Letter from the Chair Craig Knowles to environmental groups

Date: 21 October 2011

To: Environmental non-governmental organisations

RE: Environment NGOs response to MDBA briefing on 4 October 2011

Thank you for your letter of 5 October outlining the concerns of Environment NGOs relating to the current thinking on the draft Basin Plan.

In your letter you suggest that the Environmentally Sustainable Level of Take (ESLT) should be developed by consideration of environmental science alone – I do not agree. The Murray-Darling Basin has been developed over the past century, and as a result the basin is now highly modified by infrastructure such as water storages and weirs. These structures, by their very nature, place limits on our ability to generate the type of flow regimes needed by the environment, and consequently on our ability to deliver water to parts of the floodplain, particularly those areas distant from the river channel. In my view the Authority cannot ignore these system constraints in determining the ESLT. Similarly, the Authority cannot ignore the need to work within the current entitlement regimes that apply to water in the Basin, the current rules for river management, or the impacts on the social and economic fabric of the basin that the ESLT will have, both in the short and long term. All these factors contribute to the long-term sustainability of the basin, and need to be considered.

That said we believe that we have brought best available science to bear in determining the ESLT. As you will be aware the underpinning methods were peer-reviewed in 2010, and these reviews are available on our website. However, the Authority is aware that there has been a significant body of further work undertaken since these reviews and the release of the Guide. For that very reason, in June 2011 the Authority invited CSIRO to lead a review of the hydrological indicator site method. This review will be completed in late October, and draws on expertise in the ecological and hydrological sciences both within and outside of CSIRO. The panel members are Dr Bill Young (CSIRO, Water for a healthy Country Flagship), Professor Gary Jones (eWater CRC), Dr Ben Gawne (La Trobe University/Murray Darling Freshwater Research Centre), Dr Nick Bond (Griffith University) and Dr Justin Brookes (University of Adelaide). I can assure you that the review will be published to assure everyone that the Authority has drawn upon best available science in determining the ESLT.

I note your comment that a number of scientific studies have concluded that different volumes of water are required to achieve an ESLT. This is not unusual in a situation where there are clearly many different interpretations of what constitutes the ESLT; as well as significant gaps in underpinning information, models, and scientific methods.  However, I would suggest that delivering good environmental outcomes in the basin deserves and requires more than a debate about a volume of water.

The Authority believe that good environmental outcomes for the basin also requires consideration of environmental works and measures, river management rules that balance environmental and consumptive outcomes, the most effective and efficient use of all environmental water, an active water market to allow the movement of water to its most productive use whether economic or environmental, complementary natural resources management actions, and efforts that place local communities and their knowledge at the heart of enduring solutions. It is within this context that the Authority is developing the draft Basin Plan, and as a result we believe that our current thinking represents a balanced proposal that has the potential to deliver the best possible outcomes for the basin as a whole.

As you are aware the Authority is proposing that the Basin Plan will be progressively implemented over the period 2012 to 2019. This will give communities time to adjust, it will give time for water recovery measures to reach fruition, and it will give time to explore the potential contribution of complementary issues such as environmental works and measures and river management rules. At the same time the Authority is committed to rigorous monitoring and evaluation of environmental watering to ensure that it delivers the greatest possible benefits across the basin. We will use all this information to review the Sustainable Diversion Limits (SDLs) in 2015, and if necessary we will propose amendments to the Basin Plan. There is also a legislative requirement to review the Environmental Watering Plan, the Water Quality and Salinity Management Plan, and the social and economic impact of the Basin Plan. The findings of all these reviews will feed into a possible amendment of the Basin Plan by 2017 such that the foundations are set for the next generation of state water resource plans that will enforce the SDLs from 2019.

These are elements of our adaptive management approach, but we are keen to seek further input from communities and stakeholders during the 20 week public consultation period. This will ensure that we can present the best possible plan to the Minister in 2012 for adoption, that combines the right balance between consumptive and environmental use of water on the one hand, and between prescriptive detail and adaptive management on the other.  If we can all achieve this together I believe we will deliver a strategic enabling framework that will sustain the basin for generations to come.

I look forward to continuing to work with the Environment NGOs to achieve this goal.

Yours sincerely

Craig Knowles
Chair