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Corporatisation of the Snowy Mountains Hydro-Electricity Authority EIS,
Environment Assessment Branch, Environment Australia, 
GPO Box 787,  CANBERRA, ACT 2601.

Introduction.        

The Orbost Women’s Awareness Group is a widely representational group of women from Orbost and its surrounding districts.  They are vitally interested in supporting the community programmes and activities which are so necessary in maintaining the welfare and stability of  this area of South Eastern Australia.

We, the members of our organisation, view with great concern and anger, the ecological degradation which has been visited on the Snowy River below Jindabyne since the Jindabyne Dam became operational in 1967.  The members are also acutely aware of the obvious political discrimination  which has been, and  is being levelled against this region, the Snowy River, and the people of the Snowy River Corridor below Jindabyne Dam, with regard to the taking and use of Snowy River waters. We reject the approach taken in this report which is slanted away from returning water to the Snowy River.

We live in an area of Victoria where the populations of our region are not densely concentrated in large towns or living cheek by jowel with their neighbours.

However, and this point is not recognised by Government or the Bureaucracy, and certainly not acknowledged in any way in the Draft EIS Report, the social cohesion, the socio-economic necessities of this region, the need for the Snowy River to be able to maintain its ecology from having sufficient of its own water to do so, and the need of the people of the Snowy Valley and beyond, to use their river in  the same ways as the people of the Murray River expect to and do use their river, is important to us in exactly the same ways as it is to them. 

We too are a part of the “National Interest”, although Senator Robert Hill will not admit we are when, he constantly refuses to  recognise the Snowy River has been shamefully exploited and degraded, in order to satisfy the grab for water in the Murray Darling Basin over the last forty years.       The Basin, and that includes South Australia, is now paying the price for the over use of the all too readily available water from the Snowy Mountains Scheme, and by direct association,the Snowy River.  Murray River salinity, dryland salinity, acidity and waterlogging problems which , with responsible tree clearing and judicious usage of water years ago could have been largely avoided, are now the greatest threat to our “National Interest”. No Government during the last four decades can “cover itself with glory”in light of the wilful political expediency with which it has presided over what is becoming the greatest National Disaster since  the White Man’s occupation of this continent.  This, regardless of the scientific warnings which have been proffered to it for many years

Quote “The Primary Purpose of this EIS is to ensure the public is fully informed on all issues associated with corporatisation of the Snowy Mountains Hydro-electric Authority (SMHEA).

The EIS is required to focus on issues associated with potential changes in water flows associated with, or arising from Snowy corporatisation, with particular emphasis on how these might affect the future health of the Murray-Darling Basin.”

End of quote. from the Summary and Conclusions Draft Environmental Impact Statement re Corporatisation Snowy Mountains Hydro electric Authority.

The purpose of  these comments on the Draft Environmental Impact Statement  re Corporatisation of the Snowy Mountains Hydro-electric Authority is to state that :-

1.      The amount of water needed to reinstate the ecology of the ailing Snowy River below Jindabyne Dam, ie 330GLs will not cause detriment to the Murray Darling Basin from the point of view of its productive ecology or to the farming communities and towns within its boundaries.  The EIS Summaries and Conclusions (along with other reports and documents including the MDBC Audits) infer that as a conservative estimate,there are 3000 GLs of water lost in the water industry across the  River Murray System alone.. The amount required for the Snowy River is approximately 10% of that figure.

2.      Taking into account these recognised losses (see page 290  of draft Environmental Impact Statement para. 21.1.4) which information would appear to be confirmed by the recent “ Victorian Government Report on Water Savings In Irrigation Distribution of Water Systems”  released in June of this year, it becomes apparent the Bewsher Report detailing water savings in the river systems of NSW grossly underestimates the amounts available.

3.      The Snowy  Mountains Hydro-electric Authority’s generation of electricity need not be diminished by the provision of 327-330 GLs of water from out of the “Scheme”.  Water savings across the Basin, along with the implementation of “ requirements to comply with “cap” directives imposed by the MDBC will mean changes to minimum water discharge requirements from the Snowy Mountains Hydro Scheme will be able to be decreased.  Water savings should not be reabsorbed by the irrigation industry as this would defeat the purpose of the cap.

4.      This Draft Report , whilst writing that the COAG agreements and principles require water for the environment is returned to the Snowy River below Jindabyne Dam,( COAG recommends a proper environment flow)  exhibits a strong bias against doing so to the “public” it is so anxious to “fully inform”. See page 2 of Summary and Conclusions, the bottom of page13, and numerous other places in the Draft Report which exhibit this same bias against the Snowy River.

NB  We are very concerned at the perjoritive way with which the word “may”is used by the proponent to affirm arguments against returning water to the Snowy River. eg. Page 10 Summaries and Conclusions: 4^th paragraph.  It would appear the EIS is intending the reader to assume the word “may” to mean “will”.

5.      Water Authorities such as the Murray-Darling Basin Commission make the appropriate decisions to ensure that water allocations are assiduously accounted for by the distributing bodies.For example; in the interests of equity, reporting of estimates of Leakage (through channel banks and pipe joints etc), Seepage, Evaporation, System Filling, Theft,Unmetered domestic and stock use, Delivery Measurement Error, “Unaccounted Water”.

6.      Whilst much importance and great pains are being taken in the Draft Report to  protect the social infrastructure, cohesion and the “Historical Rights”of the people of the Murray, Murrumbidgee and Darling Rivers Irrigation Areas to water, many of whom had never had any riparian river rights before the advent of the Snowy Mountains Hydro-electric Scheme became operational, no such consideration or concern has been expressed in the “Document” for the people of the Snowy River Valley. These people had their true and historical riparian rights to water from the Snowy River removed with the commissioning of the Jindabyne Dam.

7.      The Aboriginal Community along the Snowy River Valley had regarded the waters of the Snowy River as theirs for thousands of years until  white men from over the ranges decided they would have those waters for themselves.  Not being satisfied with just taking two thirds of them, (ie. the waters) they decided they would have the lot.  Now we have two environmental disasters to contend with------- one in the Murray Darling Basin, including South Australia, and another in the Snowy River.

8.      The problems of salinity in the Murray River now occurring in South Australia are directly the result of past Government policy which has encouraged the over extraction and use of water from the Murray River over many years. It is apparent that the over use of the waters of the Murray River and its tributaries for irrigation,  now requires the flow to be augmented with Snowy Scheme water in order to maintain some semblance of ecology. Page 11 in the Summary and Conclusions document (the whole page) is a damming indictment of the results of “river regulation which is threatening the integrity of both the Murray and Murrumbidgee Rivers”.  The contents of the page also attempt to make this seriousl state of affairs sound much better than it is.eg.2^nd last paragraph----“An annual allocation of 100GLs to the Barmah-Millewah Forest Wetlands was approved by the MDBC in 1993, but has remained largely unused.” Refer to Sharing the Murray Document, page 22 Where it states clearly that “simply releasing the 100GL out of the Hume Dam every Spring proved to be of no benefit. The river doesn’t get high enough for water to flow into the forest.”  Furthermore, obtaining sufficient water by ‘saving’ allocations over a number of years  in order to generate the flood required simply didn’t happen as the water was used for irrigation.

The Snowy River below Jindabyne is not the sacrificial lamb with which governments and irrigator stakeholders can hide their environmental mistakes.  The “Integrity” of the Snowy River has been devastated over the last forty years---------all the way along its length including its wetlands and estuary.  Refer to Lower Snowy River Management Plan (Victorian Dept of Conservation and Environment 1990).

9.      The fact that the Draft Management Plan for the Coorong, see bottom of page11 Summary and Conclusions document, can confidently propose an environmental allocation of 500Gls of low turbidity.water in late Summer and early Autumn and expect to get it in at least six years out of ten,demonstrates yet again, the unpardonable environmental discrimination which is directed against the Snowy River.,The struggle has been going on for many years to obtain only 330 GLs for its environment, but until recently has been ignored by all facets of Government, State and Commonwealth.

10. The median flow at the mouth of the Murray River is around 21%ANF.(also page 11) This flow is low because of over extraction of water for irrigation and consumptive uses.   The Review of Cap Implementation 1998/99 (Report of the Independent Audit Group for the Murray Darling Basin Council) conveys the information that whilst South Australia does not use all of the water it is allocated under the “cap” it still takes water from environmental allocations intended for the Murray wetlands in that State for use in irrigation.  Here again the Snowy River’s environmental needs are being ignored to accommodate the misguided exploitation of water in the Murray Valley.

11.  The median flow of the Snowy River at its mouth ( which authorities do not want to know about or accept) is 30%ANF ( source Chris Gippel 1993 Melbourne University)----- not 53%ANF  as advocated by the EIS. It is also interesting to note  that the median flow of the Murray River at Albury is 110% of ANF. And that the median flow of the Snowy River at the NSW-Victorian border near Willis is only 12% of ANF (see Victorian Marine Parks Reports) .     By comparison, the mean annual flow at the mouth of the Murray is 38.5% ANF and the mean annual flow at the mouth of the Snowy is as stated in the Report, or as stated in the Snowy Water Inquiry Report ie 53%.   The lack of  consistency in reporting these flows not only constitutes an attempt to misinform the “public” as to the severity the cuts in flows have been to the Snowy River along its length, but also the extent of its degradation. This lack of consistancy displayed in the process of dissemination of information by this EIS then becomes misleading.

12.  Water Security:  Water Requirements of the Scheme :  and the effects to agriculture (page 6 of the Summary and Conclusions)

The  people of East Gippsland and indeed Southern NSW do not have a problem with sharing their waters of the Snowy River with those West of the Great Dividing Range.  However, they are adamant that the water resource which once flowed in the Snowy should not have been.removed to the extent that it was. Now is the time to redress the wrong.  The Report states that to supply the 327-330GLs needed to refurbish the Snowy River would mean a 14% reduction in water flowing from the “Scheme” to the West.  However, the Murray Darling Basin Commission is insisting that water usage in the Murray-Darling Basin is to be rationalised and “capped”.Further recommendations by environmental scientists are insisting that another 20% will have to come off the overall allocations to try and minimise the increase in salinity.  These recommendations aimed at decreasinge water usage in the “Basin”.
NSW and Queensland have not yet complied with the Murray-Darling Basin Council’s directive to audit their water availability, nor do they comply with the valley “caps”,as required by the MDBC. Again, when these directives are put in place, there will be less water needed to flow to the West from the Snowy Mountains Scheme.  Obviously ,that situation will ensure there will be more than enough  water for the Snowy River and the Montane rivers as well.  There will also be enough water to minimise any adverse effects on Hydro-electricity generation, and enough to reimburse the environmental needs of the MurrayRiver. The Murrumbidgee River is already designated to receive environmental flows under the present system of allocations,. but it would appear these savings are proving slow to materialise!!

13.  The 28% of Snowy River water required to reinstate the ecology of this waterway is equal to only 2.8% of the 12000GLs allocated for use by The MDBC in the Murray-Darling Basin.  It represents only 10% of the 3000 GLs estimated to be lost across the Basin both by the MDBC and the  this report;  These estimates do not include water which is used in the “Basin” but which is not  under the control of the  MDBC. Revision and remodelling of water allocation practices to and by the river valley managers, (which practices are constantly occurring in all irrigation areas anyway), plus decreasing the amounts of water needed to trigger the  “Caps” in each valley, would also assist in finding the savings necessary to start restoring riverine and agricultural ecologies.

14.Social Equity Issues: see page 19 Summary and Conclusions.
Here again the EIS discriminates against the people of the Snowy River Valley and the Snowy River itself.  The sad situation is that whilst the EIS is concerned about the “economic difficulties and the declines in the availability of services in the Murray-Darling Basin”,  and that “regional communities in the Murray and Murrumbidgee valleys are so heavily dependent on river flows for their level of economic activity”…………..and that “these communities have invested heavily on the basis that historical levels of water volumes and security will continue”, the EIS slides very glibly over the fact that the communities of the Snowy River corridor have been suffering these very problems since the Jindabyne Dam was commissioned.  We are still suffering  social equity or inequity problems from having OUR water taken away. This applies just as much to the people of the Monaro region as it does to the communities and farmers along the lower end of the Snowy River in Victoria. No Government has been interested in the affairs of the people of the Snowy Valley to determine how the negative effects of the “Scheme” has affected  us.

The quote in the Summary and Conclusions document on page nine, referring to the 1999 Fluvial Systems Report (John Tilliard) which refutes the findings of the Snowy Water Inquiry  with regards the extent of intrusion of salt upstream in the SnowyRiver, is another attempt on the part of the EIS to diminish in the eyes of the public the environmental degradation along the lower end of the Snowy River in Victoria. Every farmer along the river below the Princes Highway Bridge at Orbost will tell you he/she is no longer able to irrigate their pastures during the Summer unless there has been very heavy falls of rain higher in the catchment, and that they are no longer able to water their cattle from the bores which were in the riverine vicinity, and which were useable before the advent of the Jindabyne Dam. Those farmers now depend on the town water supply at high cost, to water their cattle and other stock, and to clean their dairy and other equipment as the saline water now  being found further and further up the river causes disintegration of same.  Furthermore,vegetation along the lower river including that on the two islands (once rainforest) has certainly diminished to a great degree (see Lower Snowy River Management Plan produced by the Dept of Conservation and Environment 1990 now the Dept of Natural Resources and Environment). 
Fluvial Systems Pty.Ltd. appears to be at odds with the many other panel reports on this score; and not only with the Snowy Water Inquiry but with the Scoping Study and the Expert Panel’s Report as well..

15.  Hydro-electric Generation and Green-house Emissions:
The capacity of the Snowy Mountains Hydro-electric Authority to generate 15-17% of the  South Eastern Grid is never used.  Instead the generator only generates between 4 to 5% of the grid in any year (information supplied by News Sheets Snowy Mountains Hydro-electric Authority).  Natural Gas is now becoming much more widely available for use as an alternative energy supply with the advent of the new gas pipeline between Sydney and Longford and others from other onshore gas fields.  The Bass Straight electricity link up between Tasmania and the mainland is also going to decrease the profitability of the Snowy Mountains Hydro-electricity generation.  The estimated 7% loss of generating  capacity to the Authority when supplying approximately 320 GLs back to the Snowy River is therefore going to be 7% of 5%, or 0.35%.  Under these circumstances the “loss” would constitute a very small part of the South Eastern Grid, and, it is variously reported  (? ABARE) 0.07% of the Australian Greenhouse emissions.

There is no doubt from the evidence supplied in this and other enviromental reports that, along with water savings, the management skills of the “Hydro” and Water Authorities should be required and encouraged to become more encompassing of the Snowy River as a legitimate stakeholder in this very serious water debate. We would not then have this unacceptable state of inequitable and unfair bias, against the refunding of the appropriate environmental flow of Snowy River Water to the Snowy River and its people below Jindabyne .

Conclusion  The monetary costs of the exercise to refurbish the Snowy River  with a barely adequate amount of water, 330 GLs, pale into insignificance when  we recognise that:-

1.      The water from the Scheme is sent free of charge to the Murray and Murrumbidgee Rivers for use in the irrigation industry..

2.      The irrigation industry in the Murray-Darling Basin has been subsidised in this way by the people of the Snowy River Valley and the Snowy Mountains Hydro for over forty years

3.      The Murray-Darling Basin has had billions of dollars worth of benefits during the last forty years as a result of the “Scheme” and now  when it is sold to an outside bidder, the Basin will have received the whole thing virtually free of charge

4.      The cost of trying to prevent further environmental deterioration in the Murray-Darling Basin is conservatively estimated to run into tens of billions of dollars as opposed to that needed to partially restore the Snowy River

5.      The economic value together with the social cohesion, and the sense of identification the Snowy River river and its waters impart  to the people of this region are as important to them as those same attributes which are supplied by the Murray and Murrumbigee Rivers to the people of their basin.

6.       We expect, that in the National Interest, our needs, and the ecological needs of our Snowy River below Jindabyne Dam for the return of water, are given as much consideration and credence as those of other stakeholders in this debate.  We reiterate our concernn that this Draft Report showss an obvious reluctance to acknowledge the necessity to rehabilitate the SnowyRiver to an acceptable standard of ecological function.  We hope this discrepancy will be corrected in the final document.

7.      It is interesting to note that a document called Sharing the Murray was produced in 1997 for the Murray Water Entitlement Committee.  In the interests of equity, we would be interested to know when the document entitled Sharing the Snowy River will be printed by a government department!!


We thank you for the opportunity to respond to this
Draft Environmental Impact Statement.
On behalf of the members
I am
Yours sincerely,
Heather Richardson        Chairperson.

NB A hard copy of these comments containing the Chairperson’s signature will be fowarded by surface mail at the earliest opportunity.