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Submissions

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Submissions

Submissions |

Recently the GVIA submitted to the Natural Resources Commission review into the Gwydir Regulated Water Sharing Plan. The Submission included a range of recommendations covering how the plan contributed to environmental, social, cultural and economic outcomes. We raised concerns regarding the use of section 324 temporary restriction orders, FPH zones and trade limitations, channel capacity and the need for the Minister’s decision regarding supplementary water events to rigorously assess the potential for small supplementary flows in the Gwydir to contribute to the Barwon-Darling requirements. The GVIA recommended that there needed to be greater certainty for stakeholders around these limits and decisions to implement any limits or restrictions to supplementary access, to achieve Schedule 2 outcomes, a framework should be established as part of the long-term planning arrangements. 

Submissions |

The GVIA submission included 9 recommendations. In principle the extension of the time frames is constructive, there are however so other issues which are concerning. The following recommendations were included in the submission;

The GVIA recommends that over-recovered water be returned to the Valleys where it was acquired to enhance the sustainability of the environment and the communities within those valleys. We do not support the allocation of water that cannot contribute to environmental outcomes in the southern connected system being allocated to the 450GL water for the environment.
The GVIA recommends that socio-economic criteria for all programs under the 450GL target remain.
The GVIA recommends the reinstatement of the 1,500GL limit on water purchases.
The GVIA recommends the removal of “from time to time” to be replaced with a fixed time period, aligning with the completion all other measures within the Murray Darling Basin Plan (2012).

Submissions |

The GVIA provided the following submission to the Natural Resources Commission on their 10-year statutory review into the Unregulated Water Sharing Plans in the region.  

We are now following up with the agencies key recommendations from the review including the WaterNSW licencing information and an urgent review of trade restrictions. 

Thank you to all our members who helped inform this submission and completed our survey.  

Submissions |

The Gwydir Valley Irrigators Association provides a high-level review into some of the issues on behalf of our members.  We have encouraged our members to raise specific, farm-scale issues as part of this process.

Since the finalisation of the FMP for the Gwydir Valley Floodplain, three other valleys have also progressed through development and implementation as well as, the completion of many of the outstanding legacy applications, applied for prior to 2008 and gazetted in 2016.

The five-year review is therefore an opportunity to ensure consistency in planning arrangements (where applicable) but also incorporate new information that has come to light since its implementation.

Submissions |

The GVIA provided their formal submission to the Independent Pricing and Regulatory Tribunal of NSW’s draft determination on maximum prices for both WaterNSW’s Rural Bulk Water Delivery and Water Administration Ministerial Corporation (WAMC) in NSW, from 2021.  This was a follow up from previous presentations to IPART NSW at the public hearings.

The GVIA outlined a number of core issues saying "The upward trend in prices has continued for many pricing proposals, well above inflation at a time when many water users have had diminishing water availability and diminishing services.  More work must be undertaken between the regulator and the agencies, with stakeholders to curtail this ongoing, upward trend."

" These key issues stem from our ongoing concern that water users will continue to wear the financial and reputational impact of the current and past performance of NSW water agencies.  This is then reflected in increased revenue proposals by the agencies.  The actions of the Natural Resources Access Regulator this week, to create media controversy with inadequate and misleading data to promote themselves demonstrates our concerns." the submission said.

Prices changes were variable across the different water users, with the highest increases in the regulated system with 28% for High Security charges and 16% usage charge increase also.

Submissions |

The GVIA provided a formal written submission into the Proposed Water Sharing Plan rules for the Gwydir Regulated and Unregulated Water Sources. Saying that the  finalisation of licencing of floodplain harvesting cannot be delayed any longer, 20-years is enough. The results of the Gwydir region should be reason enough to reaffirm this commitment with 30% of the long-term water take outside of the current, contemporary licencing framework.

The establishment of volumetric licences within the Water Management Act 2000 for floodplain harvesting does not create new water but rather, is recognising this existing historical form of access in the current regulatory framework. Key regulations consulted on at the end of 2020, must be put to government to enable this transition to occur.

Without enabling the licencing framework and then implementing valley-based compliance through water sharing plan rules, this form of take remains unmanaged, unmetered and unaccounted for which is not in the interests of any stakeholder. An analysis of stakeholder views presented in Attachment A, highlights there is strong commitment to licencing across a broad spectrum of interests but that other water management issues are being conflated as part of the debate.

Submissions |

The GVIA provided a submission into the NSW Government during their consultation on proposed amendment for floodplain harvesting in NSW.  These included 

  • Water Management (General) Amendment (Floodplain Harvesting) Regulation 2020
  • Water Management (General) Amendment (Floodplain Harvesting Measurement) Regulation 2020
  • Water Management (General) Amendment (Exemption for Rainfall Run-off Collection) Regulation 2020
  • Water Management (General) Amendment (Floodplain Harvesting Exemptions) Regulation 2020


We recognise the importance of this historical reform for our members, our community and communities everywhere.  It is imperative that NSW continues to move forward with how they manage, account and report on water take by water users and floodplain harvesting must be licenced in NSW.  We see these proposed amendment for floodplain harvesting in NSW within these four proposed regulations.

There are broad benefits of implementing this reform that should be acknowledged and can only be achieved once licensing is fully implemented.  

Submissions |

GVIA providing a submission into the Independent Panel's Assessment of the Northern Basin First Flush saying.

The Northern Basin 2020 First Flush event was unprecedented in uniting stakeholders around the Northern Basin in demanding the NSW Government do better at managing competing critical needs in times of drought. It became obvious that during the event, in the absence of a clear and transparent set of rules that set a strong framework to address competing critical needs in the well-defined scope of the public interest, the event would be seen as unduly influenced by one or another set of stakeholders.

With this in mind, we largely support the recommendations proposed by the panel. However, we do offer a number of suggestions to be considered in the process of refining the final report included opportunities to improve data gaps and improve the information base for future discussions. Of importance is an independent and thorough assessment of flow outcomes and alternative scenarios. Without fully understanding a range of scenarios, we cannot fully objectively review the event and properly inform any future debate about improved frameworks. Without this information we may very well focus on a range of reforms that may or may not be required.

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