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NIC Submission:
Proposed Amendments to Requirements for Commercial Forestry Projects – The Water Rule
Background
The National Irrigators’ Council (NIC) is the peak industry body for irrigated agriculture in Australia. NIC is the voice of irrigated agriculture and the industries producing food and fibre for domestic consumption and significant international trade. Put simply, our industry is helping to feed and clothe Australia and our trading partners. Irrigated agriculture in Australia employs world leading practices in water management. The industry has extensively adopted and embraced new technologies and knowledge to ensure we are consistently growing more with less water. Australian farmers also operate under strict regulations and compliance mechanisms. These factors mean we lead the world in both farming practices
and produce quality.
NIC’s policy and advocacy are dedicated to growing and sustaining a viable and productive irrigated agriculture sector in Australia. We inform, we listen and we debate ideas, but we always seek to collaborate in the best interests of all water users. We are committed to the triple bottom line outcomes of water use - for local communities, the environment, and for local and the national economies.
Key Messages
All water users must adhere to the ideals and rules of the National Water Initiative and Murray-Darling Basin Plan
NIC supports carbon initiatives and encourages action to address climate change, however action to address carbon shouldn’t be traded for inaction on water management
NIC does not support the removal of the Water Rule for forestry products as it places the burdens of water management and reform on the irrigation sector
Industries within the irrigation sector would have similar carbon capture benefits to forestry, so if the rule is to be removed it should be removed for those industries too
Discussion
In response to the call for submissions by the Department of Climate Change, Energy, the Environment and Water on removing the Water Rule, NIC sets out the following response, primarily addressing the Consultation Paper’s question - Are there any other benefits and/or impacts that should be considered in the decision to remove the water rule?
Within the Murray Darling Basin in any given year all water in the system has been allocated, either for consumptive use, conveyance water or water for the environment. This allocation of water is a basic principle of the Basin Plan.
While NIC supports the forestry industry and others, including sectors of the irrigation industry, which can provide carbon benefits, these benefits should not be at the expense of other regulations, such as the National Water Initiative and Murray-Darling Basin Plan. If the Government seeks to reward forestry and other businesses which can sequester carbon, they should do so through credits and other mechanisms.
Under the current rules, farm forestry projects and forestry plantations are required to have access to or acquire unused water which can offset any water interception. The Water Rule means these plantations must:
have a suitable water access entitlement, or
be located in a region where the Department of Climate Change, Energy, the Environment and Water determines the relevant state or territory government is adequately implementing National Water Initiative commitments to manage water interception by plantations, or
be in a region specified as one in which tree planting is unlikely to have a material adverse impact on water availability, or
be located in a region where a water access entitlement cannot be obtained, and they can be demonstrated (supported by advice from a state or territory agency) to not have a material impact on water availability or water access entitlements, or
show the project helps to manage dryland salinity.
The Minister for the Environment and Water has made numerous comments on finalising the Basin Plan and the Department is currently drafting a Water Recovery Strategy. These actions will likely lead to water being recovered, in any number of ways, from the productive sector and given to the environment with the justification that more volumes are needed. This change would seem to go against that justification. Removal of the water rule, allowing one industry free reign on water access, seems to go against the principles and ideals of the Plan, of finalising the Plan, and places the burden of water recovery and regulation on the irrigation industry.
Reforms such as this may have unintended consequences, such as farmers opting to grow forestry products instead of the food and fibre they currently grow. Free water, as opposed to the purchase of entitlements and allocations, would be a large incentive, especially as further water recovery drives up the price of water. It may also mean prime agricultural lands used to grow our food and fibre, become forestry plantations, which would have economic and trade consequences, as well as food availability and security issues.
Every drop of water used by the irrigation sector is metered and monitored under the threat of significant fines and penalties for breaches. Allowing other industries to just take water without oversight is against the ideals and principles of both the National Water Initiative and the Murray-Darling Basin Plan. All water users in the system should have to have an entitlement or allocation to use water if the system is to remain fair and deliver on the intent of these programs.
The current Sustainable Diversion Limits (SDL) include an assumed volume of water will be intercepted in each valley within the Basin region. Removing the Water Rule and allowing uncapped interception of water to occur will have valley wide ramifications throughout the Basin regions – at time when further recovery is likely in many valleys and when sensible regulations like Floodplain Harvesting regulations in New South Wales keep getting disallowed. Once a valley exceeds its SDL water allocations cease. Allowing one industry potentially uncapped access to water without the requirement of an entitlement or being subjected to the allocation system could have significant effects on the availability of water to all downstream users. If plantings are having no material impact on water availability, then they should proceed. Removal of the Water Rule would mean that these plantings could have a material effect, which would go against the Initiative and Plan, and adversely impact other water users who have to pay for water and have to follow the rules.
The decision to remove the Water Rule and benefit the forestry industry and potentially cost the irrigation industry and all other downstream water users seems particularly strange in today’s climate of tightening water availability and further water recovery.
Any attempt by the Government to recover water from one user group, while giving others free access would show contempt for the irrigation sector and their communities and would show that Government is not concerned with actual outcomes of water reform. The NIC opposes the proposed changes to the Water Rule due to the impacts that changing the rule will have on all other downstream water users. It opposes the removal of the rule because it seems to play favourites with one industry over others, including those in the irrigation sector which would have similar carbon credentials as the forestry sector. If this change proceeds other industries, including those in the irrigation sector, should be included under this exemption.
Submitted by:
Isaac Jeffrey
Chief Executive Officer
National Irrigators’ Council
National Press Club | 8/16 National Circuit | Barton ACT 2600
0407 083 890 | ceo@irrigators.org.au | www.irrigators.org.au
Dated:
Thursday 17 November 2022
