The Wentworth Group of Concerned Scientists and the Environmental Defenders Office made the following submission to the Inquiry into the NSW Government’s Management of Floodplain Harvesting.
Summary of issues and recommendations
We have four main concerns related to implementation of the FPH policy that must be addressed if floodplain harvesting in NSW is to comply with State and Commonwealth legislation including water sharing principles, extraction limits, environmental water requirements under the Basin Plan and support water management objectives. These apply to floodplain harvesting in both regulated and unregulated systems.
- Widespread lack of trust in the modelled estimates of extraction limits because of limited data and inability to verify model outcomes including levels of take;
- Higher priority water for environmental and community needs will not be protected under the proposed FPH policy;
- Many floodplain structures will continue to intercept floodplain flows even when extraction is not permitted; and
- There is insufficient evidence to demonstrate that the policy will deliver legally mandated environmental and other downstream outcomes.
In light of these concerns, we suggest that the Committee recommend that the following protections are incorporated into the licencing framework:
- improve confidence in, and implement rigorous estimates of, long-term extraction limits by improving models, the modelling process and using multiple lines of evidence;
- implement flow triggers and other rules to protect high priority flows from being extracted on floodplains, namely basic landholder rights and flows required to protect water sources and dependent ecosystems (as required under s 5(3) of the WM Act);
- ensure floodplain structures do not alter natural flood flows at times when extraction is not permitted; and
- issue only temporary licences until there is clear evidence that extractions are within limits and that legally mandated environmental and other downstream outcomes are being achieved.
Wentworth Group of Concerned Scientists and Environmental Defenders Office