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Corporatisation of the Snowy Mountains Hydro-electric Authority
Draft Environmental Impact Statement

A Picture Tells a Thousand Words

 -
The Snowy River

A submission by Craig Ingram MP
 Member for Gippsland East
Parliament of Victoria

 Wednesday, 26 July 2000

Summary 

The Snowy Hydro Environmental Impact Statement has failed in its goal to deliver a document that will provide all the relevant information to the decision-makers who will decide the future health of the rivers affected by the Scheme. Information is used selectively to overstate the environmental problems of the Murray-Darling Basin when compared to the Snowy River. Key facts, which show that the impacts to the Murray-Darling Basin will be minimal as a consequence of diversions to the Snowy, are buried in the detail of the document.  The EIS provides no evidence that diversion of flows equivalent to 28 % annual natural flow to the Snowy will have adverse environmental impacts on the Murray-Darling Basin. 

I. Introduction

The Draft Environmental Impact Statement on the proposed corporatisation of the Snowy Mountains Hydro-electric Authority was directed by Senator Hill in January, 2000.  The purpose was to ensure that "all governments and stakeholders are properly informed to ensure the best possible outcome in the national interest." (Hill, 2000).

Firstly, I do not believe that this EIS was needed for Governments to make the required decisions on potential changes in water flows associated with corporatisation. Secondly, it is my strong view that fair guidelines should have allowed a broader focus to consider the environmental status and potential impacts on the Snowy River.

From the outset Senator Hill’s guidelines ensured that this EIS would be a “MDB-centric” assessment of the potential environmental impacts of corporatisation of the Snowy Hydro Scheme. 

The draft EIS is presented in a way that is heavily biased toward the Murray-Darling Basin, as follows: 

• Most information is presented about, and in the interests of, the MDB.

• The potential impacts to the MDB, both economic and environmental, are exaggerated, while the problems of the Snowy are played down.

•  In some instances the details about the current problems in the MDB are left unexplained, leaving the reader to contemplate the worst-case scenario for the MDB.

•  Key statements, which show that impacts to the MDB will be minimal, are buried in the detail of the document, while any potential adverse impacts to the MDB are highlighted, without quantitative or substantive support.

On behalf of the people of East Gippsland and from the perspective of the Snowy River, the aim of this submission is to give some much-needed balance to the EIS. A selection of the key issues addressed in the EIS form the basis of the submission.

II. The suggested approach in the draft EIS will fail unless the decisions on environmental flow allocations are made up-front and binding.

The suggested implementation approach in the draft EIS is for restoration of flow to the Snowy in three broad stages (up to 6 % ANF, up to 15 % ANF, up to 28 % ANF), where the progression to each stage would be "subject to the willingness of governments and taxpayers generally to fund an increased level of environmental releases." (section 24.2.1)

I reject this approach - Governments will procrastinate where future requirements for environmental flows are too vague or seem negotiable. Decisions on environmental flow targets must be made binding and must be written into the Snowy Water Licence (Figure 1).

In the past, failure to recognise the environment as a legitimate user of water, including the recognition of the environment in legislation, has resulted in poor outcomes for the environment. Ecological and biological conservation in water systems has often relied on "what's left over" after the consumptive requirements have been met. It is for this reason that the National Principles on the Provision of Water for Ecosystems (ARMCANZ and ANZECC, 1996) require that:

"Environmental water provisions should be legally recognised."

Managers need clear direction on providing water for the environment.

Governments have stalled for long enough on implementing their own policies and principles on water reform. The 1994 COAG Water Resources Policy requires:

“In cases where river systems have been overallocated, or are deemed to be stressed, arrangements will be instituted and substantial progress made by 1998 to provide a better balance in water resource use including appropriate allocations to the environment in order to enhance/restore the health of river systems”

When will Governments get serious about restoring river health? The policies and principles are in place - it's time now to implement them. It is not acceptable to make adequate environmental flows an optional extra to be determined at the whim of the Government.

III.  The Snowy Water Inquiry examined the impacts to the West of the Scheme

The reason for the MDB emphasis, according to the EIS guidelines, was that "the Snowy Water Inquiry has addressed many of the environmental issues relevant to the Snowy River", the implication being that there was no consideration of the impacts to the MDB in the Snowy Water Inquiry. This is simply not the case.

The terms of reference for the Snowy Water Inquiry clearly stated that the Inquiry must "for the purposes of reporting on the impacts of the options, address the impacts on areas other than the designated area of the inquiry including the Murray and Murrumbidgee valleys and the State of South Australia" (SWI, 1998).

Robert Webster, the Commissioner to the Snowy Water Inquiry, was careful to explain that the problem of balancing the needs of competing users of water was taken into consideration:

"the only way we could succeed in providing Governments with tangible options was to deal transparently with each of the areas of consideration without any bias towards any particular partisan position or stakeholder viewpoint." (SWI, 1998)

It is deplorable that the EIS has not taken a similar, balanced approach.

IV.  River regulation is a major threat to river health

The EIS identifies river regulation as the "biggest single factor threatening the integrity of both the Murray and Murrumbidgee Rivers" (p. 170). In these rivers seasonal flows are completely out of synch with natural flow cycles, with highest flows in the summer and autumn when irrigation demands are at a peak.

As a consequence of river regulation the EIS points out that:

 "there is little evidence that reduced Scheme releases to the west would have an immediate or significant impact on the current environmental condition of the Basin” (p. 212)

This is an important statement about the overall possibility of impacts of changed flow arrangements and should be highlighted in the summary points at the start of Chapter 15. Instead the “Highlight”, which refers to the likely or potential impacts of changed flows, vaguely states that:

“The potential for reduced diversions from the Snowy Mountains Scheme to contribute to longer term deterioration in environmental conditions within the Basin, in the absence of offsetting water savings, cannot be discounted.”

Such editorial bias exaggerates the possibility of detrimental effects to the Basin without quantitative or substantive support. Decision-makers should be afforded a realistic perspective as they examine the details of the chapter.

There are several references in the draft EIS to environmental problems from excess flows as a consequence of river regulation in the Murray-Darling Basin (e.g. p. 170, p. 180, p. 191). For example, the problems in the upper section of the Murray (Zones 2-3 Hume Dam to Torrumbarry Weir Fig. 14.3) are a consequence of “river regulation as a result of delivering water to irrigators, rather than the effects of low river flow.” (p. 180 EIS).

The draft EIS fails to state the possible benefit to the waterlogged streams if there was less water available from the Snowy.

The EIS should also note the effects of Snowy water on the Swampy Plains and the Tumut Rivers. Negative impacts in these rivers are caused by excess flows, including erosion and water logging.

V.  Threatened and endangered species

The biased analysis in the draft EIS is also demonstrated in the way that it represents the status of threatened species in the Murray-Darling Basin.

Table 15.4 lists over 60 threatened species, representing seven classes of flora and fauna, which live in the Murray-Darling Basin. The EIS fails to provide any information that will assist decision-makers to assess the likely impact that changed flows could have on the listed species. A single explanatory sentence:

"While many of the species listed are some distance from either the Murray or the Murrumbidgee Rivers, they may be impacted by indirect consequences of altered flow, for example if habitat enhancement or degradation of river red gum forests occur."

is clearly inadequate and will leave decision-makers to contemplate the worst-case scenario. Simply because "Commonwealth and State agencies responsible for the compilation of data" have supplied the data and simply because these species inhabit the Murray-Darling Basin does not justify this broad approach. It is nonsense and alarmist to imply that all these threatened species could potentially be adversely affected by changed water flows - this should be clearly stated if the full list is to appear in the EIS.

Even if it was legitimate to list every known threatened species that could possibly be affected by altered flows in the Murray-Darling Basin, then why was the Snowy corridor not given equitable treatment?

VI. Financial costs of restoring environmental flows are exaggerated

Another example of alarmist and biased reporting in the draft EIS is in its summary of the potential costs to taxpayers, the community and the Scheme of implementing environmental flows of up to 28% ANF to the Snowy. The costs are summarised in the main text to present the most expensive scenario (p. 331). The reader must turn to the detail of the text to ascertain the estimated range of costs and the explanations that show that Governments have a choice and would clearly not take the most expensive option. The estimate, for example, that 28% ANF to the Snowy would cause a loss in value of the Scheme of up to $1, 500 million (listed in the summary points, p. 331) assumes that water is sourced from “Above Target” water. The more feasible and cost-effective option, however, would be to source water by reducing assured annual releases, with an estimated cost of between $250 to $400 million. 

The draft EIS recognises that:

"The need for water releases from the Scheme to satisfy irrigation demand may require generation at times which do not maximise revenue." (p. 25)

There is a far greater level of scrutiny in the draft EIS of the potential impacts of Snowy diversions than there is of the potential impacts of modified release rules, termed "relaxation rules", which are designed to better meet irrigators needs in the MDB. The potential environmental impacts of the relaxation rules are not discussed and the financial impacts require "further work …which will enable the impact to be more accurately determined" (p. 106)

VII. Salinity impacts

Diversion of water back to the Snowy will NOT make South Australia’s water undrinkable!

Salinity is the most serious environmental problem facing the Murray-Darling Basin and, in particular, the Salinity Audit (MDB Ministerial Council, 1999) was a key motivation for this EIS (Nick Minchin, 2000).

The draft EIS fails to provide a thorough and transparent evaluation of salinity impacts on the Murray-Darling Basin as a consequence of diversions back to the Snowy. The existing salinity problems in the Murray-Darling Basin are reviewed in considerable detail in the Draft EIS (Chapter 16), but the evaluation of salinity impacts as a result of changed flow conditions is reduced to one or two vague sentences. As a consequence, the description of the current salinity problems in the Basin detracts from the facts about the likely impacts of water diversions, which modelling has shown will be minimal, and there may even be some benefits.

The EIS reports that recent modelling undertaken by the MDBC has supported the modelling undertaken in the Snowy Water Inquiry, hence, a conclusion of the Inquiry that "salinity considerations related to any of the options are not a critical issue” is also supported.  The draft EIS does not provide sufficient details and implications of the recent salinity impact models, or a summary of the salinity impacts identified in the Snowy Water Inquiry. This information should be available in the EIS, particularly given the importance of river salinity and the controversy that has focused on the impacts of restoring flows to the Snowy in the past (e.g. The Australian, 21/12/199, 22/12/1999).

Figure 2 shows some predictions of salinity modelling undertaken in the Snowy Water Inquiry. The Snowy Water Inquiry models predicted that relatively high diversion options (equivalent to approximately 28 % and 40 % ANF) would have a lower salinity impact than smaller diversions (c. 12 % to 23 % ANF options).  The estimated cost of salinity impacts of 28 % and 40 % ANF flow options was predicted to be $1 million. The reduction in salinity impacts may be a consequence of less water being available for irrigation (SWI, 1998), or, as the draft EIS points out:

“…depending on where water savings are located, there may be a reduction in salinity measurements in some areas, which would have a beneficial environmental effect downstream.” (p. 212)

Whatever the case, river salinity is a variable and dynamic phenomenon that is difficult to quantify, especially where the impacts are likely to be small and there is a combined effect of reduced flow and reduced irrigation. Hence, any estimates, particularly where small changes are involved, will be questionable. The EIS fails to mention this when it reports a MDB Commission model prediction of 4 EC units increase in salinity where the flow diversion back to the Snowy was 256 GL, and there were no offsetting water savings (p. 225). 

Arguably, a scenario where there are no offsetting water savings could be interpreted as a “worst-case” scenario, but even this impact is insignificant compared to the projected impacts of dryland and irrigation induced salinity (Figure 3).

Figure 3: Irrigation and dryland projection figures from draft EIS Table 16.2 for 2050 at Morgan (original source MDB Ministerial Council, 1999); Snowy impact estimate (see p. 225 draft EIS and text).

VIII. Solutions to salinity

There is no easy solution to salinity in the Murray-Darling Basin.

The EIS must clearly and specifically state that diluting the Murray and Murrumbidgee Rivers with Snowy water is not a solution to the rising salinity concentrations in these rivers - even if the status quo water allocations are maintained salinity will continue to increase (MDB Ministerial Council, 1999).

To arrest the salinity and land degradation problems in the Murray-Darling Basin will require cultural change in land and water use practices (MDB Ministerial Council, 1999). On the other hand to save the Snowy the remedy is relatively simple, through a combination of adequate environmental flows and catchment management works. This point is not clearly made in the EIS.

The draft EIS mentions, in passing, the Prime Minister’s Science and Engineering Council report (1996), which recognised that the Murray-Darling Basin:

"is an incompatible setting for large scale European-style agricultural pursuits, especially irrigation."

Overall, however, the EIS does not pay sufficient consideration to the current growing phase of "on ground" support for water reform, including in segments of the irrigation community. Nor does it fully appreciate the future consequences that changes in land use practices may bring to the debate.

Some examples, taken from press articles on a single day in July this year, demonstrate that the way water resources are used and managed in the Murray-Darling Basin and Australia has become a top media and political issue (Appendix 1).

Referring to the Salinity Audit (MDB Ministerial Council, 1999) the Minister for Agriculture, Fisheries and Forestry noted:

'There will need to be changes to some industry practices if we are to stem the decline in the Basin's infrastructure, biodiversity and precious land and water resources."  (Truss, 1999)

And Mr Beazley has just launched his salinity platform for the next federal election.

It would be unfortunate and irresponsible if decisions affecting the future of the Murray-Darling Basin and the Snowy were made based on out of date perceptions about irrigators' attitudes.

IX.  Greenhouse implications

The draft EIS estimates that restoring environmental flows to 28 % ANF to the Snowy (295 GL), and 100 GL for the Montane and Upper Murrumbidgee Rivers would be equivalent to the permanent clearing of 28, 200 hectares of forest (through loss of power generation capacity by the Snowy Scheme). This figure pales into oblivion when compared to the land clearing statistics in Queensland:

*Source: Government figures leaked to Courier Mail (Queensland), 14/7/2000.

The Snowy is in a gradual state of declining health. With the implementation of Expert Panel recommendations for environmental flows we could expect to improve or at least maintain its ecosystem.

When land is cleared there is only one outcome - destruction.

The Snowy Water Inquiry found that it would be viable to install a small hydro-electricity generator at the Jindabyne Dam wall (flow Options 4-7). This would offset some greenhouse impacts due to the lost generation capacity of the Scheme (SWI, 1998). It is not obvious whether the draft EIS has taken this into consideration.

X.  Notes on options for environmental flows to the Snowy

The EIS explores the impacts of three options for the restoration of flow to the Snowy River below Jindabyne:

·        6 % annual natural flow (ANF) (38 GL) was the volume of water recommended by the SWI that would be needed to maintain the current environmental condition of the Snowy (no restoration would lead to further deterioration of the Snowy).

·        15 % ANF (143 GL) was suggested as the preferred option by the Commissioner to the SWI (but nominating a preferred option was outside the terms of reference of the SWI – see below).

·        28 % ANF (295 GL) approximates the expert panel recommendations for the minimum requirement to achieve acceptable environmental outcomes/benefits for the Snowy River.

Flow options up to the restoration of 40% ANF to the Snowy should be examined in the EIS.

The Snowy Water Inquiry considered options up to the equivalent of 40% ANF diversions to the Snowy. The omission of an assessment of flow diversions greater than the 28% ANF option in the EIS contradicts the approach suggested in the introduction to EIS:

"The provision of environmental flows raises highly complex and sensitive judgements…It is therefore critical that all available information is able to be considered." (EIS p.6).

Moreover, by presenting the 28% option in the draft EIS as the largest option tends to reinforce a false view that this option is an "ambit" claim.

Information on flow impacts for options greater than 28 % will be needed to aid decision-makers when the Snowy Water Licence is under review (e.g. the 5 year review).

It is my strong view that the impacts of the 40% flow option should be scrutinised in the EIS.

The 15 % option for the Snowy is unduly favoured in the draft EIS.

The draft EIS places too much weight on the 15% option on the basis that it was the “preferred option” of the Snowy Water Inquiry (Chapter 10 EIS, 10.2.7).

The terms of reference of the Snowy Water Inquiry required that it provide the NSW and Victorian Governments with “a range of comprehensive, fully costed options”. The Commissioner admitted that he went "further than the requirements laid down in the Terms of Reference" when he nominated a preferred composite option (including the 15% flow regime) for Governments to consider (SWI, 1988). The Commissioner’s choice was plainly influenced by the proposition in the Inquiry that “All allocations to the Snowy River over and above a 15% additional flow would require an offsetting reduction in irrigation diversions.” This was based on a volume of up to 140 GL of efficiency savings that was identified in the Inquiry to offset reduced diversions to the west. 

More information has become available since the Inquiry, and attitudes are continuously changing as there is a growing realisation and acceptance that certain water uses will not be sustainable in the long-term. The draft EIS does not adequately take this into consideration.

 The statement:

 "Flows in the range of 6 per cent to 15 per cent ANF coincide broadly with current estimates of water savings within State managed rivers and distribution systems" (p. 330)

is out of date and meaningless. It overlooks that there are other savings options apart from those within State managed rivers and distribution systems and appears not to be supported by a new Victorian report, which identifies water savings in the distribution systems in Northern Victoria (see below)

28% ANF is the minimum requirement for environmental flows in the Snowy.

COAG water reform and ARMCANZ/ANZECC water allocation principles recommend that environmental water requirements should be determined on the best scientific information available.

Scientific recommendations concur that the 28 % ANF option is the minimum threshold requirement for environmental flows to the Snowy River, including:

• 1996 Expert Panel (Pendlebury et al., 1996)

• Snowy Water Inquiry Scientific Reference Panel

• Erskine and Tilleard (1997) recommended flows greater than 28 % ANF per annum are need to establish and maintain pools in the lower Snowy (cited in East Gippsland Catchment Management Authority, 1988)

• Since the Snowy Water Inquiry Harris (1999) "strongly recommended" the implementation of the Expert Panel environmental flow recommendations, including the option equivalent to 28% ANF to the Snowy, to ensure the survival of endangered species.

The Snowy Water Inquiry found lower salinity impacts for the 28 % option compared to the 15 % option. The modelling undertaken in the Snowy Water Inquiry found that salinity impacts appeared to improve under “Option 6” (equivalent to c. 28% option) compared to the 15 % option (see Figure 2, above)

At least one of the Scheme's shareholding Governments (Victoria) has committed to the 28% option.

XI.              Notes on water efficiency savings

The Victorian and NSW Governments have agreed to offset diversions to the Snowy using water efficiency savings

The NSW and Victorian Governments have agreed that diversions back to the Snowy will be offset by water efficiency savings with the intention that there will be no net negative impacts on the environment or water users in the Murray-Darling Basin and South Australia:

Although the draft EIS has included, as an attachment, the joint statement between the Victorian and NSW Governments, the proponent appears to be inconsistent in its recognition and acceptance of this agreement.  On one hand, the draft EIS argues:

 "from the premise that as far as possible the provision of environmental flows to the Snowy River should have no adverse consequences for stakeholder interests within the Murray-Darling Basin." (p. 270, EIS).

Yet throughout the report it describes the impacts on irrigators when water is returned to the Snowy without being offset by water efficiency savings.

At one point the draft EIS describes the reduction in flows to the Basin if 28 % ANF is restored to the Snowy as:

 “equivalent to a loss of more than half the total volume of Sydney Harbour each year. A loss of volume of this magnitude is likely to be significant …unless equivalent water savings are identified.”

Statements such as these taken out of the context of the agreement are alarmist and distort what is actually happening in terms of negotiation between Governments. Such distortion leads to unnecessary angst from the water users who could be affected.

Verification of water savings and commitment by Governments to particular projects should alleviate concerns by irrigators that diversions back to the Snowy could adversely affect them.

Water Savings in Distribution Systems (Northern Victoria): the SKM report

A comprehensive report on the “Water Savings in Irrigation Distribution Systems” (Sinclair Knight Merz, 2000) has been published since the draft EIS was released. The final EIS must take into consideration the findings of this study.

The report found that for the period 1988/89 to 1998/99, out of an average annual inflow into distribution systems of 3380 GL, 980 GL (29%) was unaccounted for, or “lost”, in the system in Northern Victoria. The components of losses are itemised in the Table:

Source: Sinclair Knight Merz (2000).

The opportunity to gain verifiable water savings from the identified distribution losses in Northern Victoria is encouraging. The water savings could be made to offset Snowy diversions as well as provide environmental flows for the Murray.

The Victorian Government is assessing projects identified in the SKM report to verify savings and to identify the most cost-effective projects. In a preliminary response to the report the Victorian Government consolidated its commitment to the Snowy:

“The report has provided the first step to enable Victoria to develop a package of works to produce sufficient water savings within Northern Victorian irrigation systems to meet the Government’s commitment to return environmental flows to the Snowy River.”

 Snowy perspective: Victoria’s share of water diversions under the 28 % flow regime is about 74 GL (25% of 295 GL). A 2.2 per cent improvement in the delivery systems in Northern Victoria (from 71 per cent to c. 73 per cent efficiency, based on the figures in SKM, 2000) would supply enough water savings to offset Victoria’s share of the water diversion back to the Snowy. 73 per cent distribution efficiency is a realistic target, considering that channel systems can deliver up to 80 per cent efficiency and piped systems are at least 90 per cent efficient.

 The SKM report did not include savings from "on farm" sources, which is also a potentially important source of water savings.

 Also noteworthy, in the context of water savings are:

• The draft EIS did not indicate that both the Snowy Water Inquiry (1998), 140 GL, and the Bewsher report, 154 GL, provided very conservative estimates of potential water savings.

• Similar scales of water losses are likely to occur in NSW distribution to the losses in Victorian distribution systems, but a detailed study has not yet been undertaken.

• South Australia has significant opportunities to improve water efficiency and gain savings in the lower Murray (e.g. Department of Environment and Natural Resources (S.A.), 2000).

XII.           Conclusion

This so-called Draft EIS is not an environmental impact statement. It does not apply scientific rigour or provide supporting evidence to back up many of the claims it makes on potential impacts. It does not provide Governments with the information necessary to make fully informed decisions. It favours unsustainable agricultural practices in the Murray-Darling Basin and will not deliver ecologically sustainable outcomes to either the Murray-Darling Basin or the Snowy. It will not provide a socially acceptable outcome for the Snowy Hydro-electric Scheme.

References

ARMCANZ and ANZECC (1996). National Principles for the Provision of Water for Ecosystems, Occasional paper SWR No. 3, pp. 14.

Bewsher Consulting Pty Ltd (and Perrens Consultants Pty Ltd) (1999). A review of water efficiency savings available in NSW, NSW Treasury, pp. 22.

Courier Mail, 14/07/2000. Australia: Death by a Thousand Cuts, p.19, Queensland.

Erskine, W.D. and Tilleard, J.W. (1997). Formative processes of alternating bank-attached side bars and associated pool-riffle sequences on sand bed streams similar to the Snowy River at Jarrahmond, Victoria. Dept. Natural Resources and Environment Victoria.

Harris, John H. (1999). Threatened Aquatic Species of the Snowy Hydro Scheme Area. Prepared for Environment Australia, Cooperative Centre for Freshwater Ecology, Canberra.

Hill, Robert (2000). Media release: Snowy Hydro Environmental Impact Statement, 20 January 2000.

Minchin, Nick (2000). Media release: Corporatisation of the Snowy Mountains Hydro-electric Authority, 21 January 2000.

Murray-Darling Basin Ministerial Council (1999). The Salinity Audit of the Murray-Darling Basin. A 100-year perspective, 1999,  Murray-Darling Basin Commission, Canberra, pp. 39.

Pendlebury, P., Erskine, W., Lake, S., Brown, P., Pulsford, I., Banks, J., Nixon, J. and Robertson, C. (1996). Expert panel environmental flow assessment of the Snowy River below Jindabyne dam, Prepared by Snowy Genoa Catchment Management Committee, Cooma, pp. 72.

Prime Minister’s Science and Engineering Council (1996). Managing Australia's Inland Waters, Department of Industry, Science and Tourism, Canberra.

Snowy Water Inquiry (1998). Snowy Water Inquiry Final Report, prepared for NSW and Victorian Governments, Sydney.

Sinclair Knight Merz (2000). Water Savings in Irrigation Distribution Systems. Report for the Department of Natural Resources and Environment.

The Australian (21/12/1999). Flow-on effect as a river runs dry, Senator Robert Hill.

The Australian (22/12/1999). Great divide splits Coalition in river battle's ebb and flow, p.4.

Truss, W. (1999). Press release: Salinity Audit of the Murray-Darling Basin,  Minister for Agriculture, Fisheries and Forestry, October 1999.

Department of Environment and Natural Resources (S.A.) (2000). River Murray Barrages Environmental Flows, Wetlands Management Program, South Australia, for the MDBC, pp. 118.

 Appendix 1