WaterReform.Net  > > NEW GOVERNMENT FEES AND CHARGES, AND ‘RED TAPE'

NEW CAMPAIGN 2009

PAST CAMPAIGN 2007-2008

NEWS:  DISALLOWANCE OF WATER LICENCE FEES WELCOMED  14 April 2008

DOWNLOAD submission made by Manjimup and Pemberton Landowners group to the Legislative Assembly Economics and Industry Committee Inquiry into Water Licensing and Services, 7 January 2008

UPDATE: Fees Regulations Disallowed in Legislative Council on 8 April 2008

Revised Water Licence Fee Tables for Manjimup and Pemberton Region 

Class

Water entitlement Kilolitres per year

Number of Licences

Fee

2008

Expected Revenue

2008

Fee

2007

Expected Revenue

2007

 

 

 

1

1500 - 5000

9

$100

$900

$200

$1800

2

5 001 -

50 000

158

$150

$23,700

$325

$51,350

3

50 001 - 100,000

103

$250

$25,750

$600

$61,800

4

100,001 - 500,000

107

$700

$74,900

$1,200

$128,400

5

500,001 - 1,000,00

6

$1,600

$9,600

$1,800

$10,800

6

1,000,001 - 5,000,000

1

$2,500

$2,500

$2,400

$2,400

7

5,000,001 –

10,000,000

-

$4,000

-

 

$3,000

 

-

8

> 10,000,000

-

$6,000

-

Total

384

$137,350

 

$256,550

 (Note: the Number of Licences was provided by the Department of Water in August 2007)
 


Manjimup, Pemberton and Country WA have been ignored by the State Government in a reckless rush to apply the 'one size fits all' National Water Initiative based on the very different Murray Darling Basin

Unfortunately, none of the serious concerns expressed by Manjimup and Pemberton area landholders during 2006 (see Background below) in regard to the Blueprint for Water Reform in WA have modified the approach of the Department of Water and the Minister for Water Resources John Kobelke who announced on 27 February 2007 the Blueprint is being converted to legislation and regulations. New water licence fees, metering charges and water resource management charges will extract more than $1.500,000 annually from the Manjimup and Pemberton area economy, for no gain whatsoever to the community. The interests of the Manjimup and Pemberton area have been sacrificed so the State Government can access Commonwealth Government funds under the National Water Initiative which was designed for the Murray Darling Basin. The ‘one size fits all’ system is incompatible with the Manjimup and Pemberton area and Commonwealth funds will mainly be used for water supplies to Perth. There is no further period for ‘public comment’ on Minister Kobelke’s decisions. Political avenues are now the only means available to prevent these damaging impacts on the Manjimup and Pemberton area economy and community; either to convince Premier Carpenter and Minister Kobelke to change their decisions or to block enabling legislation and regulations. We will work on both! The immediate priority is to disallow regulations required to introduce the harsh water licence fees.

WATER LICENCE FEES: The water licence fees, announced by the Minister for Water Resources on 27 February 2007 and to apply from 1 July 2007 will impact on 384 licence holders in the Manjimup and Pemberton area, and 10,841 licence holders throughout WA (most in country WA): they are: 

LICENCE CLASS

ENTITLEMENT CLASS (KILOLITRES PER YEAR)

FEE FREQUENCY
  Application fee $200 On application
1 0 – 5 000 $200 Annual
2 5 001 – 50 000 $325 Annual
3 50 001 – 100 000 $600 Annual
4 100 001 – 500 000 $1200 Annual
5 500 001 – 1 000 000 $1800 Annual
6 1000 001 – 5 000 000 $2400 Annual
7 > 5 000 000 $3000 Annual

[Note: 1000 Kilolitres = 1 Megalitre,  4.55 Megalitres = 1 Million Gallons, 1000 Megalitres = 1 Gigalitre]

The Department of Water claims the annual water licence fees will raise $5.8 million which is the alleged cost of licensing 2486 gigalitres of water in 2006-07. On these figures, the average cost of licensing a megalitre of water is $2.27. Self-supplied farming families will pay $102 to $2.40 a megalitre for their water licence; whereas corporations such as water utilities, mining companies and irrigation cooperatives will pay only 14 cents a megalitre. There is no equity between water users in the proposed annual licence fees. The State Government is favouring corporations with the new fees at the expense of farming families.

Of the 384 licence holders in the Manjimup and Pemberton area, 216 will pay either $600, $1200 or $1800 annually towards a total of $256,550 in fees for the area. We are all concerned about the impact on water resources of global warming and the increased water requirements of industry and population growth, but fees and charges must have a rational basis, and be fair and equitable. The water licence fees applying from 1 July 2007 are neither rational, nor fair, nor equitable. The fees announced by the Minister are far too high for family businesses which in many instances are only marginally profitable. People ‘on the land’ may appear to be land asset wealthy but they are often ‘cash poor’ and are struggling to make a living for their families from their properties

Alternative: There is a reasonable alternative based on the cost of a driver's licence. The Manjimup and Pemberton area has for forty years been served by a local statutory committee called the Warren Water Management Area Advisory Committee who's role is to advise the State Government on water management in the Warren and Donnelly River catchments; the Committee has advised the Government to adopt an alternative fee structure equivalent in cost to a driver's licence. Please read the proposed alternative fee structure which advocates a 10 year duration water licence fee of $222.

WATER METERING:  The Minister has determined mandatory metering will be conducted by the Department of Water for all water licences above 50 megalitres, which is the majority of licences in the Manjimup and Pemberton area, and all new water licences will be required to be metered. The Department of Water will assess sites, purchase, install, maintain, replace and read the meters and recover all of these costs, plus borrowing costs, from water licence holders by an 'annual metering charge'. Based on costs from the Department of Water Directions Paper on Metering (2006) an annual metering charge would be $835 per meter for surface water, or $1670 per water licence with an average of two meters deployed per licence.  This $1670 annual metering charge will be on top of the unacceptable $600, $1200 and $1800 water licence fees the Minister intends to apply from July 2007.

Alternative: The amount of water used from private dams over summer is limited by what a dam can hold from previous winter flows and can be measured without expensive meters. An annual Surface Water Licence Report by licence holders of measurement of water levels and volumes from relevant dams is a practical alternative to expensive metering and should be an option under relevant legislation, regulations and water management plans. Estimates of the volume of the relevant dam (or dams) for the licence can be made either from the contour from a surveyed dam or by the method used in the Application for a 5C Licence to Take Surface Water. The difference between the estimated volume of the dam and the licenced volume represents the combined volume of water extracted for use and discharged by evaporation and seepage. It should be noted expensive metering doesn’t provide information on water volume in the dam discharged by evaporation and seepage; thus metering is of limited value for management of surface water resources within river and stream catchments.  The Australian Taxation Office allows taxpayers to self report income and expenditure, surely water use from dams can also be self reported without the growth of a massive Department of Water metering bureaucracy.

To demonstrate how practical this alternative to metering is, submit a Surface Water Licence Report for your water licence now, with a covering letter to the Minister for Water Resources.

WATER ENTITLEMENTS:  The Minister has decided water licences will be separated from Land Title, creating uncertainties on the value of properties, deterring investment in land use, and perhaps inviting speculators to buy water and force up the price of water. This is all part of the National Water Initiative applying blunt economic policy instruments for ‘Establishing markets for water and water trading’ and ‘Full-cost pricing of water’.  At present a Licence to Take Water is issued for 10 years duration, under the new 'water access entitlements' there will be less security, with family businesses dependent on an annual water allocation from a consumptive pool, which may vary from year to year.

Alternative: Change to the present system of licensing should only be made if and when the area specific Statutory Water Management Plan justified a need for a change in the area of the specific Plan, based on the sustainability of local water resources and the nature of water infrastructure. For example, separation of water licence from Land Title is inappropriate for the Manjimup and Pemberton area with sustainable water resources based on private dams, but may be appropriate for members of the Harvey Water irrigation cooperative who receive 'bulk water' from Government dams and trade within and outside of their cooperative. Thus Manjimup and Pemberton Landowners seek provision in the new Water Resources Management Bill for continuance of the present licence and land title relationship if the local Statutory Water Management Plan determines it to be the appropriate form of licence for the water resource and infrastructure.

WATER RESOURCE MANAGEMENT CHARGES:  The water licence administration fees above are at the leading edge of additional 'water resource management charges', to be introduced under the National Water Initiative. The nationally uniform water resource management charges are being determined by a Canberra based committee. It is vital the water licence fees above be reduced to a reasonable level, otherwise the yet to be announced 'water resource management charges' will layer on top of a high base and make most of the current water-related land uses in the Manjimup and Pemberton area non-viable.

ACTION:  We must not give up!  Please consider letters to the Premier and Ministers, modify as you wish and post. Please forward these letters or this web site address on to water licence holders you know so they can add their address, date, print, sign and post to each of the Premier and Ministers. We will also be providing further information and draft letters at http://www.waterreform.net , so please re-visit this site. There will be more letters on other topics, please visit again. Further, see questions asked in State Parliament on the detail of the water reforms. If you have questions that need to be answered, contact your representatives in the Legislative Assembly and Legislative Council and request they put your questions to the Minister for Water Resources.

QUESTIONS or COMMENT:  Please email neil@waterreform.net or phone 97724098.


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. 

Minister for Water Resources won't meet with Farmers in the South West

Landowners and businesses with concerns in regard to the proposed reforms sought a meeting in Manjimup with Hon John Kobelke, Minister for Water Resources, to directly present concerns to him. After weeks of delay in responding, the Minister won't come to Manjimup to face farmers affected by his harsh fees and charges.

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