provided in documentation.
Mature Crop Water Requirement Prior Commitment (MCWRPC) – permanent crops
If an entity applies to vary their site use approval to increase the water available for their existing
permanent crop (planted before 30 June 2003) as it matures, they undergo an internal assessment by
DEWNR Customer Service Staff. Detailed aerial photography and crop surveys collected in 2003 provide
a baseline for assessment from which to compare the application and make a determination as to
whether the crops did exist at 30 June 2003 and what their mature crop water requirement would be.
Since 2003 all commonly grown crops in the South Australian Murray-Darling Basin (SAMDB) are
considered to have reached maturity1.
Maximum level of development prior commitment (MLDPC) – annual crops
In the event an entity applies to vary their site use approval to increase the water available for their
existing annual crop, they undergo an internal assessment by DEWNR customer service staff.
Departmental records including aerial photography are used to determine the maximum development
level for that entity prior to 30 June 2003.
The current Water Allocation Plan for the River Murray Prescribed Watercourse provides adjustment values for Crop Factors
Appendix C, Table 4.
1
5-Dec-14
Page 6 of 6