Murray Darling Basin Plan and Constraints Management Strategy Submission to Senate Select Committee Submitter Margaret Abbey Chief Executive Officer On behalf of 1.0 Introduction Murrindindi Shire is situated at the top end of the catchment and Council has been an active stakeholder in the development of the Murray Darling Basin Authority (MDBA) Plan and Constraints Management Strategy, including representation on the Mid-Goulburn MDBA Technical Advisory Committee and the MDBA Community Leaders Advisory Group as well as the Floodplain Landowners Association Upper Goulburn Catchment. The Goulburn River is a significant feature of the shire. Entering from Eildon the river flows in a westerly direction through a broad, agricultural valley bordered by foothills towards Seymour leaving the shire at Kerrisdale. Water in this stretch of the river comes from releases from Eildon Dam and inflows from several unregulated tributaries. The Rubicon River, Acheron River, Spring Creek, Home Creek, Yea River (and Murrindindi River, which joins the Yea) and King Parrot Creek all enter this stretch of Goulburn River. These tributaries are unregulated and rise and fall rapidly in response to rain. The Goulburn River is key to Murrindindi Shire’s businesses including farming, fishing, aquaculture, tourism and caravan parks. Council is concerned for the environment, the people who work and live along the river and the assets that may be affected. The benefit from environmental flows is recognised, however they must be weighed against increased risk to the community and property. Whilst Council is supportive of the key principle of the Murray Darling Basin Plan (plan), to provide a coordinated approach to water use across the Basin's four States and the ACT, our concerns primarily relate to proposed constraint measures that are being considered for the Goulburn area in the Constraints Management Strategy (strategy). The provided details, on which Council is commenting, are currently limited. The recent strategy consultation documentation identified that the business case, which is currently not due to be developed until November 2015, will improve the accuracy of the predictive modelling, identify the impact of the tributaries, develop the plan for the release of the environmental flows as currently the source is only identified as Eildon Dam and/or Goulburn Weir, and decide on the volume of overbank flows. In light of these current uncertainties Council is required to consider the potential highest risk to our community and respond to that. A range of flow options are currently under consideration in relation to the ‘top up’ required to be added to deliver the required downstream flows of 25-40,000Ml/d at Shepparton, of 12,500, 15,500 and 20,000Ml/d, which potentially might be fully sourced from Eildon Dam as the contribution from Goulburn Weir is unknown. While it is accepted that the maximum in channel capacity (at the Molesworth pinch point) is 9,500 Ml/d, local experience and evidence has highlighted that the proposed environmental flow of 12,000 Ml/d impacts the Molesworth region and 15,000Ml/d elsewhere in the subreach 20,000Ml/day, more than double the channel capacity, results in major flooding and damage across the reach and is considered to be unacceptable and significantly higher than that currently indicated in the modelling. Council is also concerned about unintended consequences which may be created by the lack of coordination between the development of strategies impacting in the same area. Specifically the Victorian Floodplain Management Strategy (VFMS) on which Council has recently commented. The VFMS proposes a strategic approach of using existing wetlands to reduce the impact of flooding. However the MDBA plan and strategy are not referenced within the VFMS although the proposals have a potential to impact on each other. In addition the VFMS also states that costs to implement Water Management Schemes will be equally shared but that management, maintenance and auditing costs will be the responsibility of the LGA. With the proposed additional flooding events under the strategy, financial impact on Council could be higher than intended. Council recognises the strategic objective of the Strategy to manage water for environmental use, however a key principle is that there will be no new risks to entitlement holders. It is our belief that unintended consequences could result in a significant negative impact on Council and on the community in our Shire. These consequences have not yet been vigorously assessed and further investigation is required before the strategy is endorsed. Council’s concerns detailed in this submission relate to the following items; • Integrity of the data and modelling used to forecast impacts, including the impacts of the tributaries • Accountability for the risk of flooding beyond anticipated levels. • Unrecognised costs and impacts on landowners. • Managing health and safety. • Impact on the tourism industry. • Cost impact on Council. 2.0 Integrity of data Council is concerned that there is insufficient data to properly inform the Authority and Australian Government prior to decision making. Specifically the current flood modelling does not reflect local experience of the impacts. This has been recognised in the recent Goulburn River Reach Report July 2015 (GRRR) and it was confirmed at recent community consultation meetings that further models were being developed. The GRRR states “limited data reduce the accuracy of the hydraulic models especially in the mid- Goulburn just down from Eildon and the lower Goulburn downstream of Loch Garry)” (Page 30). In addition Council does not believe the Strategy takes into account the potential impacts of the many tributaries. This is also substantiated in the GRRR “From MDBA consultation 2013, there is some concern that we do not yet have sufficient accuracy in the stream gauge network to confidently predict how tributaries will behave under different weather scenarios.” (Page 37). Flows in the Acheron River are augmented by the Taggerty and the Steavenson Rivers. The unregulated nature of these rivers and their capacity to rise rapidly due to local precipitation compounds the impact of potential outcomes in the Goulburn River and the difficulty of accurate modelling. Currently not all of the catchment between Eildon and Trawool is gauged, half of the Yea/ Murrindindi catchment is not gauged and a large percentage of the King Parrot Creek is not gauged. The unregulated tributaries between Eildon and Seymour include the Rubicon River, Acheron River, Spring Creek, Home Creek, Yea and Murrindindi River, King Parrot Creek, Steavenson River, Whiteheads Creek and Sunday Creek. This lack of a necessary gauging network particularly on the tributaries does not allow accurate modelling or informed decisions to be made on Eildon releases to ensure flows are safely managed and contained to the targeted levels. 3.0 Risk of flooding beyond anticipated levels Given the above concerns on the validity of the modelling information, Council considers there is high risk that flooding may be greater than anticipated. The release of water from Eildon has a significant travel time, for example 24hrs to reach Molesworth. During this time there is also potential for unpredicted rain events to add to the flows. Climate change is likely to lead to more intense patterns of rainfall leading to more destructive storms which can significantly influence the severity of flood flows. The data, to date, do not appear to have considered the changes to rainfall patterns which are being dramatically disrupted due to warming temperatures as highlighted with the VFMS. The significant risk of flooding being greater than expected may cause extensive damage to property. For Council the question that has not been addressed is, if the flow footprints are larger than expected, and for which the compensation has been paid, how will people be protected and where does the increased financial liability lie?. There is concern that the risk and liability will be shifted to affected individuals or businesses and the local Council through “one off” payments and forcibly acquired easements. The potential impacts, like the flows and the subsequent damage caused, cannot be accurately predicted. 4.0 Unrecognised Cost Impacts on Landowners and Businesses There are significant impacts on a farming business created by flooding that are not acknowledged within the report. These impacts could render some farming operations unviable as extended flooding results in loss of food, fibre and economic benefits. Many farms rely almost totally on the river flats to provide pasture and grazing land for stock. Flooding of the river flats in many cases will require agistment, transportation and purchased feed for stock at significant cost. Where stock can be moved to higher ground the increased and intensified stocking rate can be detrimental to the remainder of the property requiring significant rehabilitation costs. Restricted access to river flats making urgent movement of cattle difficult and dangerous and stressful to stock particularly during the breeding period. The rapidly rising flood waters also present significant dangers for those who have to manage stock movements. The proposed period and timing of flooding has the potential for loss of silage and hay production and loss and damage to pasture during the prime fattening period of August to November. The proposed flood event timing and length is still unclear with the GRRR talking of “days to weeks” with flows occurring between June and November with the preferred period August to November. Prolonged inundation of pasture and crops will cause significant damage requiring expensive and prolonged renovation. Advice from local landowners indicates that a flood event that lasts for a week or more can result in damage to pasture that can take two to three years to recover and farmers are required to manage the subsequent weed infestation, biosecurity issues and nutrient leaching in the following years. The proposed additional events could result in up to six flood events in the ten year period, potentially an event every other year.