AAT response to Draft RWUS

The progression of The Tasmanian Rural Water Use strategy from position paper to draft status has failed to reconcile AAT’s view that the strategy gives inadequate attention to river health and water quality and fails to explicitly address potential adverse impacts from expanding irrigation-based agriculture across the state.

AAT does not believe that in its current form the Tasmanian Rural Water Use Strategy will meet the challenge to “deliver sustainable outcomes for rural water users, rural communities and the environment” and lacks the rigour to “guide Tasmania’s future water management arrangements” in a time of rapid agricultural expansion and changing climate.

As highlighted by others, the strategy appears to be primarily centred on objective b) of the Water Management Act (WMA); that is “the supply of water for hydro-electric generation, and for the supply of water for human consumption and commercial activities dependent on water.”

AAT questions the elevation of “Strategic development to maximise opportunities from freshwater resources” above “Effective regulation, strong entitlements and planning”, between position paper and draft strategy. Seemingly making development more significant than regulation.

As a document to guide future water management practices AAT considers this a missed opportunity to “increase the community’s understanding of aquatic ecosystems” WMA objective e).

Most importantly for anglers, AAT considers the strategy inadequately addresses WMA objective c) in failing to ensure we “maintain ecological processes and genetic diversity for aquatic and riparian ecosystems”.

Many of AAT reservations are elaborated by other stakeholders, principally that the scope of the strategy limits consideration of matters inextricably linked to water management.

Such constraints preclude a holistic, catchment wide, management approach proffered by many informed science-based responders. This also ignores the cumulative impacts of extraction and landuse change across systems.

Failure to consider water quality in detail, the detrimental impacts of dams on stream flow and harmful land use practices within a water management strategy “doesn’t pass the pub test”.

Goal 1 – Sustainable management of Tasmania’s water resources:

1.1  Information and tools to address changing climate

AAT endorses the RWUS intent to address the challenges of a changing climate but seeks a more precautionary approach and supports increasing research to address an accepted lack of understanding of ecosystem impacts and resilience.

1.3 and 1.6 Environmental Assessments and River Health Monitoring

The importance of environmental assessment cannot be overstated.

Disappointingly, as raised by numerous responders, government commitment to such assessment has been lacking.

As noted by the Tasmanian Independent Science Council:

The National Water Initiative (NWI) made funding available for monitoring of flow, water quality and broader river health. However, this support has eroded over the past 10 years, with fewer sites now monitored and at decreasing frequencies.

The Monitoring River Health program should provide important insight into waterway conditions and trends. A review paper was prepared for this program two years ago, However, the full paper has not yet been released. Accordingly, we request that this paper be released as part of the RWUS process.

An updated State of Rivers report is long overdue for Tasmania – the last one dates back to 2008.

The Australian Freshwater Sciences Society states:

“the Conservation of Freshwater Ecosystem Values (CFEV) data base is now very dated and its revision and upgrading is well overdue.”

And from The Environment Defenders Office:

 “Vital aspects of the State Policy on Water Quality Management 1997 SPWQM have not been fully implemented”

The E.P.A. board is yet to identify water quality objectives as required under clause 11.

Such objectives, industry best practice guidelines and codes of practice are designed to avoid impacts considered offences under Environment Management and Pollution Control Act 1994.

The National Water Reform Productivity Commission Inquiry Report no. 87 Dec 2017 noted Tas gov failed to implement provisions within Tasmania’s commitment to NWI National water initiative, to assess ecological sustainability… with respect to irrigation proposals.

Despite statutory requirements that the state of the Environment Report be published every 5 years it was last published by the Tasmanian Planning Commission 11 years ago”

Hence AAT has little confidence in an assurance to “continue to undertake…..” such vital assessments.

AAT strongly supports the Tasmanian Independent Science Council request that “this paper (The Monitoring River Health report) be released as part of the RWUS process” and that its recommendations be addressed.

And further, that as suggested by the E.D.O., required Water Quality Objectives (under the SPWQM) be identified and factored into WMA decisions and hence the RWUS.

As stated in our initial response:

“AAT seeks ongoing extension and broadening of the River Health Monitoring Program.”

The request for improved monitoring is supported by numerous stakeholders who repeatedly call for broader monitoring parameters, greater frequency, and more sample sites. (The Australian Freshwater Sciences Society, Tas institute of Agriculture, Trout Guides and lodges, Cradle Coast NRM, Derwent Catchment Project, Derwent Estuary Program, Tas Independent Science Council, Environment Defenders Office, plus concerned individuals.)

Justification for greater resourcing of such monitoring is outlined within detailed responses to the position paper.

Several stakeholders back angler observations sent to A.A.T. from around the state, that the health of their local rivers is declining, many suggesting water management strategies are at fault.

The River Basin Management Society cites evidence from aquatic invertebrate sampling and IFS has supported requests from anglers to study North West rivers due to declining wild trout recruitment and in stream populations. The Trout Guides Association gives examples of rivers which no longer provide positive experiences for their clients.

Local councils, TasWater and oyster growers refer to cost transfers to their industry or jurisdiction through poor water management. TasWater specifically cites water quality and the addition costs transferred to households to ensure quality drinking water.

 LGAT believes:

“That the State Government to (sic) take greater responsibility for the management of streams.”

Successive State Governments have reduced the resources applied to the overall management of streams (rivers etc) and increasingly relied upon Local Government to take responsibility to address stream management issues as they arise and to play the lead role on addressing problem areas and locations.”

TasWater proposed amendments to the scope of the strategy, calling for:

Consideration of the potential impact increased agricultural production may have on water quality and the adoption of water quality objectives that protect all water users including drinking water.

And further Proposed amendments with respect to goal 1 to provide:

Inclusion of a (sic) consideration of the water quality needs for urban drinking water and the adoption of appropriate water quality objectives that protect all water users

AAT is intent on supporting citizen science to facilitate broader stream monitoring.

Currently AAT is collaborating with Waterbug Blitz to establish a network of Waterbug samplers based on fishing clubs around the state. The intent is broaden sampling, increase awareness and have authenticated data provide an easily understood picture of stream health. 

1.7 Water Accountability and Reporting

A.A.T. remains strongly supportive of strengthened measurement and reporting of water extraction and conveyance proposed within the draft.

Few who spend time on our rivers have faith in the current risk-based compliance model, as evidenced by numerous stakeholders calling for mandatory metering, tamperproof meters, compliance officers in the field, even public disclosure of compliance breeches.

The River Basin Management Society’s submission points to figures undermining department claims of a good understanding of water usage across the state.

The 2018/19 DPIPWE Annual Report states allocation to irrigation is 837,000 ML, while the BOM Water Resources estimate is 3,553, 919 ML

The significant discrepancy supports the identified actions in the RWUS Position Paper regarding reporting and management of water resource information.

Such contradictions, anecdotal reports from disgruntled farmers and anglers, and repeated stories of water theft in the Murray Darling in the media, have severely undermined public confidence in accountability and question the appropriateness of allocations.

Hence AAT support for proposals to strengthen water accountability.

AAT believes a roll out of meters, principally to large volume extractions, then becoming more widespread, would not only allay public scepticism but better inform water managers through measured rather than estimated and “honesty reliant” data.

AAT also welcomes improved transparent water resource and water allocation information being made available. DPIPWE’s recent addition of dam permits and water licences into LISTmap, is a positive step towards rebuilding public understanding and trust.

AAT notes several references by stakeholders for the need for “feet on the ground” and the general dissatisfaction of a centralised risk-based model and calls for resourcing to match growth in irrigation and extraction volumes. It is apparent that compliance officers have insufficient time or resources to adequately complete the range of tasks for which they are responsible.

GOAL 3 Effective regulation, strong entitlements and planning 

3.1 3.3 Deliver outcomes in line with the Water Management Act 1999 and Greater visibility of allocations, water availability and limits in catchments

AAT strongly supports the draft proposition to use best available science to Deliver outcomes in line with the Water Management Act (WMA.)

As stated in our introductory overview AAT recognises strong intent within the draft to address WMA objective b)

“the supply of water for hydro-electric generation, and for the supply of water for human consumption and commercial activities dependent on water.”

AAT deems it imperative that resourcing be ensured to provide ample monitoring to deliver the “best science” to inform this strategy and ensure it meets obligations to WMA objective c) to “maintain ecological processes and genetic diversity for aquatic and riparian ecosystems”.

The recommendation for better access to information is strongly supported.

AAT believes greater availability of environmental monitoring data will “increase the community’s understanding of aquatic ecosystems” WMA objective e).

Improved transparency and visibility in both allocations and decision making will address community lack of confidence in water management planning.

Water management plans.

The value of such plans was alluded to by several responders. WMP’s are seen as; transparent, scientifically rigorous, community supported frameworks for managing a catchment’s water resources in accordance with the objectives of the Water Management Act 1999, and the State Policy on Water Quality Management 1997.

AAT supports the Independent Science Council’s call for comprehensive statutory management plans for Tasmanian rivers. It was disappointing to discover that the majority of Tasmanian river catchments are without such plans and therefore AAT agrees that the current tally of 14 WMPs be expanded.

In light of rapidly changing rainfall and evaporation patterns AAT recognises the importance of reviewing and updating WMPs to cater for such change and gauge their effectiveness.

AAT shares the concerns of both the Independent Science Council and Oyster Growers where the Rural Water Use Strategy position paper recommends the development of water management statements rather than statutory water management plans.

Although considered outside the scope of the strategy the issue of dams was raised by numerous stakeholders.

AAT fully concurs with the Tasmanian Independent Science Council that:

Catchment dams should be included in the broader water management system, particularly with respect to cumulative impacts at the catchment scale. The perception in the RWUS paper seems to be that the current unregulated approach is adequate. We recommend that this issue be given more detailed review, assessment and management, particular where dams are large and/or numerous.

The same point is made by the Tasmanian Conservation Trust:

The TCT shares the concerns raised by stakeholders that the dam assessment process is too limited especially as it fails to take into account cumulative impacts of dams on water flows and aquatic species and the indirect impacts from increased access to water e.g. increased land clearing and increased intensity of land use which increases sediment inputs to rivers. This is a key reason for a catchment management approach that incorporates assessment of all impacts to river systems from all major water users.

It is thus appropriate for AAT to reiterate angler concerns regarding off stream storage and conveyance of irrigation allocations via waterways.

Whilst AAT sees the value in opportunistic take, this must be strictly within guidelines which protect the environmental benefits of high flow periods and the seasonality of river systems.

The potential impact of water conveyance on the health of Tasmanian waterways has gone unrecognised. From turbidity and sediment loads through temperature and low dissolved O2 levels to transference of pests or diseases, inadequate assessment and monitoring of waters released into streams is undertaken.

AAT considers a reactionary model to address environmental degradation is not acceptable in 2020. (i.e. Hefford’s Rd Fingal, sediment contamination of the South Esk from off-stream storage)

Conclusion

In this document repeated references have been made to the responses of eminent scientific bodies to the RWUS position Paper. Many of the issues mentioned by such respected independent groups validate the concerns raised by anglers regarding the failure of existing, and indeed proposed, management practices to protect Tasmanian waterways.

The strident responses and documented examples from many individuals indicate widespread dissatisfaction with bodies responsible for planning and those tasked to ensure compliance with guidelines and regulations.

Within responses there was an undeniable call for the RWUS to recognise values beyond those of economic development.

ü  To provide habitat for Tasmania’s unique native species.

ü  To provide safe drinking water.

ü  Provide for social, spiritual and cultural use.

ü  Our waterways have undeniable aesthetic value, especially to a state so heavily dependent on tourism

ü  Our waterways should be safe to swim in, fit for participation in aquatic sports and to wet a line (with the expectation of catching a fish, and be able to eat it if the angler so wishes.)

The objectives of the Water Management Act respect these values are given equal weight.

Many anglers are well travelled and have seen the deleterious effects of injudicious expansion of broad scale agriculture, where sensible environmental checks and balances have been neglected.

Tasmania is in a position to avoid the pitfalls suffered in New Zealand, of adverse impacts on water quality and river health, prompting expensive retrospective “Action For Healthy Waterways” legislation and compliance, which followed a damaging “Dirty Dairy” campaign detrimental to the New Zealand’s export reputation.

Tasmania’s clean, green, pristine image was enhanced by the World Flyfishing Championships held last year, highlighting the value of our rivers and wild fishery. It is vital this strategy seeks to build upon this reputation and ensures Tasmania’s environmental integrity is maintained.

While acknowledging the aim to increase agricultural contributions to the state’s bottom line, we caution against the narrow scope of this strategy.

AAT considers it imperative that greater environmental focus be incorporated into the strategy, and believes, from examining other stakeholder submissions, many other Tasmanians have similar misgivings.

Howard Jones

Executive Member, Anglers Alliance Tasmania