1. The Environment Institute Where ideas grow Chewing over the CEWH Mike Young Executive Director, The Environment Institute

2. The Environment Institute Life Impact The University of Adelaide Some design principles and concepts Hydrological integrity – Most interception is included in the SDL algebra Equitable risk sharing with Environment – Conveyance reserve specified separately – Environment gets an entitlement for freshes and some overbank work Maximum subsidiarity – Uniform definition of SDL across the Basin built around a 114 year average less 3% allowance for adverse climate change – But CEWH takes a centralised view of the world.... Robust planning as the “premier” control instrument – Entitlement and allocation system sits under the plan

3. The Environment Institute Life Impact The University of Adelaide The LTASDL Long Term – Hides climate change signal Average – Mean not mode or median Sustainable – Not defined as a limit Don’t compromise key environment or productive base Diversion – Not allocated – Not “used” Limit Not a share of inflows Not a seasonal resource allocation

4. The Environment Institute Life Impact The University of Adelaide Section 23 23 Long ‑ term average sustainable diversion limits (1)A long ‑ term average sustainable diversion limit for the Basin water resources, for the water resources of a particular water resource plan area or for a particular part of those water resources must reflect an environmentally sustainable level of take. (2)A long ‑ term average sustainable diversion limit for the Basin water resources, for the water resources of a particular water resource plan area or for a particular part of those water resources may be specified: (a)as a particular quantity of water per year; or (b)as a formula or other method that may be used to calculate a quantity of water per year; or (c)in any other way that the Authority determines to be appropriate.

5. The Environment Institute Life Impact The University of Adelaide “Take” not “net use” environmentally sustainable level of take for a water resource means the level at which water can be taken from that water resource which, if exceeded, would compromise: (a)key environmental assets of the water resource; or (b)key ecosystem functions of the water resource; or (c)the productive base of the water resource; or (d)key environmental outcomes for the water resource. Not “allocated” Little concept of optimal storage management

6. The Environment Institute Life Impact The University of Adelaide Conveyance Reserve Conveyance water is water in the River Murray System required to deliver water to meet critical human water needs as far downstream as Wellington in South Australia. Not to barrages No requirement to have a minum annual flow to the sea

7. The Environment Institute Life Impact The University of Adelaide South Australia – Tier 1 Flow SA has an administrative choke Storage options, interstate trade & environment flow management is severely constrained

8. The Environment Institute Life Impact The University of Adelaide Policy Commitment “Only buy water from willing sellers” 50.Governments are to bear the risks of any reduction or less reliable water allocation that is not previously provided for, arising from changes in government policy (for example, new environmental objectives). In such cases, governments may recover this water in accordance with the principles for assessing the most efficient and cost effective measures for water recovery. Commitment to pay compensation for new policy CEWH has a big role to play but.... (3,000GL)

9. The Environment Institute Life Impact The University of Adelaide What is the role of the CEWH? environmentally sustainable level of take for a water resource means the level at which water can be taken from that water resource which, if exceeded, would compromise: (a)key environmental assets of the water resource; or (b)key ecosystem functions of the water resource; or (c)the productive base of the water resource; or (d)key environmental outcomes for the water resource. Any water held by the CEWH may be outside the SDL Only way to fix an error is to redefine the SDL

10. The Environment Institute Life Impact The University of Adelaide A legislative dilemna If the commitment is to a Robust Plan the Water Act would be amended before a draft plan is released!! – Provide for Tier 1 conveyance and minimum flow to barrages – Convert SA’s entitlement into a share of inflows – Establish a proper Basin Bulk Water Entitlement System

11. The Environment Institute Life Impact The University of Adelaide Main types of Water Regulated Unregulated Groundwater – Connected to river – Disconnected but recharging – Fossil Overland flow Interception Why not define “ALTSDL” differently for each type of system

12. The Environment Institute Life Impact The University of Adelaide Regulated water guidelines Set aside conveyance water under – T1 – conveyance to end possible – T2 – not enough water for 100% conveyance – T3 - Exceptional circumstances After conveyance reserve satisfied, share next slice of inflows between Environment and all other users in accordance with the size of their entitlement – Define sharing limit as amount when all entitlement holders have 100% allocation – Define size high security pool as moving average of, say, last 10 years allocation to that pool – Convert non-conveyance rules based water to an entitlement. – Move to continuous accounting everywhere Allocate last tranche to the environment under a rules based regime.

13. The Environment Institute Life Impact The University of Adelaide Unregulated water guidelines Require plans to allow shepherding Define trigger points Allow trigger points in licences to be raised and lowered Change with compensation may be required in some systems – Role of environmental water manager is less tactical and more infrastructure rather than volume based

14. The Environment Institute Life Impact The University of Adelaide

15. The Environment Institute Life Impact The University of Adelaide

16. The Environment Institute Life Impact The University of Adelaide I nterception and overland flow guidelines Better to be approximately right than comprehensively wrong Licence separately Introduce an offset rule – Buy and surrender an entitlement equivalent to the expected mean impact Re-issue entitlement when interception licence is surrendered.

17. The Environment Institute Life Impact The University of Adelaide Connected Groundwater Location matters May need many zones within each region Enable tagged transfer to river when permission to extract is close to it. Holding an environmental entitlement may not work if there is no where to allocate it Is the CEWH really going to buy this water?

18. The Environment Institute Life Impact The University of Adelaide Three Questions 1.Is it possible to change the Act? 2.Should this occur before the draft plan is presented or proposed as part of the plan? 3.Would the Basin be better served if with a plan that proposes to buy a share for the environment and build a structure that makes this the prime management instrument?

19. The Environment Institute Where ideas grow www.adelaide.edu.au/environment www.myoung.net.au