News: 23 December 2013 Submissions on Water Reform legislation due 31 December 2013



September 2013: Department of Water issues a Position Paper on 'Water resources management legislation which has major implications for self-supply water users in agriculture; forcing food producers into ‘water markets’ to pay for water by auctions, tenders and trades.

ACTION by 31 DECEMBER 2013: Make a submission to the Department of Water to protect your interests in agriculture and the value of your property. Below is a 'template' submission being used by self-supply water users in the Manjimup and Pemberton area. Please download the submission, edit to add your name and address, type in your name at the signature position and email to at the Department of Water. Submissions must be made by Tuesday 31 December 2013. 

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PO Box ###

########, WA ####

## December 2013

Policy submissions – Water Reform
Policy and Innovation Directorate
Department of Water
PO Box K822, Perth WA 6842

We are self-supply water users in agriculture in the Warren and Donnelly River catchments and object to the plans of the Department of Water in its Position Paper to apply water markets that will increase the cost of water as an input to agriculture and reduce the competiveness of our produce. We request an increase in the allocation of water to agriculture to prevent the introduction of costly water markets and associated ‘red tape’.


1. The Department of Water has restricted the water available to agriculture in the ‘food bowl of the South West’ to force ‘water markets’ policy onto water users.


Over 90% of the water in the Warren and Donnelly River catchments is water for the environment flowing into the Southern Ocean. Two thirds of this area is forest where all of the water is for the environment. In the third that is cleared for agriculture only 40% of the water has been allocated to agriculture and other uses and 60% is allocated to the environment. The Department of Water forced this imbalance onto agriculture in 2012 through their Warren Donnelly Surface Water Allocation Plan (2012). By restricting water available for agriculture to 40%, most areas are now fully allocated or nearing fully allocated. Thus the Department of Water is forcing agriculture into ‘water markets’ to pay for water by auctions, tenders and trades. This will enable the Department of Water to ‘tick a box’ for compliance with the dogma of the National Water Initiative. At our expense! Managing water markets and the associated increased ‘red tape’ will also assist the Department of Water to justify its $83 million budget and 452 staff. At our expense!


2. More water must be allocated to agriculture in the ‘food bowl of the South West’ by revising the Warren Donnelly Water Allocation Plan.


Our area is designated ‘Priority Agriculture’ by the State Planning Commission and water for agriculture should have priority over the environment. We request the Warren Donnelly Surface Water Allocation Plan (2012) be revised to provide 60% of water for agriculture and other uses and 40% for the environment. This will provide sufficient water for growth of agriculture and maintenance of property values. There would then be no justification for imposing initial purchase of water allocations from the State by auction and tender, restrictive consumptive pools requiring purchase of water from other licence holders, separation of water licence from land title with uncertain outcomes, and mandatory metering, all of which the Position Paper advocates.


3. The Warren Donnelly Surface Water Allocation Plan must be a statutory Plan to provide security of water access for agriculture.


The Department of Water ignored repeated requests that the Warren Donnelly Surface Water Allocation Plan (2012) be a statutory plan prepared in accordance with the provisions of the Rights in Water and Irrigation Act. Water licence holders demanded the security for water entitlements that can only be provided by a statutory Plan. The Department has now done a ‘backflip’ on this admitting in the Position Paper (page 17) that “Administrative allocation plans provide less security to licence holders as the plans may be changed with administrative, rather than legislative due process. Decisions made based on an administrative plan are not as certain as those based on a statutory plan, and there may be additional costs to water users and the government if those administratively based decisions are appealed.”. The Warren Donnelly Surface Water Allocation Plan must be converted to a statutory Plan under the Rights in Water and Irrigation Act, without delay in 2014.


4. The Minister for Water must publish a draft ‘green' Water Resource Management Bill for public comment.

The proposed legislation covers separation of water licence from land title, consumptive pools for periodic determination of how much water can be taken from private dams, water auctions and tenders, mandatory metering, and what types of dams are to be included, affecting property rights. These and many other provisions will require detailed consideration by water users affected in the ‘food bowl of the South West’. With controversial legislation, the ‘devil is in the detail’; thus it is vital the Minister for Water issue a draft ‘Green Bill’ for public comment. 

Yours sincerely


(Type your name here)


Please download the submission

Thanks for making a submission!
Sponsored by ‘Manjimup and Pemberton Landowners’: 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. Subsequently, in 2009 Manjimup and Pemberton Landowners again responded when the Barnett coalition Government attempted to introduce costly water resource managment charges.  Email:  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.