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Ref: RH/SF/GG23023

4 May 2023

Department of Regional Development, Manufacturing and Water
Chief Executive
Water Services Northern Region
Attention: Manager Water Planning and Science
PO Box 5318

TOWNSVILLE QLD 4810
 
By Email: wpburdekin@rdmw.qld.gov.au

Dear Ms Minnesma

Re: Input to Replacement of the Water Plan (Burdekin Basin) 2007

AgForce Queensland Farmers Limited (AgForce) is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool & goat producers. The cane, beef, broadacre cropping and sheep, wool & goat industries in Queensland generated around $10.4 billion in on-farm value of production in 2021-22. AgForce’s purpose is to advance sustainable agribusiness and strives to ensure the long- term growth, viability, competitiveness and profitability of these industries. Over 6,500 farmers, individuals and businesses provide support to AgForce through membership. Our members own and manage around 55 million hectares, or a third of the state’s land area. Queensland producers provide high-quality food and fibre to Australian and overseas consumers, contribute significantly to the social fabric of regional, rural and remote communities, as well as deliver stewardship of the state’s natural environment.

Burdekin Cane & Agriculture Organisation Ltd is an organisation tasked with representing the interests of our members who collectively supply approximately 1.3 million tonnes of sugar cane to our local miller, Wilmar Sugar International. BCAO’s purpose is to actively engage on our members’ behalf with policy and political advocacy both state and federal. We exist to promote a positive image for agriculture in our region and to provide professional grower specialised services for our members.

Introduction

Thank you for the opportunity to provide input to the replacement of the Water Plan (Burdekin Basin) 2007 (‘the Plan’) and water management within the plan area. The Public Notice and Statement of Proposals identifies a number of issues and risks that need to be addressed in a replacement plan.
AgForce holds to the following general water policy principles:
  1. Water is a vitally important resource and needs to be managed to secure its environmental, social and economic values.
  2. To sustain access and associated ecosystems, planning and management should avoid risks to the long-term sustainability of water resources.
  1. AgForce supports the cost-effective use of objective, scientific information to guide water resource management decisions, including the release of unallocated water and protecting the integrity of water entitlements.
  2. The water resource planning process in Queensland is supported as it sets up a system of entitlement security, enables tradability and is designed to plan for sustainable management to meet future consumptive and environmental water requirements.
  3. Where water resources are at risk of over-use, there may be a need to manage demand through the use of targeted regulation (noting the primacy of basic stock and domestic (S&D) rights and that planning and management decisions should be transparent, efficient and equitable).
This submission will focus on issues raised as important by our members in the plan area. A key issue identified by the AgForce Cane Limited (ACL) and the Burdekin Cane & Agricultural Organisation Limited (BCAO) producing members, is rising groundwater and associated salinity in the Burdekin Haughton Water Supply Scheme (BHWSS). This issue needs to be addressed urgently by government and industry stakeholders, both within this water planning process and outside of it and ACL and BCAO calls for it to be more clearly included in the Plan review process.

Rising Groundwater in the BHWSS

The statement of proposals identifies that rising groundwater in the BHWSS, is threatening the productivity and sustainability of agriculture across the region. It references working in partnership with local users and Sunwater on responses and undertaking socio-economic assessments, groundwater modelling and water quality sampling to better understand the issues.

It also notes the Sunwater Rising Groundwater Mitigation Project to investigate and deliver off-farm actions. ACL is now part of the Customer Advisory Committee (CAC) informing this work and seeks a seat on any local and catchment-wide Stakeholder Advisory Groups, as flagged to AgForce members by Patrick Levings, Team Leader, Water Planning and Science, North Region. Local technical agronomic expertise would also be of benefit to the Group, with representation also for BCAO.

Despite the extensive efforts of BHWSS cane producers over many years to minimise deep drainage, it has been estimated that about 3,000-4,000ha of the BHWSS area has groundwater within 1.5 metres of the surface, varying with wet season conditions.
ACL and BCAO is developing a number of concurrent solutions to the rising groundwater issue, that have to be applied on an area by area, farm by farm basis, including:
  1. Dewatering – eg, from a bore field near the Mulgrave Road into the Burdekin River during high flow conditions (eg, very high dilution rates of 15ML/day into a 2,500ML passing flow) to very effectively dilute the salinity to match the receiving environment. This dewatering requires automated water quality monitoring (only nutrients and chemicals) and cease flow provisions to avoid any risk of adverse environmental impacts. Environmental managers and regulators like DES need to be involved in developing this solution. There is a need for public funding for required infrastructure and ongoing pumping and monitoring costs. Up to date government water monitoring data should be used to inform this option. Past dewatering trials have shown dewatering is able to stop the increase of groundwater levels and this effect, more widely achieved, could propagate across the affected area, not just in the vicinity of the bore field itself and thereby a desalination plant is not required.
  1. Conjunctive use of less saline groundwater with surface water supplies – with the resulting water quality such that no adverse effects occur on the receiving soil structure and productive capacity. Pumping costs may impact on the viability of this option in some circumstances and on its own, conjunctive use will not suffice to deal with the rising groundwater issue (per Dr Roger Shaw’s 2014 report).
  1. Sunwater infrastructure improvement, maintenance and management – including a) targeted channel sealing/lining (eg, coinciding with the ‘red’ soils, including the Baratta main channel – Haughton and Upper Haughton), b) addressing the Mulgrave balancing storage (copper dam partition) and c) dewatering of Gladys Lagoon and supplement pipeline, with a dropping of water levels in the interim by a minimum of 2 metres. The funding for off-farm works ($12.5M + $12.5M) could also be applied to the dewatering pilot point 1 above.
  2. On-farm actions (including channel and recharge pit sealing/maintenance, improved farm furrow design/bankless technology and irrigation practices) to minimise deep drainage. Options must be looked at case by case with the producer and be economically viable to implement with some support (funding and expertise) likely needed to be provided in implementation.
  3. Examination of Sunwater pricing structures (and any relevant plan or subsidiary document settings) to incentivise groundwater use. This examination to include the balance of fixed to operational charges to encourage groundwater use (lower Part A charge). This may involve a specific direction from the Minister to the QCA to examine pricing influences on rising groundwater outcomes.
ACL has been engaging with Departmental officers and other Burdekin stakeholders in relation to identifying an effective set of interventions to progress action on this long-standing issue that is becoming increasingly critical. We welcome the efforts of Department staff to engage positively on this issue and collaborate with industry in achieving the desired outcome of a sustainable irrigation system and environment.

While not directly a planning issue, water pricing structures are acting as an impediment to on-farm efficiency and groundwater mitigation. This issue should be considered within subsidiary document settings and through the QCA process. ACL and BCAO notes that it is also proposed to amend the Water Management Protocol, Resource Operations Licences and Distribution Operations Licences (detail conditions on WSS operators), Operations Manuals (day to day scheme rules) and Water Entitlement Notices as necessary during the plan replacement process. This is supported.

Further, third party retailers who impose fines and restrictions upon irrigators perversely work against the reversal of rising groundwater. While potentially not an issue that can be addressed in the Plan itself, it should be examined in the context of incentives to lower groundwater in the BHWSS.

Future Water Demand

As a general guiding principle, AgForce is supportive of the release of unallocated water that can be made available for agricultural purposes such as cane production without compromising the environment or the supply to existing water users. AgForce supports governments investing in the investigation of strategic options to improve water security and inform future priority water proposals in the Burdekin and Central Queensland regions. This includes the Big Rocks Weir proposal.

However, ACL and BCAO members in the BHWSS are sceptical of the benefits to be brought by the proposed raising of the Burdekin Falls dam wall by 2 metres. This is driven by the relatively low yields (150,000ML of saleable water from a 450,000ML volume) for the area of land to be inundated and the associated loss of water through evaporation.

The dam does already attenuate the magnitude of large flows, with implications further down the system including the removal of natural flows/flushes into the lower Burdekin and impacts on ground water replenishment, sand bar clearance, coastal formation and environmental outcomes. Provision of flows for existing water users and the environment, including the Great Barrier Reef, is essential.

Further, it is thought that the funding currently being put into feasibility studies of a wall raising could be re-directed, in the first instance, to address the existing issues with the BRIA scheme, predominantly as investments into addressing rising groundwater.
 
Recovering of deep drainage losses would contribute significantly to water availability without the need for additional infrastructure construction and maintenance costs, some of which may fall on existing water users. Also, the costs of safety upgrades are expected to at least partially fall on water users.

Inclusion of Additional Areas

While both ACL and BCAO agree with an update to the Plan, there is a requirement to demonstrate the validity of the inclusion of Black River and Townsville and Crystal Creek into the Burdekin Plan. This is in acknowledgement of the fact that water plans are a key part of the Queensland Government’s approach to water management. These Plans are intended to strike a balance between water needs for industry, irrigators, town water supply, social and cultural values and the environment across our state. However, we need to be mindful of and responsible in, not transferring costs and environmental impacts across catchments.

Indigenous Cultural Water

ACL and BCAO endorses the following policy relating to indigenous cultural water:
  1. We support stakeholder consultation in water resource planning and management, including of Indigenous peoples.
  2. We support the provision of water for Indigenous use, but only where this does not result in third party impacts to existing entitlement holders, including the environment.
  3. We support the use of existing held and planned environmental water entitlements for the co- benefit of Indigenous cultural water use.
  4. We support the use of existing market mechanisms to acquire Indigenous water entitlements from willing sellers for contemporary economic use.
  5. Allocation of water within unallocated reserves (including strategic, general and Indigenous) should be equitable across stakeholder groups and with a consistent methodology that is applied across the state.
  6. We acknowledge that the ownership framework for Indigenous water entitlements for contemporary economic use is a matter for governments and Indigenous peoples however, additional restrictions to Indigenous entitlements that unnecessarily constrain trading should be removed.
  7. If the above framework were adopted, the current hierarchy and security of water entitlements, as enshrined in state legislation, would be respected and therefore unaffected.
We support the government incorporating the above considerations as it seeks to incorporate indigenous cultural water matters into a revised Plan.

Climate

According to the statement of proposals, climate projections for the Plan area predict an increase in evaporation rates, potentially resulting in increases to water consumption and losses from storages and may reduce persistence of water holes.
Water Allocation Security Objectives (WASOs), currently stated in Schedule 6 of the Plan, were established to protect the rights of water allocation holders across the Burdekin Basin. WASOs are proposed to be reviewed and contemporised to maintain security of water allocations. In addressing climate change effects significant impacts on the security of entitlements should be avoided.

Conclusion
ACL and BCAO supports the water planning process and the active consultation of key stakeholders, including ACL and BCAO, in identifying and satisfactorily addressing issues such as rising groundwater in the Burdekin Plan area.
 
ACL and BCAO seeks representation on local and catchment wide Stakeholder Advisory Groups to be established as part of the Plan review process.
For any follow-up questions or engagement about this submission, please contact Sam Forzisi, AgForce Cane Policy Director, via email: forzisis@agforceqld.org.au or by calling (07) 3236 3100.

Yours sincerely
 
Russell Hall
President
AgForce Cane Ltd
Charles Quagliata Chairman Burdekin Cane &
Agriculture Organisation Ltd