Draft entitlement submission
Submission on draft entitlements – originally due 3 June 2021, extended to 17 June 2021
This maybe the LAST opportunity (other than legal challenge) to put forward concerns, errors or omissions regarding your floodplain
harvesting licences shares. If you have concerns, or you have outstanding issues that have not been addressed adn the recent flood
provided you more evidence, you are encouraged to prepare a submission. Have it drafted, ready to submit by the due date to ensure you can
exhaust all your options of review.
As there is growth in extractions everyone is going to have a reduction. Some key questions that may help to identify
if you have an outstanding issues are:
Question 1: What is your rate of in-take compared with your duration of flood? The model is constrained by storage
capacity, intake capacity and opportunity. Is there a physical limitations and is this information correct.
Question 2: Do you extensively store water on fields or in other options? Historically and now? Has the model captured your full
storage capability.
Question 3: If you had 500% allocation and no significant new development since 2008, could you fill your storages in this last flood
event?
Consider reasons as to why not and prepare that in your submission. The policy impacts in a sequence of wet events, not isolated
events.
Question 4: what is the percentage reduction from your unrestricted 5-year maximum average modelled take to the licence shares?
This may help to understand the percentage of reduction you individually have encountered. The average valley reduction is 32%
reduction over the long-term (based on the rainfall runoff exemption applying).
I will note that the GVIA is pursuing outstanding valley-scale issues with the cap scenario, which we hope to inform you of the outcome of
those efforts and/or share with you suggested wording for submissions, prior to the deadline.
We are seeking an opportunity to understand the differences between unrestricted model outputs and shares from the Department.