Draft Mitchell Water Resource Plan

Transcription

1 Draft Mitchell Water Resource Plan Queensland Environment Groups Submission December 2006

2 Executive Summary The Mitchell River Basin covers one of the most diverse ranges of natural habitats in Australia, encompassing the rainforests of the Wet Tropics World Heritage Area, the open savannah of the upper and lower Mitchell plains, and the vast mangrove and lagoon systems of the Mitchell River delta. Natural water flows in the Mitchell are the heartbeat for these ecosystems, and the lifeblood for many existing communities and industries, including fishing and tourism. This country has been managed for millennia by its Traditional Owners, who maintain strong cultural connections to the land and water of the Mitchell River Basin. The Mitchell River basin has largely been spared the destructive and costly impacts associated with land clearing and overdevelopment that have so affected southern Australia. As a framework for the sustainable management of water, the Mitchell Water Resource Plan (WRP) should ensure these vital natural flows are sustained and the disasters of the south are not repeated in North Australia. We commend the Queensland Government for rejecting the Northedge Dam and other in-stream impoundments in the draft WRP, which threaten the natural flows and healthy function of the Mitchell River system. We also congratulate the Government for the holistic, single-resource approach to surface water and groundwater management in the plan area. Our groups contend, however, that the amount of new available water proposed in the draft WRP encourages the type of unsustainable development that will adversely alter natural flows and degrade this important river system. We are concerned the Government has not based their water reserves policy on sound environmental, economic and social grounds, but on the highly speculative demands of consumptive water users on the Community Reference Panel. We strongly encourage the Government to cap water entitlements and reserves at existing levels and spare the Mitchell River Basin from inappropriate development. We also ask that the Government commence arrangements for the decommissioning of Southedge Dam, and a Wild River listing for the Mitchell. Below is a summary of our key recommendations. The Draft WRP Comments and Recommendations in this submission provide more detail to these points. The submission also includes recommendations for the Resource Operations Plan. Queensland Environment Groups Key Recommendations: WRP Amendments: Cap water entitlements and reserves at existing levels Include a clause in the WRP that specifically rules out in-stream impoundments Include a clause to address the degradation of the Upper Mitchell River Immediate Priorities: Amend the draft WRP to ensure the Mitchell River and its tributaries (excluding the Upper Mitchell) remain eligible for Wild River listing Cancel the license of Southedge Dam and begin initial assessments to decommission the dam and restore flows to the Upper Mitchell River Review Government consultation process with Indigenous people and communities and undertake a comprehensive cultural survey of the planning area to identify cultural values in water and culturally significant sites, as appropriate. Make Overland Flow works Code Assessable Development under the Integrated Planning Act 1997 Require all water entitlement holders to complete a Land and Water Management Plan 2

3 Contents 1 Preamble Draft WRP Comments and Recommendations Strategic and General Reserves General Reserve of ML in Upper Mitchell River ML in the remainder of plan area Consultation Process General Concerns Indigenous Representation Mitchell as a Wild River Overland Flow Integration of Land and Water Management No Dams Policy Connected Water Resource Management Decommissioning Southedge Dam Nullinga Dam and FNQ Water Supply Strategy Resource Operations Plan Recommendations References Queensland Environment Groups Submission into the Draft Mitchell Water Resource Plans December 2006 Developed by: The Wilderness Society The Australian Conservation Foundation Queensland Conservation Council Cairns and Far North Environment Centre 3

4 1 Preamble The Queensland Conservation Council (QCC) is the peak environmental organisation in Queensland, with over 70 member groups. In partnership with its members, QCC works to protect, conserve and sustain Queensland's natural environment. Established in 1969, QCC provides leadership on a wide range of environmental and conservation issues, at all levels of government and throughout the community. QCC's Rivers Project aims to promote ecologically sustainable river management, protect natural and wild rivers and to highlight the impacts of instream and off-stream structures and diversions. ACF is a not-for-profit community organisation committed to inspiring people to achieve a healthy environment for all Australians. For 40 years we have been a strong voice for the environment, promoting solutions through research, consultation, education and partnerships. We work with the community, business and government to protect, restore and sustain our environment. The ACF Northern Australia Program (NAP) was established in 2003 and is based in Cairns. The NAP progresses culture and conservation outcomes through its work across the north, from Cape York Peninsula in the east to the Kimberley region in the west. The Wilderness Society is a community-based environmental advocacy organisation whose mission is protecting, promoting and restoring wilderness and natural processes across Australia for the survival and ongoing evolution of life on Earth. TWS have lead the campaign for the protection of Wild Rivers in Queensland. TWS have been involved with the Gulf Water Resource Planning process holding a seat on the Community Reference Panel as a conservation representative. The Cairns and Far North Environment Centre Inc. (CAFNEC) is a not-for-profit organization that was formed in 1981 by concerned members of the Far North Queensland community seeking better protection for Far North Queensland's natural environment. CAFNEC's geographic range of interest stretches from Cardwell in the south to the Torres Straits in the north and the Gulf of Carpentaria in the west. This region includes three World Heritage areas including the Great Barrier Reef World Heritage Area and the Wet Tropics World Heritage Area. Our groups support the recognition and expression of native title rights of indigenous Australians in natural resource management planning. We acknowledge the significant cultural rights, obligations and interests of Traditional Owners and Indigenous peoples in water. 2 Draft WRP Comments and Recommendations 2.1 Strategic and General Reserves The Mitchell River Basin is a mosaic of nationally and internationally significant ecosystems. Its free flowing rivers, whose natural flows support these important ecosystems and many existing communities and industries, are among the healthiest remaining catchments in Australia, and indeed the world. Aside from the Southedge Dam the blight of the health of the Upper Mitchell River water development and alteration of natural flows in the Mitchell River Basin has been extremely limited, helping to maintain the natural integrity of region. The amount of water currently set aside for entitlements totals just ML, with only 30% of this amount currently being used (DNRW 2006b; p.42). The draft Water Resource Plan (WRP), however, proposes new water reserves of ML for the Mitchell River Basin. This effectively allows for a 12-fold increase in current entitlements, or a 39-fold increase in current water consumption. 4

5 Our groups strongly contend there is little justification for such a colossal increase in available water. The heavy under-utilisation of existing water entitlements suggests there is little demand for an increase in water reserves and also indicates there are currently significant constraints on water intensive industries such as irrigated agriculture. These constraints are echoed in the Government s Mitchell economic and social assessment report, which indicates a likely increase of just ML ML in water demand for the 10- year life of the WRP. This is based on clear evidence of the following: numerous significant constraints on the development of irrigated agriculture, [including] climate, lack of suitable soils near available water supplies, distance to markets, poor roads and access to farm services, and a lack of risk capital for development (p.iv); a significant contraction of the mining industry in the planning area (p.iv); and very small urban demands. The Queensland Government is also obliged under the National Water Initiative (NWI) to ensure existing allocations are used before the release of unallocated water: If a release is justified, generally, it should occur only where alternative ways of meeting water demands, such as through water trading, making use of the unused parts of existing entitlements or by increasing water efficiency have been fully explored (Section 71, NWI 2004, Italics added) Government policy in the draft WRP, however, does not the match the realities of the Mitchell plan, the conclusions of the above Government reports, or the NWI. As Table 1 illustrates, new water reserves have instead been based on the speculative demands from Community Reference Panel (CRP) members. River System Current Entitlements % Currently Used Probable Demands Stated CRP Demands Draft WRP New Reserve Total New Water Available % Increase in available water ML Mitchell ML 30% ML ML ML ML Table 1: Current and future water use in the Gulf water planning ares (key water-use rivers) Source: DNRW 2006b *Additional water use demands stated in Economic and Social Assessment Reports (DNRW 2006b) **Demands flagged by water users in CRP meetings (DNRW 2006b) These large water reserves, if converted to entitlements and used for water intensive industries such as irrigated agriculture and mining, will significantly alter the natural flows and function of the Mitchell River and its tributaries. Large-scale irrigation in particular will likely reduce wet season flows and increase dry season flows, causing major changes to natural riverine function. The use of fertilizers and pesticides in irrigation operations will also greatly increase the risk of river pollution, further threatening the health of downstream ecosystems and the availability of indigenous traditional resources. Our groups are concerned the Government has focused their environmental flows policy primarily on end-of-system mean annual discharge (MAD), rather than on a range of flow data (including median, low, high, and medium flows) and impacts on particular stream reaches. That is, the focus has been to ensure the end-of-system MAD for the entire Mitchell River system is kept below 1.5% of pre-development flows, rather than giving appropriate attention to the impact of water extraction on individual rivers or stream reaches. The Upper Mitchell River is a good example of this flaw in this current policy approach. While the end-of-system MAD for the Mitchell may be below 1.5% of pre-development flows under the proposed new reserves policy, at the Rifle Creek junction below Southedge Dam, flow reductions equate to 32% of median annual flows, 50% of 20% flows, and 25% of mean annual flows (DNRW 2006e). So while the flows for the whole of the Mitchell River Basin may remain 5

6 near natural, the impacts on this particular reach of the Mitchell River will be considerable. Local impacts have been largely ignored through this approach. The Ecological and geomorphological assessment for the Gulf and Mitchell draft water resource plans (TAP) report also casts serious doubt on the Government s reliance of MAD: in semi-arid and arid landscapes, mean annual flow is a poor predictor of flow in any one year, and more than half of all years will have well below mean annual flows. The mean flow is strongly influenced by the rare but very large flow events (p.246). The report goes on to say that water demands are likely to be small compared with average flows, but may be substantial compared with low flows, when both the ecosystem and stakeholder demands for the water are likely to be greatest (p.247). Herein lays one of our major points of contention with the large water reserves approach of the Government. The rivers of the Mitchell are tending toward highly variable tropical systems operating on a short sharp wet and long dry. All stages in the cycle of flows in these rivers are critical to the health and resilience of riverine, wetland and estuarine ecosystems, including dry season baseflows, on-set timing of initial wet seasons flows, overbank flood flows and peak flow events (to name a few). Extracting large amounts of water in these systems during any flow stage, particularly during the dry season, not only requires highly complex planning, but will disrupt the natural cycle and threaten the integrity of many water-dependent ecosystems. Our groups therefore do not consider the proposed strategic and general reserves an entirely sustainable approach to water planning in the Mitchell plan area. A truly sustainable water plan would recognise water is already being used by the environment, existing communities and industries (including fishing and tourism). It would recognise there is simply no room for waterguzzling crops and river-polluting irrigation and mining operations. A sustainable water plan would protect the natural flows of rivers and the unique wilderness values and cultural heritage of the Mitchell River Basin General Reserve of ML in Upper Mitchell River As a result of the Southedge Dam, the Upper Mitchell River is the most degraded watercourse in the plan area. The dam has impacted significantly on sediment transport, runoff and recharge processes and natural flows (Smith et al 2005, p.231). According to the Integrated Quantity and Quality Modeling (DNRW 2006e), natural flows at the Rifle Creek confluence, just below Southedge, have been reduced by 17% of mean annual flows, 21% of median flows and 46% of 20% flows. As natural flows are the surrogate for riverine ecosystem health, it follows that the Upper Mitchell River is in relatively poor natural condition. A key purpose for the WRP is provide a framework for reversing, where practicable, degradation that has occurred in natural ecosystem (Section 2, part d). One would expect the Upper Mitchell River, given its condition, would be the target for such a framework. The draft WRP, however, does precisely the opposite it provides a framework for the further exploitation of this river system by allowing for a new water reserve of ML. This will see a further reduction of flows to 25% of mean annual flows, 32% of median annual flows and 50% of 20% flows (DNRW 2006e). According to the Ecological and geomorphological assessment for the Gulf and Mitchell draft water resource plans: any impediments in the Upper [Mitchell] Reaches will potentially have major impacts on all downstream ecosystems. Since flow in the lower reaches is often very small to negligible, any impedance in the upper reaches will hinder the ability of the bed sands to recharge. Reduction in flow and bed sand recharge in downstream reaches may have severe implications for all ecosystems given the prevailing high temperatures the 6

7 groundwater/bed sand systems are likely to increase. The higher salinities induced by this evaporation and subsequent concentration could have substantial impacts on any groundwater dependent ecosystem associated with the system (Smith et al 2005; p.223) This is a highly unacceptable and unsustainable facet of the draft WRP. On top of this, the land between Southedge Dam and the Riffle Creek confluence is owned by George Quaid (formerly Southedge Daintree Pastoral Company Pty Ltd), the proponent of Northedge Dam and the Southedge Lakes Resort, which means the ML is for a single private interest. The Mitchell draft water resource plan overview report and draft plan claims this water would supply supply an urban community or an equivalent agricultural or industrial development in the area (p.18), presumably for the Southedge Lakes Resort. This is entirely inconsistent with the Far North Queensland Regional Plan 2010, which specifically excludes the development project and the Wangetti to Southedge access road infrastructure that is key the viability of the project (FNQRPAC 2000). Key recommendation: Omit ML in Upper Mitchell River from Draft WRP ML in the remainder of plan area Consumptive water use in the Mitchell River Basin is limited, with just 5920 ML allocated, of which only 30% is currently used. This low amount of water development, aside from the Southedge Dam, has greatly helped to maintain the health of wetland, riverine and estuarine ecosystems in the plan area. The draft WRP, however, features new water reserves totaling ML for the area outside of the Upper Mitchell River a substantial increase in water available for water intensive industries such as irrigated agriculture and mining. This policy is in direct conflict with the information produced in the Gulf and Mitchell agricultural land and water assessment report and the Mitchell draft water resource plan economic and social assessment report: the Gulf and Mitchell agricultural land and water assessment report remarks that the soils in the area limit the potential agriculture, due to potential salinity, sodicity, erodability and poor drainage (DNRM+W 2004; p.29), while the Mitchell draft water resource plan economic and social assessment report observes that the drivers for developing irrigation in the plan area are weak (p.20), estimating likely demand for the life of the 10-year plan to be just ML: 2000 ML for agriculture, ML for mining and 150 ML for urban. Given the under-utilisation of existing entitlements, the clear lack of the demand for large volumes of water, the undeniable constraints to irrigated agriculture and the importance of natural flow regimes to the riverine health and function, we strongly advocate a cap on water entitlements and reserves at existing levels. Key Recommendation: Cap water entitlements and reserves at existing levels for the remainder of the plan area 2.2 Consultation Process General Concerns Community consultation is a vital component of water resource planning, helping to ensure community opinion and feedback into policy is integrated into the draft WRP. Our groups maintain that there is much room for improvement in this process. In the Mitchell CRP our representative found that from the second meeting onwards, input form the CRP was 7

8 focused on commenting on the CRP Report. This report was supposed to explain how this input had been taken into account in drafting the plan. The most important section of the report was never shown to the CRP (even in draft form) so although CRP members could comment on how their input had been recorded, they were unable to comment on how their input had been interpreted to influence the WRP. We contend that genuine community consultation requires transparency in the process of translating CRP concerns and comments for the Minister. The focus on perfecting the earlier sections of the CRP report were a poor substitute for discussion on how our input would be taken into consideration in the actual WRP. The most serious breach of transparency in the process was the appointment of the Australian Groundwater and Environmental Consultants Pty Ltd (AGE) to conduct the desktop groundwater assessment of the Mitchell and Gulf plan areas. The desktop assessment was commissioned by NRM with no reference to the CRP and presented to the third meeting. No explanation was given as to why it was commissioned and how the consultants were commissioned, or indeed, appointed. The main point of the AGE Report appeared to question many of the findings of the TAP report pertaining to Subartesian Water Resources. These findings had not been questioned when the TAP report was initially presented to the CRP. AGE is the same consultant commissioned by the Southedge Daintree Pastoral Company Pty Ltd to prepare a submission in relation the Southedge Lakes Resort development in the Upper Mitchell, which included advocating for the Northedge Dam. Surprisingly, the Minister found no reason to be concerned over this conflict of interest (Letter to QCC and MRCCC, 10 January 2006) We also contend that stakeholder representation was weighted well in favor of consumptive water users in the Mitchell CRP. While conservation groups are legitimately viewed as a sector, we are effectively representing the integrity and health of the natural environment and a whole spectrum of species without a voice. This approach, therefore, risks marginalising the environment as just another stakeholder, when a healthy environment and ecosystem resilience as championed by our groups in fact underpin a thriving community and economy. We therefore encourage much greater conservation representation on future CRP s. A possible way to balance the CRP could be to have greater diversity of conservation sector interests by including regional, state and national groups (in this case CAFNEC, QCC, TWS and ACF). It could also be said the Mitchell River Basin and the fate of its wild rivers, given their national significance, is of concern not just to consumptive and non-consumptive water users, but all Australians. Greater weight must therefore be given to the national imperative of protecting our national heritage Indigenous Representation Indigenous people have a long history of caring for country in the Mitchell region, with strong spiritual and cultural connections with the land and water. With such a strong link to the water resources and important role in the health of this unique Mitchell River country, it is imperative indigenous people are extensively consulted over the draft WRP. Although consultation has occurred with the Kowanyama community, we are concerned other Indigenous groups and communities have not been adequately or appropriately engaged. Given there are native title determinations over much of the land from a range of groups (including Sunset Yalanji, Kunjen and Yir Yiront, Kunjen, Barbaram, Bulimba, Kuku Djungan) it is vital that the Government place greater emphasis on, and devote more resources to Indigenous consultation, particularly with communities outside of Kowanyama. It is also possible that the Government is preemptively affecting Native Title rights by reserving such large amounts of water. 8

9 We strongly feel that Indigenous consultation following the release of the draft WRP, as the Government intends to do, does not equate to appropriate recognition of Indigenous rights and interests, nor does it acknowledge the critical role of Indigenous people in ongoing management of water resources for cultural, environmental and economic purposes. We also contend that the failure to effectively engage Indigenous peoples has resulted in the lack of a comprehensive cultural inventory/study of the plan area making it difficult for the Government to protect the cultural values of the plan area, as outlined in the draft WRP (Section 13). We encourage the Government to conduct such comprehensive cultural inventory/study, in partnership with Indigenous peoples of the Mitchell River basin region to ensure important cultural values are not overlooked in future planning decisions. Key recommendation: Review Government consultation processes with Indigenous people and communities and undertake a comprehensive cultural survey of the plan area to identify cultural values in water and culturally significant sites, as appropriate. 2.3 Mitchell as a Wild River A Wild River is a free flowing river. It is a river where the natural ecological, hydrological and geomorphic processes have not been altered by modern development, maintaining healthy ecosystems and the rivers important aesthetic, cultural, commercial, and recreational values. Queensland s Wild Rivers Act 2005 the first of its type in Australia sets out to preserve the natural values of wild rivers. So far, the Government has committed to protecting 19 Wild Rivers in Queensland, four of which are in the Gulf of Carpentaria: Settlement Creek, Staaten River, Morning Inlet and the Gregory River. Our groups maintain that the Mitchell River and its tributaries (excluding the Upper Mitchell), as free flowing, healthy rivers, of comparable ecological condition to the soon to be declared Wild Rivers of the Gulf country, are also worthy of Wild River listings under the Wild Rivers Act We are greatly concerned the Government appears to be of the attitude that these rivers can be developed for agriculture and mining as a balance to the (near) declaration of the four Gulf Wild Rivers. We strongly oppose this approach. Water planning should not be about balancing the needs of every stakeholder that raises their hand for an allocation of water. Some interests, such as the irrigated agricultural industry, are simply incompatible with the healthy function of the Mitchell River Basin landscape. The approach should instead be to set ecosystem health and the integrity of wild rivers as a baseline, then look at the types of industries that are compatible with the long-term function of these rivers (for instance ecotourism or sustainable fisheries), ruling out the non-compatible interests. The result would be a truly sustainable water plan, with little risk of encouraging the damage and repair bill of much of our southern catchments. Key Recommendation: Amend the draft WRP to ensure the Mitchell River and its tributaries (excluding the Upper Mitchell) remain eligible for Wild River listing 2.4 Overland Flow 9

10 Overland flow water (OLF) is vital to feeding the vast floodplains of the Mitchell River Basin in the wet season, supporting sustainable industries such as tourism and fisheries, as well as food production for Traditional Owners. Overland flow is also harvested by landholders for stock and domestic needs by constructing storages to capture flows. Current Government policy is to allow self-assessment of these storages for volumes below 250 ML (for any purpose ). Our groups contend this is too great an amount, with too few restrictions. The size of these storages indicates that they could potentially be used for irrigation and fodder crop production in the planning areas. Over the life of the planning scheme this has the potential to drive demand for this type of irrigation development and lead to an increase in the construction and use of OLF water storages. In addition, there is no limit on the number of storages that may be constructed in the plan area, providing a loophole for water users in areas where unallocated water has not been made available. We therefore strongly encourage the Government to adopt a precautionary approach to OLF in the WRP. We strongly recommend any new OLF developments other than stock and domestic water and of any size become Code Assessable Development under the Integrated Planning Act 1997 and allow for these developments only where unallocated water is made available. Key Recommendation: Make OLF works (other than for stock and domestic purposes) Code Assessable Development under the Integrated Planning Act Integration of Land and Water Management The draft WRP provides little integration between the allocation of water and the management of water and land use. Current Government policy is to separate water allocations from land management and require that land management is regulated though other mechanisms such as Land and Water Management Plans (LWMP s) or Water Use Plans. There are no existing LWMP s in the Mitchell plan area and there are no Water Use Plans in Queensland. The implications of this planning gap are serious; poor land management can alter natural sediment fluxes, mobilise soil-based salts, and pollute waterways with harmful agricultural chemicals, jeopardising the health of riverine ecosystems. There is therefore an urgent need to develop a trigger that requires compulsory LWMP s for all water entitlement holders in the plan area within the 10-year life of the Plan. 2.6 No Dams Policy Key Recommendation: Develop a trigger that requires compulsory LWMP s in the plan area Dams and weirs are one of the greatest threats to the health and integrity of the Mitchell River Basin and its diverse ecosystems. These types of in-stream impoundments inundate natural habitat, seriously hamper fish passage (and other aquatic fauna), greatly effect downstream flow and sediment patterns and impair downstream ecosystems. In the Mitchell plan area, the Northedge Dam has long threatened the natural flow and function of the Mitchell River (already impacted significantly by the Southedge Dam). Our groups are strongly opposed to this particularly destructive dam. 1

11 Encouragingly, the draft WRP specifically rejects these destructive proposals. We commend the government for this decisive and important policy position. We do note, however, that the draft WRP contains no specific clauses ruling out in-stream impoundments in the Gulf plan area. Given the immense natural and heritage importance of the Gulf region and the significant threat posed by dams and weirs, we strongly encourage the Government to categorically prohibit instream impoundments. Key Recommendation: Include a clause in the WRP that specifically rules out in-stream impoundments 2.7 Connected Water Resource Management Traditionally, surface water and groundwater have been viewed and managed as separate resources in Australia, with little regard for the interaction between these water sources. There is a growing recognition in the science community and in Government s, however, that much of our surface and groundwater resources are in fact connected resources. That is, some streams and watercourses exchange waters with aquifers. This requires careful, holistic planning to ensure water extraction of surface water ecosystems does not adversely impact on groundwater-dependent ecosystems, and visa versa. Connected water resource management is one of the primary objectives of the National Water Initiative (NWI): to recognise the connectivity between surface and groundwater resources and connected systems managed as a single resource (NWI 2004, clause 23x). Our groups are encouraged by the Government s single-resource approach in the draft WRP and the consistency with the NWI. 2.8 Decommissioning Southedge Dam Southedge Dam is blight of the health of the Upper Mitchell River. It has impacted significantly on sediment transport, runoff and recharge processes and natural flows (Smith et al 2005; p.231), seriously degrading this reach of the Mitchell river. Southedge Dam was illegally constructed in 1986 by private interests and since construction has been used for stock and domestic purposes only. There are currently no approvals under the Integrated Planning Act 1997 for urban, residential or tourist development that would be serviced by water stored in the impoundment. In addition, the FNQ Regional Plan does not identify this area as a future urban/ planning node within its current planning horizons. As noted earlier (3.1.1), a key purpose of the draft WRP is to provide a framework for reversing, where practicable, degradation that has occurred in natural ecosystems (Section 2, part d). This is consistent with key aspects of the National Water Initiative and the Water Act As a framework for reversing degradation, we strongly encourage the Government to devise a strategy to decommission Southedge Dam, restore natural flows to the Upper Mitchell River, and rehabilitate the cleared catchment. This is not a new or radical concept. In the US, the State and Federal Government s, recognising the enormous impact of impoundments on riverine ecosystem health, have worked together to remove over 465 dams and successfully restore environmental flows to many thirsty rivers (American Rivers et al 1999). The Queensland Government has the opportunity to again show national leadership with river protection policy by emulating the dam removal program of the US, starting with Southedge Dam. The first step should be to cancel the water license for the dam (as made possible under Section 227, part 1 of the Water Act 2000 the chief executive may cancel a water license if the 1

12 chief executive is satisfied the license should be cancelled ) and commence research into the most environmentally sensitive method of removal. Key Recommendtion: Cancel the license of Southedge Dam and begin initial assessments to decommission the dam and restore flows to the Upper Mitchell River Commence program to reverse the degradation of the Upper Mitchell River. 2.9 Nullinga Dam and FNQ Water Supply Strategy In July 2006 Premier Beattie announced $6 million for the design work of the Nullinga Dam on the Walsh River. The dam site is situated in the Barron plan area, however the implications for the riverine ecology of the Walsh River in the Mitchell plan area are substantial. If constructed the dam will significantly alter the natural flow of the Walsh River, devastating the ecosystem and have long term serious effects to the downstream area. As these likely impacts directly conflict with Section 13 of the draft WRP ( General ecological outcomes for both surface water and subartesian water ), approval of the Nullinga dam will likely require significant amendments to the WRP. According to Section 69 of the draft WRP, this will re-trigger the CRP process all over again. It is highly inappropriate that the CRP should go through such a lengthy and detailed process, only to be trampled by reckless infrastructure plans in the Barron plan area. We are also concerned with the FNQ Water Supply Strategy and its interaction with the Mitchell and Barron WRP s. Currently Water Supply Strategies (WSS s) are non-statutory and do not require the same rigour of consultation and transparency as WRP s, in particular with regards to conservation sector input. We feel WSS s are increasingly used as tools to legitimise large-scale infrastructure, as has occurred in South-East Queensland. It is our understanding that the Government is considering making WSS s a statutory mechanism. We strongly oppose such a move as it would further legitimise the construction of large-scale impoundments such as the Nullinga Dam and undermine the WRP process. Key Recommendation: Do not allow for the construction of the Nullinga Dam under the Barron Water Resource Plan. 3 Resource Operations Plan Recommendations Our groups recommend the Government consult closely the Ecological and geomorphological assessment for the Gulf and Mitchell draft water resource plans to inform the Resource Operations Plans. The most important conditions on licenses we see are: Use of the multiple wetting approach (Smith et.al 2005; p ) to ensure sufficient flows from the initial flood pulses are allowed through the system; Use of the habitat diversity threshold approach (Smith et.al 2005; p ) to ensure habitat at all stream levels (including overbank) is maintained; No allowance for extraction in dry months (when the integrity of water refugia (such as waterholes) is critical to the ongoing survival of a range of fauna and flora); No unallocated water to be used for large scale irrigated agriculture: and Detailed local surveys and plans to ensure the license is catered to the local conditions and ecological requirements. 1

13 4 References American Rivers, Friends of the Earth & Trout Limited, Dam Removal Success Stories. ( Department of Natural Resource, Mines and Energy (DNRM+E), Gulf and Mitchell agricultural land and water assessment report. The State of Queensland, Brisbane. Department of Natural Resource and Water (DNRW), 2006a. Mitchell draft water resource plan overview report and draft plan. The State of Queensland, Brisbane. Department of Natural Resource and Water (DNRW), 2006b. Gulf draft water resource plan economic and social assessment report. The State of Queensland, Brisbane. Department of Natural Resource and Water (DNRW), 2006c. Gulf draft water resource plan community reference panel report. The State of Queensland, Brisbane. Department of Natural Resource and Water (DNRW), 2006d. Gulf and Mitchell report on the subartesian water resources in the Gulf and Mitchell water resource plan areas. The State of Queensland, Brisbane. Department of Natural Resource and Water (DNRW), 2006e. Gulf draft water resource plan Integrated Quantity and Quality Modelling. The State of Queensland, Brisbane. Far North Queensland Regional Planning Advisory Committee (FNQRPAC), Far North Queensland Regional Plan. The State of Queensland, Cairns. Smith et. al. (Technical Advisory Panel - TAP), Ecological and geomorphological assessment for the Gulf and Mitchell draft water resource plans. The State of Queensland, Brisbane. National Water Initiative 2004 (Commonwealth of Australia, QLD, NSW, SA, VIC, ACT, NT) Water Act 2000 (QLD). Wild Rivers Act 2005 (QLD). 1