WaterTaxGrab.com  > > NEW GOVERNMENT FEES AND CHARGES, AND ‘RED TAPE'

Agriculture in Manjimup and Pemberton using farm dams is the 'food bowl of the South West,' with production valued at over $100 million, twice the production of the Ord River district.  Self-supply water users in the South West are targeted for a water tax grab while the Ord River irrigation scheme is being given a $415 million subsidy. This web site provides resources to fight the water tax grab.

News: $29 MILLON WATER TAX GRAB HITS FARMERS BUT SPARES PERTH GARDEN BORES

CAMPAIGN 2009-2012

PAST CAMPAIGN 2007-2008

May 2009: Treasurer, Troy Buswell and Minister for Water, Dr Graham Jacobs announced an ‘Inquiry into Water Resource Management and Planning Charges’ to be conducted by the Economic Regulation Authority; the Inquiry covers both water licence fees and water resource management charges. The 'tax grab' Inquiry has been initiated before the Water Resources Management Bill, determining the scope of potential fees and charges, is either public, debated or enacted by State Parliament. We requested the Inquiry be halted until there is the necessary Water Resources Management Act re-defining regulated water resources in Western Australia and the extent of regulation. But no, Mr Buswell, Dr Jacobs and the Economic Regulation Authority (ERA) are pushing on with the 'tax grab' inquiry.

Download RECENT SUBMISSIONS made by Manjimup and Pemberton Landowners:

26 February 2010 - Submission to the ERA Inquiry into Water Resource Management and Planning Charges in response to Draft Report

15 February 2010 - Submission to the Department of Water on pending Water Resources Management Bill

31 August 2009 - Submission to the ERA Inquiry into Water Resource Management and Planning Charges

12 June 2009 - Submission to the ERA Inquiry into Water Resource Management and Planning Charges

ACTION: 4 November 2010 Download and read the ERA second 'Draft Report' of the ‘Inquiry into Water Resource Management and Planning Charges’ and the planned $29.2 million water tax grab. 

Information: Example of PAST submission made by growers/producers in Manjimup and Pemberton.

Inquiry into Water Resource Management Charges
Economic Regulation Authority

Email:
publicsubmissions@era.wa.gov.au
Fax: (08) 92131999 

We are a self-supply water user in agriculture; our private investment in water infrastructure is in contrast to irrigation cooperatives which are subsidised by the public. The Draft Report of the Inquiry into Water Resource Management and Planning Charges (December 2009) has identified $29.625 million of the annual budget of the Department of Water for cost recovery from water users. This amount for cost recovery is five times the $5.8 million cost recovery sought by the Department of Water in 2007–2008, which was twice disallowed by State Parliament because the associated fee structure was irrational and unfair. The previous flawed attempt at cost recovery was particularly unfair to self-supply water users compared to irrigation cooperatives, water supply utilities and large users in the resources sector.  

We are not going to be victims to recover costs for a bloated Department of Water with a budget of $93.57 million and 601 FTE in 2009-10 that doesn’t supply a drop of water to our business and generally disregards the views of self-supply water users. At the same time as these attempts to cost recover $30 million for the Department of Water, the State and Commonwealth Governments are providing $415 million in further public subsidies to the relatively unproductive Ord River irrigation scheme. These are absurd policy contradictions and we are not going to be victims of bad Government policy by being subject to harsh fees and charges because we provide our own water supply to conduct efficient agriculture.

We submit the following in relation to services relevant to self-supply water users: 

1.   Water is vital to all communities and most economic activity in WA. The State Government should fund water resource management and planning from the consolidated fund derived from State and Commonwealth taxes we pay. Specific charges imposed on water licence holders for ‘water resource management’ (including planning) are opposed. Any attempt to apply water resource management and planning charges is likely to be fundamentally flawed because of diversity between water resource regions, uses and users in WA. There is no simplistic revenue raising ‘formula’ for water resource management charges that can be applied rationally and equitably across all water resources and use regions. The State Government should stop wasting taxpayer funds on consultants in pursuit of formula for water resource management charges.

2.    Where an allocation of or entitlement to water is sought, an ‘Application Assessment Fee’ could be required which reflects the complexity of Department of Water assessment for the particular dam or bore and water resource; with the applicant to receive a quote for assessment related to hours of service and fee per hour, and be able to appeal to a senior officer of the Department if the quote is unacceptable. The cost incurred by the Department of Water for assessment of an application for an allocation (new licence) must not be spread across existing water licence holders by inflating the ‘Water Licence Fee’ for administration of a licensing database. Such cross-subsidy was the fundamental flaw in the previous water licence fees twice disallowed by State Parliament.

3.    Upon allocation of water, a ‘Water Licence Fee’ could be required which reflects cost recovery of administration of a licensing database. The licence holder could opt to pay either annually or 10 years in advance (analogous to a drivers licence). The Drivers licence fee is an established benchmark for administration of a licensing database and is either $36.60 annually or $116 for five years in advance. A ‘Water Licence Fee’ at a higher cost than a Drivers licence fee is opposed.

4.    A ‘Licence Renewal Fee’ at end of licence duration (usually 10 years) could be required; this would re-present the ‘Water Licence Fee’ (analogous to the renewal of a Drivers licence). If a relevant Water Allocation Plan identified a particular water resource was over-allocated because of diminished resource, a reassessment could be required and be subject to the same transparent fee process as an initial application.

5.    An ‘Arbitration Fee’; in the rare event a dispute arises between water users, the water users could seek conciliation and arbitration services of the Department of Water and the Department apply a reasonable charge to recover officer’s time for conciliation and arbitration. 

Yours sincerely


Manjimup and Pemberton Landowners’: are an association of representatives of agricultural sectors in the Manjimup and Pemberton area using water from the Warren and Donnelly River catchments captured in private dams. Our ‘self-supply’ water user group convened in March 2007 to respond to water reforms proposed by the previous State Labor Government; the initial challenge was responding to harsh water licence fees which were defeated in State Parliament in November 2007 and April 2008.  Email: contact@watertaxgrab.com Phone: 97724098

Our Policy Position: Manjimup and Pemberton Landowners support a reasonable water licence application fee to reflect time required to assess new licence applications, and thereafter a licence database administration fee equivalent to that for a driver’s licence fee. Proposed water resource management and planning charges aren’t acceptable, such costs of public service should be met by the State Government Consolidated Fund, derived from GST and other taxes paid by farming families and agricultural businesses. Whatever fees and charges are introduced must be applied equitably across all water users and water resource areas in Western Australia.


WaterReform.net  > > PROPOSED WARREN-DONNELLY WATER ALLOCATIONS

The Warren-Donnelly Surface Water Allocation Plan issued by the Department of Water for public comment doesn’t provide sufficient water for agriculture in terms of security for existing water users in agriculture and for potential growth in agriculture in the ‘food bowl of the South-West’. Surface water licence holders are encouraged to make submissions on the Plan by 6 September 2010.

Information: See table on Warren Donnelly Surface Water Allocation Plan: Streams and sub-catchments important for Agriculture comparing allocations by Department of Water compared to allocations proposed by Manjimup and Pemberton Landowners.

Information: Download SUBMISSION made by Manjimup and Pemberton Landowners on 6 September 2010

ACTION:  A template submission is available below for download and use. Submissions must be made to the Department of Water by 6 September 2010. 

By Email to: allocation.planning@water.wa.gov.au ; save the downloaded file to a convenient folder, browse to and open, add your address, date, and type your signature below Yours Sincerely, save file and attach to email to allocation.planning@water.wa.gov.au , in the Subject line use ‘Submission on the Warren-Donnelly Surface Water Allocation Plan’ so they know what the email relates to, and refer to the attachment in the body of the email. 

By Post to: the address in template letter after adding your details, printing and signing. 

Please take action on this issue, and advise others with a surface water licence to make a submission. There are 484 surface water licence holders subject to the Allocation Plan. If the allocation of water to agriculture is not increased, consumptive pools loom as a threat in most sub-catchments, with intrusive regulation and associated water management charges. Apathy will be costly!

South West Region
Department of Water
PO Box 261
Bunbury WA 6231 

SUBMISSION ON WARREN-DONNELLY SURFACE WATER ALLOCATION PLAN 

I am a surface water licence holder subject to the Warren-Donnelly Surface Water Allocation Plan (Allocation Plan) which is open to public comment. I do not support the Allocation Plan, it doesn’t provide sufficient water for agriculture in terms of security for existing water users in agriculture and for potential growth in agriculture in our area, regarded as the ‘food bowl of the South-West’.  

In the alternative to the low amounts of water for agriculture in the Allocation Plan, I support a greater percentage of water being allocated to agriculture, as proposed in the attached table prepared by growers/producers in Manjimup and Pemberton. The attached table proposes the water for agriculture in relevant sub-catchments in the Warren catchment be increased from an average of 20% to 37% of annual flow, and in the Donnelly catchment from 14 % to 28% of annual flow.  For major agricultural sub-catchments, the allocations to agriculture are substantially increased, for the Wilgarup River from 31% to 60% of annual flow, for Smith Brook from 30% to 60%, for East Brook from 29% to 50%, and for Manjimup Brook / Yanmah-Dixvale from 29% to 60% of annual flow. 

Further, and importantly, in supporting increased allocations to agriculture, only some of the increased provision of water should be granted to new entitlements in the first five years of the Allocation Plan; a substantial component of the allocation to agriculture should be reserved and held for review and possible allocation ten years after introduction of the Plan, and beyond. 

The reasons for my non-support of the Allocation Plan prepared by the Department of Water are:

  1. the Allocation Plan allocates too much of annual stream flow to the environment to the detriment of security of water for existing agricultural users and provision of water for growth in agriculture. A drying climate may further reduce water available for agriculture within the minor proportion allocated to agriculture compared to the environment;
  2. insufficient provision of water for agriculture could force important sub-catchments into highly regulated consumptive pools while the majority of water is allocated to the environment, in excess of what is required for the environmental health of the Warren and Donnelly Rivers;
  3. the proposed ratio of water for the environment compared to water for agriculture in the Warren and Donnelly catchments is much higher than in the Harvey, Collie and Ord irrigation systems, and compared to other water uses in the public water supply catchments in the Darling Range, where virtually no water is provided for the environment; and
  4. the State Government is proposing major changes to water legislation which could require unlicensed dams in stream headwaters, run-off dams, spring fed dams and tree plantations be granted water entitlements. It would be unacceptable that licence entitlements for these water uses be taken from the meager allocations to agriculture in the Allocation Plan.

Finally, I support the local Warren Donnelly Water Advisory Committee being granted full powers to plan and manage water allocations as a Water Resource Management Committee, provided for at section 26GK of the Rights in Water and Irrigation Act 1914. 

Yours sincerely

Download template submission (Word Doc)

Information: Reference documents on the proposed Warren-Donnelly Surface Water Allocation Plan are available at the Department of Water web site here: http://www.water.wa.gov.au/Managing+our+water/Water+planning/Allocation+planning/Warren-Donnelly+surface+water/default.aspx

Please read on >
MEDIA RELEASES

The private farm dams subject to the Government's harsh licence fees are vital habitats for water birds in the South West. In contrast, 150,000 unlicenced garden bores in Perth have depleted urban wetlands and habitat for water birds has been lost. The State Government should recognise the importance of farm dams to the environment.


BACKGROUND  

A public workshop was held in Manjimup on 27 July 2006 to discuss the Draft Blueprint for Water Reform in Western Australia published by the State Government Department of Water. The majority of attendees expressed serious concerns at the potential negative impact of the proposed reforms on landholders in the Shire of Manjimup and on the Manjimup regional economy. The Draft Blueprint for Water Reform in Western Australia is available at http://dows.lincdigital.com.au/waterreform.asp . Submissions on the Blueprint were required by 22 September 2006.  Below is a submission made by Neil Bartholomaeus of Jardee in response to the request to comment on the the Blueprint for Water Reform; over 20% of the submissions on the Blueprint were based on this submission. If you would like a Word document copy of the submission download Word document submission from here.

The summary submission on the proposed reforms is presented in the H ‘Other Comments’ section below and is:
 
The Manjimup area (being the Shire of Manjimup) will not benefit from the proposed water reforms which, if implemented, will impose unacceptable costs and deter investment. Abundant, high quality surface water provides Manjimup landholders with a range of food, wine and other production opportunities for increasingly cost competitive globalised markets. Increased Government imposed costs associated with water use will decrease competitiveness and could cause decreased food production and job losses in the Manjimup area. The proposed changes to water licensing will cause uncertainties that will deter further investment, both by existing landholders and new investors.  

The Manjimup area and community has recently been the subject of major Government imposed structural changes to the native forest based timber industry which affected local economic confidence. This further round of Government intervention, now in surface water based economic activity, will cause a further loss of confidence. 

The proposed reforms arise from problems associated with over allocated and over used water resources in the Murray Darling Basin, much of which is used inefficiently for flood irrigation of rice and cotton. These problems evoked disputes between the Governments of New South Wales, Victoria, Queensland and South Australia which, with Commonwealth conciliation, led to the ‘National Water Initiative’ which is the core blueprint for the proposed water reform in Western Australia. There are material differences between Manjimup and the Murray Darling Basin in how water is both obtained and used. In most regards, the proposed water reforms are as unsuitable for Manjimup as would be growing rice and cotton!

The ‘National Water Initiative’ and Draft Blueprint for Water Reform in Western Australia are driven by an economic rationalist water trading theory - dependent on metering and the separation of water entitlement from landholding - which would be totally impractical in the privately constructed dam systems in Manjimup which are not interconnected in a manner which would enable water trading on the scale proposed. 

A well attended public workshop held in Manjimup on 27 July 2006 to discuss the Draft Blueprint for Water Reform in Western Australia overwhelmingly rejected the proposed reforms, preferring the present system of licensing and self management of water resources in the Manjimup area. 

SUBMISSION ON WATER REFORM IN WESTERN AUSTRALIA (2006)

Feedback on a Draft Blueprint for Water Reform in Western Australia  

(A) CHANGING THE WATER ENTITLEMENTS SYSTEM 

1 What are your views in relation to statutory water management plans as the basis of new water access entitlements? 

Statutory water management plans are supported in general subject to the following specific concerns:

  • the Manjimup area (being the Shire of Manjimup) has been well served for 40 years by statutory based planning for the proclaimed Warren River catchment, supported by input from the Warren Water Management Area Advisory Committee. The present management system, with a substantial self management component, is in many aspects preferred to the proposed management system with impractical and costly implementation requirements upon landholders.
  • the cost of development by Government of statutory plans is high (eg $20 million per annum in Queensland) and must not be imposed on landholders and water licence holders.

2 What are your views and comments on the proposed framework for water access entitlements? 

The proposed framework for water access entitlements whereby water entitlements from private dams will be separated from access to land or land title is both confused in concept and confusing for landholders. It is difficult to understand how a water entitlement can be separated from the dam a landholder in the Manjimup area (being the Shire of Manjimup) has purposefully constructed to hold the water? Far from the increased security claimed by the Draft Blueprint for Water Reform in Western Australia, the proposed framework raises uncertainties that will deter further investment, both by existing landholders and new investors The proposed framework has it’s origins in the Murray Darling Basin channel and pipe irrigation systems supplied by huge Government constructed dams. The proposed framework may be applicable to Harvey irrigators where the Harvey, Logue Brook, Stirling and other dams, channels and other infrastructure were funded, constructed and managed by Government, and similarly at the Ord River. Indeed, the Harvey Water co-operative already applies the framework which enabled the ownership of entitlement to water to be separated from the land title and to be traded separately to the land. In contrast, the privately constructed dams on land in the Manjimup area are regarded as assets which add to the total value of the land at point of sale. While there may be a legal and hypothetical concept that the water belongs to the Crown, without the private landholder investment in dams and self-management, the water would flow into the Southern Ocean and there would be no potato, apple, cauliflower, avocado, cherry, truffle, wine, Marron, beef cattle and other production in the Manjimup area.  

There is probably capital investment of approximately $100 million in private dams in the Manjimup area. Landholders would rightfully expect compensation from the State Government if water entitlements were to be separated from this infrastructure. 

The present system of 10 year licenses under the Rights in Water and Irrigation Act 1914 ‘To Take Water’ from privately constructed dams where the ‘Location of the Water Source’ is the land title is preferred and should be maintained for the Manjimup area.  

3 Do you have any comments on the proposal for a register for water access entitlements? 

The proposal to separate water entitlements from land titles in the Manjimup area is not supported, therefore a register based on the proposal is opposed. A public and accessible register of licenses ‘To Take Water’ under the Rights in Water and Irrigation Act 1914 ‘is supported. It should be simple for the Department of Water to publish the licenses from a database onto the Internet. 

4 How should the uncertainty associated with groundwater resource management be addressed?  Would creation of different classes of licences be a good solution? 

Yes, there should be different classes of licenses to take either surface or ground water. 

5 Do you have any comments regarding what system might apply for irrigation cooperatives? 

Not relevant to the Manjimup area. 

6 Do you have any comments in relation to environmental water, indigenous access or mining? 

The present conditions on licenses ‘To Take Water’ in the Manjimup area requiring summer flows to be bypassed are supported and are necessary for environmental water. It is important to adequately provide for environmental water requirements in the Manjimup area, both to maintain stream biota and as there are economically relevant tourism activities based on viable streams during summer, especially fishing for Trout and Marron. 

(B) FACILITATING WATER TRADING 

1 Are there further issues in relation to water trading that need to be considered? 

See (B)2 below. 

2 How important is water trading likely to be in your area or industry? 

A formalised system for water trading is not important for the Manjimup area. However, the undesirable prerequisites of separation of water entitlement from land title, and enforced metering, are being proposed in the Blueprint for Water Reform. The Department of Water publication on Water Entitlements, Water Plans & Trading for Western Australia (June 2006), prepared by Victorian based consultants, specifically refers to “Restrictions to Trade in the Manjimup Area” (page 53) as (i) no metering or measurement of actual volumes taken, and (ii) the existing level of licensed development in some streams is well below the agreed allocation limit which is equivalent to around 40% of Mean Annual Flow. The paper states “With several intervening dams in between the seller’s and buyer’s dams, the lack of metering, means that there is no way of ensuring that water sold by a landowner whose dam is at the top of the catchment is actually delivered to the person who purchased that water for delivery at a lower dam.” However, the Department of Water and its consultant conclude for Manjimup that “Metering is the beginning and end of this (trading) process.”!  This is a naïve conclusion reflecting ignorance of the diverse nature of extraction of water from dams and of the inadequacy of interconnections for trading water. Many dams have multiple water extraction points and most dams are only connected by winter streams from overflow spillways. Extensive new and costly infrastructure would need to be introduced to support metered trading of water. If and when ‘sellers’ and ‘buyers’ wish to trade in the Manjimup area, it is they who should meet the cost of any interconnecting metered infrastructure. That should not be a cost that is unnecessarily imposed by the Department of Water on all landholders.

Informal arrangements are occasionally made between neighbours in the Manjimup area to supply water from their dams to assist a neighbour. Such ad hoc arrangements should be able to continue without intervention from Government. 

3 Do you have any comments in relation to speculation and monopolies in water markets? 

The Department of Water publication on Water Entitlements, Water Plans & Trading for Western Australia (June 2006) provides no comfort that Government will protect landholders in Manjimup from speculative acquisition of water entitlements under the proposed auctions or tender for entitlements. It makes reference to the relevant powers and remedies of the Commonwealth Trade Practices Act 1974 being publicised and perhaps enhanced for water holding and trading. Governments have generally failed to prevent speculation, monopolies and near-monopolies in other areas (eg land prices, fuel supplies and prices). It is unlikely either individual or collective interests in the Manjimup area would be able to stimulate the Australian Competition and Consumer Commission to take action under the Trade Practices Act if well financed corporate speculators moved to acquire water entitlements via the proposed auctions or tender for entitlements.  

(C) IMPLEMENT WATER METERING 

1 Do you have any comments about the proposed metering requirements? 

The proposed Government imposed installation, reading and maintenance of meters is unnecessary and impractical in the Manjimup area, and is opposed. There is no benefit for Manjimup landholders from mandatory metering. The high costs of metering will increase the cost of food and wine production and decrease the ability of producers to compete in globalised markets. The Blueprint for Water Reform proposes mandatory metering for new water allocations (including licenses), for existing licenses above 50 megalitres per annum and where the Department of Water deems it necessary. The Department of Water’s Directions Paper on Metering (July 2006) estimates the average costs of fitting meters to existing pipes to be between $1800 (for 50mm) and $7500 (for 200mm), and the cost of maintenance every 5 years to be between $1500 and $2500 for each meter. The landholder will also be required to pay an additional estimated ‘meter administration’ cost of $550 per meter per year, to the Department of Water. It is important to acknowledge many water licence holders in the Manjimup area have multiple points/pipes extracting water from dams to which licenses apply, thus these initial and ongoing costs would be multiplied. The Blueprint for Water Reform underestimates the extent of multiple extraction points and thus meters required per licence for surface water from private dams. Further, the cost estimates in the Directions Paper on Metering are based on experience associated with ground water extraction from the Gnangara Mound near Perth, costs may be higher 300 kilometers south in the Manjimup area. 

The Government shouldn’t take further steps to impose metering in the Manjimup area until it conducts a 3 to 5 year trial of surface water metering under Manjimup food and wine production conditions, and not until after publication of a detailed report on the trial outcomes and costs of metering for public comment.  

2 Which option do you prefer in relation to the installation of meters:

- By the user

- By the Department of Water (through third party contractors) 

There is insufficient information available in the Blueprint for Water Reform and Directions Paper on Metering to respond in an informed manner on this issue; see requirement at (C)1. above for a trial of metering in the Manjimup area.  

3 What do you believe is a fair basis upon which to recover the costs associated with meter installation? 

No substantiated basis has been made by the Department of Water to justify mandatory metering of surface water use from privately constructed dams in the Manjimup area. There is no benefit for Manjimup landholders from mandatory metering. If the State Government imposes metering, it should pay the full costs until such time as it can be clearly demonstrated metering is in the interest of Manjimup landholders.  

4 Which option do you prefer in relation to meter reading:

- By the user

- By the Department of Water (through third party contractors) 

There is insufficient information available in the Blueprint for Water Reform and Directions Paper on Metering to respond in an informed manner on this issue; see requirement at (C)1. above for a trial of metering in the Manjimup area.  

(D) RECOVERING WATER RESOURCE MANAGEMENT COSTS 

1 Do you have any comments in relation to the proposed structure and level of licence administration fees? 

The Department of Water in the Blueprint for Water Reform proposes water licence administration charges of $180 to $1720 annually for Manjimup landholders to use water from their privately funded and constructed dams. The funds are intended to fully recover the cost of licensing administration activities for 2005-2006 of $5.8 million, “for assessment of applications and licence renewals, checking compliance with licence conditions, maintaining licensing databases, appeals and community awareness.” (Blueprint page 34).  This is an unusually wide scope for ‘user pays’ cost recovery; the cost of checking compliance (or regulation) and community awareness should not be included in cost recovery as they are not directly related to licensing service provision to licensees. It is difficult to see how these costs are derived when the 2006-07 Budget papers for Appropriations and Forward Estimates state the 2005 -2006 budget appropriation for ‘Water licensing and regulation’ was $18.645 million and for 2006-2007 is $21.544 million. Even at the higher estimates of licensing costs, the 2006-07 Budget papers state, as a Key Efficiency Indicator, the “Average cost per gigalitre of water licensed” is $6164; if this is the actual cost of services then administration charges should be $6.10 per megalitre. The proposed charges, in most instances, are more than double the $6.10 per megalitre cost of licensing water.  

The level of the proposed licence fees in the Blueprint for Water Reform are related to the volume of water licensed as if there is a water ‘user pays’ principle applying. While the cost of assessment of license applications may vary depending on whether a dam-related licence was for 5 megalitres or 50 megalitres, the computerised administrative cost of licence renewal wouldn’t vary depending on licensed volume. Further, what is being renewed annually? The present licenses ‘To Take Water’ are for 10 years duration before renewal is required. The Blueprint for Water Reform claims to offer greater security of access to water for landholders yet now an annual licence renewal is proposed!   

It is reasonable there be some charge for water licence application assessment and renewal administrative services. However, the charge for the initial assessment of a licence application should be related to the water volume of the licence sought (perhaps $6.10 per megalitre of water sought), whereas the renewal fee should be a ‘flat’ fee related to the cost of computerised issue of licence renewal. If such a fee was to be charged for assessment of new licence applications, applicants would expect better service from the Department of Water than at present where it takes more than 6 months to process simple applications. A suitable benchmark cost for computerised renewal of a licence in WA would be that for a ‘Drivers Licence’ renewal, which is $107.30 for 5 years licence duration. 

(E) LAND AND WATER PLANNING FOR THE LONGER TERM PROTECTION OF AGRICULTURAL LAND 

1 To what extent do you support the longer-term protection for existing and future agricultural precincts? 

Such centralised planning by Government will be of negligible assistance to agricultural production, indeed it could lead to non-viable distortions in production. It has failed in the past and would fail again. The open market value of land for various uses, including agriculture, will determine how it is used.  

Rather than planning interventions, it is preferable Government not impose additional unnecessary regulatory ‘red tape’ and costs on producers, such as proposed in the Blueprint for Water Reform. 

2 What are your views on the methods for determining agricultural areas that require longer-term protection?

There are various State laws to protect agriculture and water from pollution; they should be vigorously enforced before additional interventions by Government. 

3 In general terms, what are your views about the five options for providing longer-term protection for agricultural land? 

None of the interventionist options are attractive, see (E)1 above. 

4 What other things could be done to ensure better integration of land and water planning? 

If the value of the land and/or profit from land use is high, then land users will pay more for the water if or when sources diminish. It is a simple cost of inputs and profit from outputs economic relationship. In the Manjimup area, much of the food and wine production is of marginal economic return because of increasing competition from lower priced produce in globalised market places, both international and local markets. The best contribution the Government could make is to not impose on producers unnecessary Government costs for vital water inputs as proposed in the Blueprint for Water Reform.  

(F) INCREASE SELF-MANAGEMENT 

1 Under what circumstances would particular models work? 

The present system of water licensing and some involvement of stakeholders (such as via the Warren Water Management Area Advisory Committee) in advice to the Department of Water is sufficient to ‘manage’ partially allocated and privately dammed surface water in the Manjimup area. There is no need for a proliferation of advisory committees, each requiring a degree of Government administrative support with associated servicing costs then forced onto ‘users’ who neither need nor want the service. The ‘water reform’ should not be a medium for another thickening layer of Government processes and committees. It is worth noting rural Local Governments were once ‘roads boards’ with responsibility solely for local roads. Now, Local Governments have grown to be expensive operations requiring landholders to submit for many approvals before they can run business on their own land. There have become so many costly compliance requirements on business that private investment and ventures are stifled. 

2 How would the model work in practice? 

See (F)1 above 

3 Is/are there other model(s) for self-management that should be considered? 

See (F)1 above 

4 In a self-management arrangement, what level of responsibility for water resources management should water users be prepared to accept? 

Land owner water users in Manjimup presently accept full responsibility for management of water resources on their land. They neither receive any management support from Government, nor do they request or require support. Again, the Blueprint for Water Reform fails to recognise water used for agricultural and other production in the Manjimup area is entirely from privately constructed dams and has always been self-managed by landholders. There was never any Government funded and managed water infrastructure as for the Harvey and Ord River irrigation schemes, and Manjimup landowners don’t require any Government investment in public dams for production from private land. 

(G) INVEST IN WATER USE EFFICIENCY 

1 To what extent do you support the proposals for water use efficiency? 

Manjimup landholders are efficient users of water from their private dams. Manjimup landholders use efficient sprinkler and drip irrigation, not the inefficient flood irrigation systems that have been widely used at Harvey, the Ord River, and in the Murray Darling Basin where the Blueprint for Water Reform has its origins. Water used by irrigators in Manjimup via efficient sprinklers and drips is pumped using either fuel or electricity powered pumps; the cost of pumping is a disincentive to waste of water and thus an incentive for efficiency.  

Of great concern to Manjimup landholders is that the ‘Proposed Directions’ for water use efficiency in the Blueprint for Water Reform may too heavily rely on the blunt economic policy instruments of ‘Establishing markets for water and water trading’ and ‘Full-cost pricing of water’ (Blueprint page 51). Markets for water trading are of no interest to Manjimup landholders and neither the Blueprint nor the Water Entitlements, Water Plans & Trading for Western Australia (June 2006) paper has practical detail on how water trading markets might operate in Manjimup.  Similarly, neither the Blueprint, nor the Department of Water publication Water use efficiency (July 2006) provides detail on what full-cost pricing of water would mean in practice in Manjimup, with the exception of funding aspects of the Department of Water through licensing and metering fees. 

2 Are there other ways to improve water use efficiency in any water use sectors that should be considered? 

The ‘Others options by sector’ in the Blueprint for Water Reform are comprehensive.  

(H) OTHER COMMENTS 

Do you have any other comments to make in relation to the proposed directions in this consultation paper?

The Manjimup area (being the Shire of Manjimup) will not benefit from the proposed water reforms which, if implemented, will impose unacceptable costs and deter investment. Abundant, high quality surface water provides Manjimup landholders with a range of food, wine and other production opportunities for increasingly cost competitive globalised markets. Increased Government imposed costs associated with water use will decrease competitiveness and could cause decreased food production and job losses in the Manjimup area. The proposed changes to water licensing will cause uncertainties that will deter further investment, both by existing landholders and new investors.  

The Manjimup area and community has recently been the subject of major Government imposed structural changes to the native forest based timber industry which affected local economic confidence. This further round of Government intervention, now in surface water based economic activity, will cause a further loss of confidence. 

The proposed reforms arise from problems associated with over allocated and over used water resources in the Murray Darling Basin, much of which is used inefficiently for flood irrigation of rice and cotton. These problems evoked disputes between the Governments of New South Wales, Victoria, Queensland and South Australia which, with Commonwealth conciliation, led to the ‘National Water Initiative’ which is the core blueprint for the proposed water reform in Western Australia. There are material differences between Manjimup and the Murray Darling Basin in how water is both obtained and used. In most regards, the proposed water reforms are as unsuitable for Manjimup as would be growing rice and cotton! 

The ‘National Water Initiative’ and Draft Blueprint for Water Reform in Western Australia are driven by an economic rationalist water trading theory - dependent on metering and the separation of water entitlement from landholding - which would be totally impractical in the privately constructed dam systems in Manjimup which are not interconnected in a manner which would enable water trading on the scale proposed. 

A well attended public workshop held in Manjimup on 27 July 2006 to discuss the Draft Blueprint for Water Reform in Western Australia overwhelmingly rejected the proposed reforms, preferring the present system of licensing and self management of water resources in the Manjimup area. 

 
If you are interested in Marron aquaculture, Jardee.com also addresses issues associated with Marron aquaculture licensing and approvals.
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