Water take measurement and metering

Submission to the Water Reform Action Plan April 2018

Accurate measurement and access to real-time data improves resource management, system operations and increases efficiency. The NSW Government is seeking to implement a robust framework to measure and meter water take to adopt the no meter, no pump recommendations of the Matthews Review.

Metering standards vary widely across NSW; southern systems are highly metered while some unregulated systems have no uniform metering requirements. If it can’t be measured, it cannot be managed.

Murray Irrigation is Australia’s largest private water delivery company and the nation’s most modern. Since 2012 the company has spent over $200 million1 upgrading our internal network with telemetry-enabled metering equipment to the farm.

Through that investment, more than 95 percent of water use within the Murray Irrigation system is now delivered through an upgraded meter and the company’s operations are an example of best practice measurement and metering in bulk water management achieving an annual system delivery efficiency of 87 percent through almost 3,000km of earthen irrigation channels. Cost recovery

The costs of compliance or metering developments stemming from the creation of the Natural Resources Access Regulator must be recovered from the region/s in they are incurred.

Murray Irrigation is a not for profit entity that has already invested heavily to create a fully compliant system that is intensively and accurately metered. It would be unconscionable if it were to incur any costs associated with the measurement, metering and policing of other system.

1 $169 million from the Federal Government Private Irrigation Infrastructure Operators Program (PIIOP) 443 Charlotte Street, NSW 2710 PO Box 528, Deniliquin NSW 2710 T 1300 138 265 F 03 5898 3301 www.murrayirrigation.com.au Measurement and metering: WRAP

April 2018

Consultation topics Effective metering is vital for efficient resource management.

In 2009 the Council of Australian Governments (COAG) developed the National Framework for non-urban water metering under the National Water Initiative. This framework required all non- urban meters to comply with national standards by 30 June 2020.

In 2013 the NSW Government published Interim Water Metering Standards to provide guidance in the absence of enough pattern approved meter options. In 2015 the NSW Government released a discussion paper on Water take measurement in NSW2.

The objective of improved measurement must be about improving resource management and reporting which in turn will lead to better accountability and compliance. To ensure equity and fairness metering and measurement requirements should be applied consistently across the State. When should a meter be required?

The 2015 Water take measurement strategy discussion paper identified a target of not less than 95 percent of licenced water to be delivered through an approved meter. To reach this target, Government-owned meters were installed on all pumps of 50mm or larger in the pilot areas of the NSW Murray and Murrumbidgee.

In Murray Irrigation, prior to 2012 the standard farm outlet measure was the Dethridge Wheel. The company decided to invest in those outlets with an average four-year delivery history of greater than 50ML/yr. As a result, more than 95 percent of the water we deliver is measured by one of the most advanced water metering networks in the world.

According to the consultation paper, metering 46 percent of water supply works would meet the target of 95 percent of water use but what are the metering options that are being considered?

A key principle must be consistency across the State. Water users must have confidence that everyone is being held to the same standard and that metering and measurement must apply to all water users regardless of purpose.

Murray Irrigation continues to believe that the key to improved environmental performance will be achieved when: The rigours of the consumptive water use industry must be applied to the management of environmental water.

2 NSW Water Take Measurement Strategy: Discussion Paper, NSW DPI-Water, July 2015. 443 Charlotte Street, Deniliquin NSW 2710 PO Box 528, Deniliquin NSW 2710 T 1300 138 265 F 03 5898 3301 www.murrayirrigation.com.au Measurement and metering: WRAP

April 2018 This table examines the options under consideration:

Threshold basis Comment

Water Share Component: This would not capture high temporary water use. Require a meter based on the number of water shares associated with the works. Example: Within Murray Irrigation, some of our highest water users hold little or no entitlements and use the temporary water market.

Infrastructure size: Infrastructure size was used as a threshold in the NSW southern valleys metering projects The size of the infrastructure will limit the set at 50mm. volume that can be taken, noting that improving technology means pumps are The issue of multiple works can be becoming more efficient. addressed by linking the threshold to a review of the account holder’s usage history. How to capture multiple works below threshold that cumulatively use a volume Example: Murray Irrigation adopted four-year above the threshold capacity. average usage to determine its threshold for capital investment.

Water source risk: Based on the information available, there is no indication of how much total water take Linked to ecological risk and competition risk. would be captured through by this option.

This option does not provide for consistency across the State as current estimates indicate 24 of the 57 water sharing plan areas would be considered at risk.

Combination water share and risk: The paper does not explain how this option would cover a relevant percentage of Requires meters in an at-risk area where a licenced water use. set number of water shares are held on infrastructure of a certain size. This option does not deliver state-wide consistency.

443 Charlotte Street, Deniliquin NSW 2710 PO Box 528, Deniliquin NSW 2710 T 1300 138 265 F 03 5898 3301 www.murrayirrigation.com.au Measurement and metering: WRAP

April 2018

Type of metering equipment?

The consultation paper proposes that all meters in NSW meet Australian Standard 4747 for non- urban water supply.

There is currently no pattern approval for large open channel offtakes such as those used by Murray Irrigation, and it is unlikely that pattern-approved meters of sufficient size will be commercially available.

Irrigation Infrastructure Operators (IIOs) such as Murray Irrigation are required by our licence conditions to have the accuracy and calibration of our offtakes independently assessed on a regular basis. Calibration reports are published annually in the Annual Compliance report. An example of the Calibration report is provided at Annex A.

Key message: The NSW Government must establish an alternate accreditation for these large river offtakes to ensure ongoing compliance by Irrigation Infrastructure Operators.

Murray Irrigation’s offtakes have data loggers and transmit data via telemetry to river operators. This access to live data enables managers to adjust upstream and downstream operations to generate better services, increase on-farm productivity and increase system efficiency.

“I now order water and monitor flows on my iPhone. Once the outlet is set to auto, it will chase the ordered amount so the flow stays consistent,” Marcus Flanagan, Dairy Farmer, Finley3. Metering roll-out

Murray Irrigation’s infrastructure upgrade project commenced in 2012 leading to the replacement of over 2,100 meters across the network. A strategic and phased rollout was essential for the successful completion of the project capture immediately begin to deliver the benefits of system efficiencies section by section.

Efficient and effective measurement and metering must be about system management as much as about compliance. To improve resource management, metering should be rolled out system by system or valley by valley.

The consultation paper proposes prioritising meter rollout to large users and high-risk areas.

Murray Irrigation recommendation: Focus on systems rather than users when rolling out metering. It will accelerate the roll out of benefits across an entire system rather than favour individual enterprises.

3 http://murrayirrigation.com.au/piiop/testimonials/ 443 Charlotte Street, Deniliquin NSW 2710 PO Box 528, Deniliquin NSW 2710 T 1300 138 265 F 03 5898 3301 www.murrayirrigation.com.au Measurement and metering: WRAP

April 2018

Meter ownership

Murray Irrigation elected to own all meters within its network to provide uniformity, ensure telemetric compatibility and to realise the benefits of economies of scale. We:

 coordinated the installation of all meters,  oversaw compliance with government and manufacturers recommendations  assumed responsibility for all ongoing monitoring and maintenance, and  provided a options for size and type e.g. FlumeGateTM or SlipMeterTM. Metering and compliance Murray Irrigation access water from the following accredited water supply work sites:

Canal Offtake from the at Canal Offtake from the Colligen Creek from the Edwards River

Both sites utilise ultrasonic AFFRA meters calibrated annually by Thiess Hydrographic Services4 . These meters are fitted with data transfer modems that provide hourly downloads to the river operator, WaterNSW. River operators and regulatory authorities know exactly how much water the Company is extracting, and, along with annual reporting obligations, the company’s extraction records and operating efficiency are transparent.

Since 2012 Murray Irrigation has upgraded more than 2,100 farm outlets with modern and efficient Rubicon FlumeGateTM and SlipMeterTM outlets both verified by Manly Hydraulics Laboratory for accuracy within +/-2.5 percent5.

More than 95 percent of water use within the Murray Irrigation system is now delivered through an upgraded meter.

Michael Renehan Chief Executive Officer

Annex A: Excerpt from the Murray Irrigation Annual Compliance Report 2016-17

4 Annual Compliance Report, Murray Irrigation, 2017, p38 5 https://www.rubiconwater.com/ 443 Charlotte Street, Deniliquin NSW 2710 PO Box 528, Deniliquin NSW 2710 T 1300 138 265 F 03 5898 3301 www.murrayirrigation.com.au Measurement and metering: WRAP

April 2018

About Murray Irrigation Murray Irrigation is Australia’s largest private water delivery company. With an established reputation as the authoritative voice in the delivery of consumptive water, we also have a commercial interest in the management and delivery of environmental water i.e. our single largest customer.

Murray Irrigation Limited operates the most modern irrigation infrastructure system in Australia. It is equipped almost entirely with telemetry-enabled metering equipment that has been installed over the last six years at a cost of over $200 million.

Whilst the flow and metering infrastructure in farm delivery channels is less than five years old, the backbone of the system is one of the nation’s most critical pieces of river management infrastructure: the 80-year-old Mulwala Canal.

As an unlisted public company, Murray Irrigation provides irrigation water and associated services to almost 2,400 landholdings through around 3,000km of gravity-fed earthen supply channels over an area of 723,000ha in the NSW southern . Murray Irrigation’s source of water is the regulated River Murray above Barmah Choke and the company’s water supply is almost exclusively NSW Murray General Security Water.

Murray Irrigation’s shareholders are farmers, with food and livestock being the focus of regional production for both domestic and international markets.

Our single largest customer is the environment.

Peak body membership

Murray Irrigation is a member of both the NSW Irrigators’ Council and the National Irrigators’ Council. We work with these bodies to ensure the interests of irrigators are represented.

The Water Exchange – pecuniary interest declaration

The Water Exchange is wholly owned and operated by Murray Irrigation. It was originally developed to enable customer shareholders to trade water between themselves with minimal red-tape. Paramount to the success of the Exchange has been the ability to access information. The exchange lists current price information, historical price information as well as current offers from prospective buyers.

The Water Exchange is open to all; however, it is the responsibility of external buyers or sellers to transfer sales to or from their own WAL.

443 Charlotte Street, Deniliquin NSW 2710 PO Box 528, Deniliquin NSW 2710 T 1300 138 265 F 03 5898 3301 www.murrayirrigation.com.au Measurement and metering: WRAP

April 2018

Annexure A:

Excerpt from the Murray Irrigation Annual Compliance Report 2016-17

443 Charlotte Street, Deniliquin NSW 2710 PO Box 528, Deniliquin NSW 2710 T 1300 138 265 F 03 5898 3301 www.murrayirrigation.com.au