Proposal to Replace the Water Plan (Fitzroy Basin) 2011

1. Water is a vitally important resource and needs to be managed to secure its environmental, social and economic values.
2. To sustain access and associated ecosystems, planning and management should avoid risks to the long-term sustainability of water resources.
3. AgForce supports the cost-effective use of objective, scientific information to guide water resource management decisions, including the release of unallocated water.
4. The water resource planning process in Queensland is supported as it sets up a system of entitlement security, enables tradability and is designed to plan for sustainable management to meet future consumptive and environmental water requirements.
5. Where water resources are at risk of over-use, there may be a need to manage demand through the use of targeted regulation (noting the primacy of basic stock and domestic (S&D) rights and that planning and management decisions should be transparent, efficient and equitable).
6. Access to available water for S&D purposes is a basic landholder right with intrinsic volume limits related to land capability and should be prioritised over other competing consumptive uses.
7. Support making further water available for economic development in a responsible and sustainable way where this does not reduce the certainty, security and reliability of current entitlements, or increases the risk of adverse environmental impacts.

• In past Fitzroy WP processes, multi-interest stakeholder advisory groups were formed to discuss issues together in person and this style of engagement approach would be supported again, such as in the draft WP review phase – agriculture, resources, energy, environmental, local government, etc.  Meeting face to face to present the draft plan to affected irrigators is also supported.
• It would have been preferable for water user certainty and given a range of issues exist, if this renewal process was commenced earlier without the need to extend the plan by a further 3 years. This will be exacerbated by the finalising by the Department of Environment and Science (DES) of the model and its subsequent population with robust data.
• It would be preferable if the draft WP is released alongside the supporting protocols and documents so that the best understanding of how issues will be addressed can be developed by affected stakeholders and so that feedback on the draft WP is fully informed and with sufficient time to enable full consultation.

• Given the level of connectedness between the ground and surface water resources in the area, opportunities around the bringing together of surface and groundwater entitlements.
• Ensuring the Department’s key indicator bore network reflects the local conditions and actual operation of the aquifer, particularly in Zone 4, and enabling network bores with telemetry to support more timely irrigator decision-making.
• Ensuring effective and responsive engagement with the Association and local irrigators prior to the setting of announced annual entitlements and increased transparency on the decision-making process concerning the AEs and its potential inclusion in the Protocol.
• Improving seasonal transfer rules for surface water, such as current zone restrictions and enabling irrigators with more than 160 ML allocations to be able to voluntarily transfer their entire allocation (eg, Zone 5 to Zone 4), but some protective provisions such as limiting to 160 ML lots as per current rules.  Carry-over provisions could also be reviewed in light of any new knowledge about the aquifer.
• Revisiting the area to volume conversion process (without disadvantaging other users) to ensure it is fair and operating effectively – the Association reports that the 4ML per hectare area Part B allocation has not been able to be accessed and this should be addressed.

• It would deliver benefits if the process for temporary trade of ground or unsupplemented water was simpler, more efficient and cheaper (currently $188.60 charge but could be free or much reduced if automated as proposed).
• The conversion of licenses (including area-based) to tradeable volumetric entitlements in the tributaries should be enabled where third party impacts can be avoided. Further, water user concerns remain about the application of an arbitrary 6 ML/ha conversion factor across the state, despite historical use rates often being greater.

• Review of the trading zones within each river catchment and unless there is a negative risk to current entitlements or adverse environmental impacts, allow trading to occur throughout the catchment (with appropriate conversion factors as required) and not between defined zones.  Ultimately this approach will not change the relative take at the end of the system but will allow water to be more productively and sustainably taken.

• Earlier iterations of the Fitzroy WP had greater levels of medium priority reserves, such as on the Dawson River, but these volumes have been reduced each plan.  We would support the government looking at unallocated reserve volumes and maximising their availability for agricultural consumptive use, including the release of high priority volumes as a greater amount of medium priority water.
• We would support the government investing to improve the understanding of the water resource through improved data and modelling so that further opportunities (primarily at a local level) can be identified and enabled.  For example, AgForce members have identified situations where assessments could occur of self-contained lagoon systems (within property impacts only) or where high flows from a river overbank into anabranches from which water could subsequently be taken after the river flow falls, and the downstream river connection ceases.    
• We support the government releasing the Expert Panel’s report into the Bradfield and like schemes and considering the findings of CSIRO research to inform the treatment of future infrastructure proposals in the WP area.
• Recognising the need for extensive studies to identify the most promising candidate projects within a region and the whole state, there is an opportunity cost in holding back reserves of water for yet to be constructed infrastructure.  In a sense the government is the largest holder of under-utilised water under these circumstances.  AgForce has supported the temporary release of SWIR water and the recent pilot study has clearly demonstrated the underlying demand and the benefits of such initiatives. Increasing the certainty/longevity of access to those reserves held against very large, long time frame projects should be examined as it increases financier preparedness to invest, as well as progressing other opportunities in the WP area for similar SWIR releases and increased certainty within the process of release.
• AgForce would also support working through enabling smaller infrastructure projects like weirs and off-stream storages to occur in the Plan area where a viable opportunity presents.     

1. Conditions under which water may be taken (clear with the 15 & 30 cumec flow conditions)
2. Water taking capacity of pump under normal operating conditions (pump curves clearly show an increased flow capacity)
3. Irrigation or water distribution system related to pump for past 10 years (water harvesting claim forms submitted over this period have all indicated a higher rate of daily take)
4. Efficiency of water use (minimal seepage losses from storages and ability to efficiently pump this water on to crops can be proven).

• Dawson Carryover – both the length of time and volume allowed to be carried over in the Dawson needs to be increased. This would have significant positive impacts on the environment given that irrigators would leave water in the system longer if they knew they were not going to lose it at the end of the water year. Current spill conditions would also ensure that new season allocations are not impacted
• Dawson – Orange Creek Weir – usable volumes held in this Weir need to be included in the announced allocation process
• Dawson – Moura Offstream Storage – restrictions to filling this storage need to be completely removed so that Sunwater can efficiently operate this storage similar to every other storage on the system
• Dawson – disparities exist with existing Medium A and Medium allocation holders, under the WP both have the same monthly supplemented water sharing index of 82% but in the Operations Manual preference is given to Medium A with a 20% differential at the start of the year. 

1. AgForce supports stakeholder consultation in water resource planning and management, including that of Indigenous peoples.
2. AgForce supports the provision of water for Indigenous use, but only where this does not result in third party impacts to existing entitlement holders, including the environment.
3. AgForce supports the use of existing held and planned environmental water entitlements for the co-benefit of Indigenous cultural water use.
4. AgForce supports the use of existing market mechanisms to acquire Indigenous water entitlements from willing sellers for contemporary economic use.
5. Allocation of water within unallocated reserves (including strategic, general and Indigenous) should be equitable across stakeholder groups and with a consistent methodology that is applied across the state.
6. AgForce acknowledges that the ownership framework for Indigenous water entitlements for contemporary economic use is a matter for governments and Indigenous peoples however, additional restrictions to Indigenous entitlements that unnecessarily constrain trading should be removed
7. If the above framework were adopted, the current hierarchy and security of water entitlements, as enshrined in state legislation, would be respected and therefore unaffected.