Submission in response to :
Environmental Flows for the River Murray
South Australia’s framework for collective action to restore river health
2005 – 2010
DRAFT for Consultation – October 2004
December 2004Introduction
The Conservation Council of South Australia (CCSA) is the peak environment body in SA with a membership of over 50 environment groups.
CCSA welcomes the opportunity to comment on the Environmental Flows for the River Murray DRAFT, a document that we believe has the potential to seriously address the critical condition of the River Murray in South Australia.
Each chapter of the document is discussed below.
Ch1. Introduction
CCSA is very concerned that the documents vision, in pursuing the return of at least 1500 gigalitres of water per year by 2018, is insufficient if the objective is to achieve a sustainable relationship with the river.
The appropriate target is the return of at least 1500 gigalitres in annual flows to the river within 5 to10 years. This timescale is based on an ever growing amount of scientific literature discussing decreased system inflows, and the economic, social and environmental predictions within this literature which highlight the need for South Australia to adopt a proactive agenda based on this evidence that a precautionary approach is warranted. Some of this evidence is outlined below:
Australia’s leading river ecologists state that annual flow returns of 1500 gigalitres, will give the river a moderate chance of regaining its health[1]. In other words, this is the bare minimum that must be returned.
It is predicted that more than 2000 gigalitres may be lost from the system over the next 20 years due to:
· water use efficiency savings being used to increase irrigation rather than river flow,
· trade in sleeper licenses,
· land use changes,
· salinity interception schemes, and
· groundwater extraction [2].
The Murray Darling Basin Commission is making similar predictions, suggesting that by 2023, over 2000 gigalitres of system inflows will be lost as a result of climate change, reafforestation, growth in groundwater use and the construction of farm dams [3].
A study recently completed by CSIRO Land and Water suggests that the total Water Requirement of irrigated agricultural land uses in the MDB in 1996/97 was 9,346 gigalitres and which increased by nearly 29% to 12,050 gigalitres in 2000/01[4]. This alarming increase, despite the presence of a cap, is attributed in part to water use efficiency savings being used to increase irrigation rather than river flow and increased groundwater extraction.
The point that is being emphasized is that water losses of more than 1500 gigalitres from the MDB are a possibility by 2018. Therefore, assuming 1500 gigalitres have been successfully returned over the proposed 15 year period, the rivers health will be more critical than it is today. To achieve 1500 gigalitres of increased flows by 2018, flow increases of approximately 3000 gigalitres may have to be acquired.
Ch 2. The First Step : Sourcing, Delivering and Managing Flows to our ‘Significant Ecological Assets’
CCSA would encourage South Australia to not only fulfill its obligations under the Living Murray Initiative (LMI) First Step, but to lead the rest of the MDB states by example and go beyond the obligations. In the event that the LMI fails to achieve a sustainable relationship with the river, South Australia has the most to loose of all MDB states. The opposite also holds true – there is much to be gained from an effective restoration of the system. South Australia should therefore continue to take action above and beyond what is absolutely required to give the initiative its maximum chance of success.
The purchase of water entitlements is by far a most cost effective measure of water recovery. CCSA would encourage South Australia to purchase water entitlements as part of the LMI, but also in significant addition to it. We stress this point, particularly in light of current delays to LMI funding due to disagreements over the National Water Initiative (NWI).
All water entitlements purchased should be permanently removed from the consumptive pool, and the MDB cap reduced accordingly. South Australia should advocate for the immediate capping of all water resources (surface and ground water) in the MDB.
CCSA is concerned that the document may appear to rule out the compulsory acquisition of water entitlements. If this mechanism is not to be used, evidence must be provided that flow volumes capable of achieving a healthy river can be returned through other means.
From a sustainability perspective, the Lower Murray Swamps are an appropriate region to purchase entitlements. Compulsory acquisition of all water entitlements not currently in use in this area should be considered.
Yearly flow return targets should be specified in the document, including appropriate budget allocations, particularly with regard to the restoration of the Significant Ecological Assets. For instance, it is recognized that flows across the barrages of about 2 gigalitres per day would be successful in reducing the risks of mouth closure [5]. This equates to about 730 GL per year, a vital flow return target.
The mouth is the only natural way to flush salt out of the MDB.
Ch.3 Taking it a Step Further: Addressing the Flow Needs of our Other Important Ecological Assets
CCSA supports the broad objectives of this chapter. The reconnection of the river to its floodplain and wetlands is fundamental to the process of restoring the system to health.
We would also stress the importance of a coordinated SAMDB wide approach to revegetation, a process critical for habitat restoration and the mitigation of erosion and salinity. The award winning Murray Mouth Estuary Restoration Project provides a good example of wetland and riparian indigenous revegetation.
Ch.4 Getting Support Systems in Place
Again, CCSA supports the objectives of this chapter. We would highlight the fact that all water entitlements purchased for environmental flows should be permanently removed from the consumptive pool and the MDB cap reduced accordingly. South Australia should be proactive and allocate significant funds to allow this investment to happen. The cost of purchasing water entitlements in the future will increase dramatically.
Conclusion
The critical health of the River Murray is a National State of Emergency and an issue of internal security. Whilst much of SE Australia has been in drought over the past few years, CCSA would like to emphasize that climate change is very real and upon us. We have to therefore plan accordingly, recognizing that we are living in changing times.
pro.
[1] Cooperative Research Centre for Freshwater Ecology (2003) Ecological Assessment of Environmental Flow Reference Points for the River Murray System – Interim Report prepared by the Scientific Reference Panel for the Murray Darling Basin Commission, Living Murray Initiative.
[2] Young & McColl, 2003, Robust Reform: The Case for a New Water Entitlement System for Australia, The Australian Economic Review, vol. 36, no. 2, pg. 227.
[3] Murray Darling Basin Commission, 2003, Prospects for future deterioration in flow in the Murray Darling Basin.
[4] Bryan & Marvanek, 2004, Quantifying and valuing land use change for Integrated Catchment Management evaluation in the Murray-Darling Basin 1996/97 – 2000/01, pg.5.
[5] Close, A, 2002, Options for Reducing the Risk of Closure of the River Murray Mouth, MDBC Technical Report, 2002/2.
