Part E &

Part F

THE MURRAY-DARLING BASIN

RESOURCE MANAGEMENT IN THE MURRAY-DARLING BASIN

Chapter 13

Chapter 15

Chapter 16

Chapter 17

REGIONAL AND ECONOMIC BASE

ENVIRONMENTAL CONDITION OF THE MURRAY-DARLING BASIN

SALINITY

RESOURCE MANAGEMENT FRAMEWORK IN THE MURRAY-DARLING BASIN

These Chapters are valuable in providing relevant information on Snowy Corporatisation matters.

This Draft Environmental Impact Statement is remiss in not considering the same aspects in relation to the Snowy catchment.   This region has a regional and economic base, which has been significantly affected by the loss of flows in the Snowy River.  

There is also comparable information available on the environmental condition of the Snowy catchment, as is presented for the Murray-Darling Basin.

Part D

THE SNOWY RIVER CATCHMENT

Chapter 10

ENVIRONMENTAL STATUS OF THE SNOWY RIVER
BELOW JINDABYNE

10.1.1

Draft Scoping Study 1995

In discussing the various scenarios from the Draft Scoping Study the Draft Environmental Impact Statement fails to acknowledge that the Study details that overall the greatest social, ecological and economic benefits are obtained by Scenario 5 – release from Jindabyne Dam of an average 800 ML/d (released in a natural monthly flow pattern).

10.1.2

Expert Panel 1996

The Report states …. the recommendations were consistent with the precautionary approach to ecological management ….

It would be incorrect to assume from this statement that the recommendations erred on the higher side of flow requirements.   In fact, the recommendations from the Expert panel were considered to be the minimum requirements.

This aspect of the Panel’s report is not accurately portrayed in this section of the Draft Environmental Impact Statement.

10.2

SNOWY WATER INQUIRY 1998

10.2.3

Inquiry Findings

Condition of the Snowy River

It is acknowledged that there is significant degradation to the Snowy River downstream of Jindabyne.

It is inappropriate to state that the condition of the Snowy River from Delegate River to Buchan River is relatively good compared with its upstream section.   The relative condition is immaterial.   The Draft Environmental Impact Statement should be objectively reporting on the condition of the Snowy River.   The section is still degraded, even if the upstream section is in a worse condition.

The fact that 95% of this reach is within a National Park is not a measure or guarantee that the condition will not be degraded.

10.2.7

Preferred Option

The Authority acknowledges the option recommended by the Snowy Water Inquiry but disputes that this option will achieve any significant improvement in the environmental condition of the lower Snowy River.

The scientific evidence indicates that a flow of 15% ANF will be inadequate to improve the condition in the lower reaches.

Chapter 12

ADDITIONAL INFORMATION COMMISSIONED
POST THE SNOWY WATER INQUIRY

12.1

Review of Snowy Water Inquiry

The Fluvial Systems Pty Ltd review of the environmental findings of the Snowy Water Inquiry considers catchment and river channel works to be most effective in the lower reaches.   These river channel works would still be reliant on flows and would be more effective and if coupled with the flow levels in accordance with those recommended by the Expert Panel and subsequent studies.

The statement that there is no evidence of impacts on banks or vegetation from increasing salinity is strongly disputed.   The Authority can clearly demonstrate that loss of Phragmites australis along the lower reaches is related to alternating salinity regimes.

12.3

Greenhouse Considerations

While acknowledging the loss of power generating capacity resulting from returning water to the Snowy River, the Draft Environmental Impact Statement assumes that the replacement power will come from coal based power stations.

While acknowledging that no new information was gather for the Environmental Impact Statement, it should be noted that alternative power sources are available (gas fired turbines, access to the Tasmanian Hydro schemes through the national grid).

The Draft Environmental Impact Statement only considers greenhouse emissions in regard to power generation.   No consideration has been given to the greenhouse gas emissions resulting from continuing to supply Snowy River water to greenhouse gas producing industries.

Part E

THE MURRAY-DARLING BASIN

Chapter 16

SALINITY

It is acknowledged that the salinity issue in the Murray-Darling Basin is a significant one.   The Draft Environmental Impact Statement correctly concludes that both the Snowy Water Inquiry and the latest Murray Darling Basin Commission modelling report that that there is only a marginal impact on salinity from returning water to the Snowy River.

Part G

DELIVERING ENVIRONMENTAL FLOWS

Chapter 19

THE DECISION-MAKING FRAMEWORK

19.2

Determining a level of Environmental Flows

The Catchment Management Authority contends that the application of the ecologically sustainable development principles and the COAG Water Reform framework would require rather than suggest that some level of environmental flow should be returned to the Snowy River.

19.2.1

What are the Options?

The Catchment Management Authority takes strong exception to the range of options presented.

The Snowy Water Inquiry clearly considered options above 28% ANF.

The Expert Panel indicated that 28% ANF was a minimum flow required.

The Final Report should include an option of at least 28% ANF.

19.2.3

Water Security

The Catchment Management Authority acknowledges that the water resources of the Scheme are already fully committed and that there may be adverse impacts when water is returned to the Snowy River.   However, incurring these impacts may well be a factor the decision-makers take into account and should be balanced against the significant adverse impacts which already exist within the Snowy catchment.

This section appears to ignore that these adverse impacts are already occurring within the Snowy catchment.

19.2.4

Implications for the Murray-Darling Basin

In order to provide a balanced view, this section should also include the benefits from returning water to the Snowy River.

A section on Implications for the Snowy Catchment would improve the balance of this Draft Environmental Impact Statement.

19.3

Suggested Approach

The Catchment Management Authority queries why the first conclusion started with the premise that …. the provision of environmental flows to the Snowy River should have no adverse consequences for stakeholder interests within the Murray Darling Basin.   This premise ignores the significant adverse conditions in the Snowy catchment resulting from the Scheme.

This Draft Environmental Impact Statement should seek to minimise the adverse impact on all stakeholders and not focus solely on the Murray Darling Basin.

The third conclusion commences with …. if the water security ….   The Catchment Management Authority contends that the protection of the water security interests of consumptive users and environmental stakeholders in the Murray Darling Basin must be balanced against the Snowy catchment’s legitimate claims.   This decision will be made by Government and should not be a conclusion of this Draft Environmental Impact Statement.

The Catchment Management Authority does not fully support the decision-making framework as proposed.   This approach ignores the benefits to be gained from returning flow to the Snowy and seeks to substantiate and perpetuate a decision made 50 years ago.

The Catchment Management Authority contends that with current knowledge and processes, such a decision would not be made today.

The framework should therefore accommodate the possibility that previous decisions may need to be altered and appropriate compensation made.