29 October 2021

The Concerned Waterways Alliance (CWA) welcomes the release of the Discussion Draft of the Central and Gippsland SWS. The SWS will be an opportunity to relieve mounting pressures on our stressed rivers and wetlands from consumptive uses, over-extraction and the growing toll of climate change.

The government’s candid acknowledgment of the impacts of climate change on rivers is welcome. Those impacts are already underway and likely to get worse.

We welcome the acknowledgment that rivers cannot give up any more water to meet future demand and the need to diversify our water sources for urban use. That recognition must be translated into action through the SWS.

We further welcome the focus on discussion and invitation for community input. We intend our suggestions to strengthen the outcomes achieved in the final strategy.

It is not clear to us that the proposals set out in the Discussion Draft will be sufficient to halt the decline in health experienced by the rivers and wetlands of the region, address historic over-allocation of water for consumptive use, and establish viable buffers for resilience of water ecosystems, landscapes and Country across southern Victoria in the face of climate change.

The underpinning strategy presently proposed for water management across southern Victoria might be summed up as including certain, minimal water recovery targets for flow-stressed rivers highly contingent on somewhat indeterminate actions to increase water supply for urban areas and irrigated agriculture. Water supply interventions proposed for urban areas and irrigation include increased water efficiency, greater use of stormwater and recycled water, and desalination, but these are not quantified.

The diversification of water supply (or substitution from very high reliance on natural surface and groundwater sources) is welcome and, in our view, necessary and inevitable.

However, in addition to being contingent, water recovery targets for rivers appear to be set at minimum levels to avoid cease to flow events, but not sufficient to maintain or improve ecological health and functioning.

The strategy must be based on sound science and its actions be transparent and in the public interest. Water corporations and other authorities must be accountable for their role in implementing the strategy, in particular in sourcing alternative supplies so that rivers can be allowed to be rivers.

We fear that the strategy will not address the desiccation of the landscape due to climate change and existing rates of over-extraction of water in many systems. Water needs to be kept, at appropriate volumes and of sufficient quality, in natural and cultural landscapes to enable resilience and to avoid ecosystem degradation tipping points that will lead to collapse.

We offer the following initial response to the Discussion Draft. A more detailed analysis will follow in November, along with comments about specific rivers.

1. The fundamental framing of the draft strategy appears to be that if we create more ’manufactured’ water supply to meet urban needs, then all other needs can be met even under conditions of reduced water availability due to climate change. The fact that rivers have already lost an average of 20% of their water to climate change is acknowledged. It does not seem to feature in the response. Any water recovery for rivers is already playing catch up to climate change. Climate change is, in effect, a human driver of loss of environmental water in water systems. This compounds existing impacts from over-allocation for consumptive use and the precarious state of many rivers and wetlands. Recovery targets should be designed to reduce extractions to a long-term sustainable level to protect rivers and the water resource. They should not be contingent on future water supply options for towns and agriculture.
   
2. The scientific basis for environmental water recovery targets is not clear. They seem to be set through a combination of minimum flows to avoid cease to flow events, targeted protection of certain iconic species, an assessment of possible urban water supply options, and the level of community campaigning for increased flows. For example, the only river for which there is a dedicated action to meet a water recovery target is the Moorabool, where the desperate need for more water has been the subject of a strong community campaign by PALM. Targets for other rivers are more vague and/or qualified (often expressed as ‘up to [an amount]’) and contingent on as yet undecided actions to increase urban supply. Rivers cannot remain on long-term life support, which seems to be what the discussion draft is proposing. They need to get out of the ICU. Pathways for return to health need to be committed to.
   
3. Water recovery targets should be based on foundational conditions for waterway health. These include targets sufficient to provide lateral connectivity to wetlands and floodplains as well as maintaining water in the river channel. A river without connection to its floodplain is like a body without kidneys and lungs. The river ceases to function as an integrated, living being. Floodplain integrity is fundamental to ecological function. It is also essential to resilience and buffers in the face of climate change. This is part of ‘letting rivers be rivers’.
   
4. While we note commitment to substitution of new forms of urban water supply for river water, the draft strategy rules out other methods of water recovery. It specifically excludes water buybacks from licence-holders, targeted or strategic qualification of water rights in stressed systems, or action on farm dams or other forms of interception other than monitoring and information gathering. Irrigated agriculture is not being asked to make any changes – and, indeed, it is proposed for marginal expansion – other than potential gains in irrigation efficiency which will be taxpayer-funded. The crisis facing our rivers demands that all water recovery and restructuring options are on the table, not just urban water supply and uncertain outcomes for rivers.
   
5. The discussion draft has some glaring gaps. In many ways it is a ‘plan for a plan’. We accept there is further work to do on settling this strategic water-planning framework for the next decade. However, there are very substantial ‘unknowns’, including a Water Supply Readiness Roadmap, the Greater Melbourne Urban Water and System strategy, catchment scale Integrated Water Management plans and the Statewide Groundwater Strategy. There is no reference to recommendations of the Barwon or the Waterways of the West Ministerial Advisory Committees or the government’s response to these recommendations. All these strategies and plans have a significant relationship to the SWS. The lack of detail on a Water Supply Readiness Roadmap is particularly troubling as so many of the water recovery targets for rivers are contingent on water supply options. There needs to be a thorough assessment of options: for example, does it make sense to pump desalinated water all the way from Wonthaggi to Geelong, or would it be more effective for Geelong to have its own desalination plant and use Wonthaggi to meet Melbourne’s needs?
   
6. The discussion on unallocated water assumes that existing caps are set at appropriate levels, are scientifically informed and justifiable, and that environment and Country will be protected by those caps. Identification of ‘unallocated water’ assumes environmental outcomes are fully or sufficiently accounted for. Not only, as the discussion draft points out, is this ‘above cap’ water uniquely vulnerable to climate change and the first water to be lost in times of shortage, the scientific basis for this water management tool (‘caps’ and ‘unallocated’ water in excess of them) is at best opaque. Diversion limits and ‘caps’ in all water systems need review and reform. To make sense of these contradictions and in order to take a precautionary approach to river and wetland health, we propose a moratorium on all new extractions. All water presently identified as ‘unallocated’ should be transferred to the environment and to Traditional Owners, to protect river health and Country. Review and reform of the governance of diversion limits and ‘caps’ should be a priority under this SWS.
   
7. We warmly welcome the discussion draft’s emphasis on Traditional Owner water needs. That focus must be backed up with action. The only firm proposal is to transfer Amcor’s unused entitlement on the Yarra to the Wurrundjeri. Decommissioning of the Latrobe Valley power stations opens up significant opportunities for transfers to the environment and to Traditional Owners. We believe that outcomes for the environment and Traditional Owners should be locked into the SWS first and these used to drive the diversification of water supplies for cities and agriculture, not the other way round as the discussion draft proposes.
   
8. There is limited attention to water quality in the discussion draft. The SWS is required to identify threats, and ways of responding to threats, facing water quality as well as quantity and reliability. While tackling pollution loads from agriculture into the Gippsland Lakes is included in the discussion draft, there are other major existing and emerging sources of water quality degradation that are not, such as risks and harms from current and proposed mining operations. Both water quality issues and stormwater management indicate the imperative of regulatory responses across government (water combined with pollution control and water combined with planning controls) and avoidance of silo-ed action. For example, stormwater management and Integrated Water Management need to be brought together to address the impacts of urban stream syndrome in catchments such as the Merri Creek.
   
9. Design and delivery of a 10-year outcome for sustainable water management in southern Victoria, which this SWS must drive, cannot be done without squarely considering economic dimensions, incentives and disincentives. In particular, the SWS will need to contend with water pricing, subsidies, and reforming how we set values for water. This discussion is not anticipated in the present draft. Not only does pricing and expenditure need to be on the agenda in order to drive changes anticipated (whether those indicated in this draft or others that may eventually be adopted) but it is basic premise of ‘sustainability’ that environmental costs and benefits are internalized in economic settings. The foreshadowing of economic tools is achieving sustainable outcomes needs to be included in the discussion going forward.
   
10. In the longer term, we need significant reform on how rivers are provided with a fair share of their own water and how caps on extraction are set to protect environmental values and the sustainability of the resource. We need to pay more attention to principles of precaution, intergenerational equity, and the conservation of biodiversity and maintenance of ecological integrity. We need to shift our focus from ‘water as an essential service’, as described in the discussion draft, to ‘water is life’. It may be that this SWS is a framing document for transformation. However, as strategy, it must lay down targeted and effective action, directed to clear goals and objectives (SMART planning). There will be trade-offs. That is different from an illusory ‘magic pudding’ where everyone wins. The strategy, fundamentally, must be sustainable in an environmental sense. That is what the law provides for. It is what the needs of our own and our children’s generation require.