Dear Craig,
We would like to thank you for the 4 October 2011 briefing provided in Sydney by the MDBA staff on their current thinking regarding the Draft Basin Plan proposed for release in mid -November 2011.
The following day Environment NGOs went on to discuss their concerns relating to the current thinking on Basin Plan.
The group agreed that it was critical to provide their considered response to that briefing prior to release of the Basin Plan.
1. We are deeply concerned that the figure of 2800 GL appears to have been driven by a range of factors apart from best available science, such as system constraints, and socioeconomic analyses, that have been deployed at a range of decision points during the hydrologic modelling process.
It is unclear when the MDBA adopted the figure of 2800 GL and what was the best available science on which they relied to support their decision. The modelling and science underpinning the environmentally sustainable level of take in the draft Basin Plan must be based on best available science.
Any trade-offs based upon system constraints, socio-economic data or local knowledge should occur after the environmentally sustainable level of take has been decided and these should be made explicit, as should the impacts of those trade-offs on environmental outcomes.
We would appreciate the list of system constraints being made public at the time the Draft Basin Plan is released. Many of these constraints have been agreed to be modified with Federal and State Government funding previously, such as the Gundagai Bridge, but several others that were discussed in our meeting with the MDBA appeared to be very vague and non specific.
2. Several peer reviewed scientific studies independently concluded that extractions would need to be reduced by at least 4000GL, compared to the 2009 baseline (i.e. pre buybacks), in order to achieve an environmentally sustainable level of take. This was also the figure presented in the Authority's End of System Flow modelling contained within the Guide. We asked at the meeting and we continue to seek clarification of when the 4000 GL SDL became 2800 GL as the figure supported by best available science? In our view, based on the best available science, the MDBA is taking an enormous risk publishing a Draft Basin Plan without at least modelling the 4000 GL scenario using the hydrologic modelling.
3. The independent peer review process of the hydrologic modelling that was undertaken well prior to the release of the Guide cannot be relied upon by the MDBA as a peer review of the current hydrologic modelling. An independent peer review of the current hydrologic modelling on which the Draft Plan is based must be made public at the time of the release of the Draft Basin Plan.
4. The MDBA's adoption of a scenario which results in a high risk of the Basin's key environmental assets and ecosystem functions remaining in a poor or moderate condition is unacceptable, as has been stated several times by Minister Burke. We advocate a Basin Plan developed according to the precautionary principle. Any adaptive management must therefore start with a higher (lower environmental risk) volume to be returned to the environment; this should be reduced only if and when delivery of ecological outcomes has been demonstrated.
5. We note the MDBA is committed to adopting an adaptive management approach to the Basin Plan. We commend the Strategic Adaptive Management process adopted in the Macquarie Marshes and the Lake Eyre Basin as illustrating current best practice on adaptive management of river and wetland ecosystems, a process that has strong local knowledge input. For adaptive management to work it requires articulation of clear ecological outcomes, thresholds and targets based on best available science; systematic scientific monitoring; and agreed adaptation actions to occur at specified stages. It also requires adequate representation from all stakeholders, and sufficient resources committed for the entirety of the process. We are of the view that the MDBA should be very careful to ensure that the Draft Basin Plan achieves the correct balance between gaining knowledge to improve management in the future and achieving the best short -term outcome based on current best available science.
We request that as Chair of the independent Authority charged with developing the Murray-Darling Basin Plan you consider adapting the process to incorporate these points.
We understand that the Draft Plan will be released in mid-November and thus time is of the essence.
We look forward to hearing from you as a matter of some urgency.
Yours sincerely,
Juliet Le Feuvre, Environment Victoria
Dr Arlene Harriss-Buchan, Australian Conservation Foundation
Belinda Fairbrother, The Wilderness Society (Sydney)
Nigel Parratt, Queensland Conservation Council
Barney Stevens, Darling River Action Group
Jonathon La Nauze, Friends of the Earth
Prof Diane Bell, River, Lakes and Coorong Action Group; Conservation Council of South Australia
Anne Reeves, National Parks Association NSW
Don White, Nature Conservation Council of NSW
Bev Smiles, Inland Rivers Network
John Pettigrew, Environmental Farmers Network
Nicola Rivers, Environmental Defenders Office (Victoria)
