Have Your Say - the Plan behind the 40 000 ML FAFM (Singleton) Water license is being reviewed.

The massive 40 billion litre / year FAFM (Singleton) groundwater licence was granted under the Western Davenport Water Allocation Plan 2018-2021.

The Plan is up for review.

Stand again with the Davenport.

Stand behind Traditional Owners.

Before next Friday October 29, 2021 either:

1. Complete the 'Have Your Say' questionnaire at https://haveyoursay.nt.gov.au/westerndavenport/survey_tools/westerndavenportwapfeedback

or

2. Send an email to waterresources@nt.gov.au

For more information please go to https://depws.nt.gov.au/water/water-management/water-allocation-plans/western-davenport-water-allocation-plan

Please feel free to copy and paste the content below:

To Whom it May Concern,

Thank you for providing me with the opportunity to have my say on the Western Davenport Water Allocation Plan. I have summarised my responses to the 'Have Your Say' questionnaire below:

QUESTION 3

To what extent do you think the Plan is meeting its objectives?

The current plan is not meeting it's objectives. It clearly does not:

• Meet the environmental water requirements of water dependent ecosystems
• Protect Aboriginal cultural values associated with water
• Provides access to water resources to support local Aboriginal economic development
• Provide equitable access to water to support ecological sustainable regional economic development

(it is unclear / I don't know if the Plan meets the objective allocate water for future public water supply and rural stock and domestic.)

QUESTION 4

If you believe these objectives as a whole could be better met through different management arrangements than those described in the Plan, please outline these.

I believe these objectives as a whole could be better met through different management arrangements than those described in the Plan:

Management by Traditional Owners

The authority of Traditional Owners must be recognised. 

• Rules need to be in place to ensure the water allocation plan and licences have the informed consent of Traditional Owners.
• Traditional Owners must be heeded when they state impacts on their values are unacceptable.
• If there is any groundwater still available for extraction this must be set aside in the Strategic Aboriginal Water Reserve as local Aboriginal people are missing out.

Management of Groundwater

The current consumptive allocation makes protection of groundwater dependent ecosystems and Aboriginal cultural values impossible.

• Reduce the estimated sustainable yield (ESY).
• Reduce allocations to ‘consumptive uses’.   

Management of Groundwater Dependent Ecosystems (GDEs)

• The target ‘GDE condition and extent is maintained’ needs to be enforced.
• A separate ‘groundwater management zone’ is needed over areas where groundwater needs to be reserved as it is already supporting GDEs and cultural values.

Management of large extraction licences

• Revoke the FAFM (Singleton) licence and reissue it for a genuinely sustainable amount and only for ten years.
• Large extraction licences must be fully assessed by the NT Environmental Protection Authority before extraction licences are decided.  This will give the public access to all the information up front and a much greater say.

QUESTION 5

Are there any assumptions underpinning the Plan that you believe are invalid? If so please describe.

I believe the following assumptions underpinning the plan are invalid:

• The NT Department of Environment, Parks and Water Security (DEPWS) and the NT Controller of Water Resources would enforce rules to protect groundwater dependent ecosystems and cultural values.
• The DEPWS would not introduce a new guideline, contrary to the Plan, allowing 30% of groundwater dependent ecosystems to be impacted without public consultation.
• It is acceptable to mine water beneath groundwater dependent ecosystems and cultural values.
• Massive irrigation projects will not contaminate groundwater reserved for the environment by leaving salt behind.
• Water dependent sacred sites in groundwater drawdown areas do not have to be considered.
• The target of protecting 100% of GDEs would be enforced and mining groundwater would not be permitted in a “Groundwater Dependent Ecosystem Protection Area”.
• It is acceptable to mine water for the next thirty years and damage GDEs leaving less water and a lesser environment for future generations.
• GDEs do not need to be secured for climate change resilience.
• Groundwater dependent ecosystems in arid parts of the Northern Territory can be destroyed for profit.
• The DEPWS and Controller of Water Resources will implement the adaptive management plan and reduce the estimated sustainable yield when is shown to be unsustainable.
• Appropriate public consultation would occur around mega licences like Fortune Agribusiness Funds Management (Singleton).  It is not acceptable that only a handful of submissions were considered and the comments of over 23,000 people were not even acknowledged in the Notice of Decision, and the appeal to the NT Minister for Environment, Water Security and Climate Change.
• The Controller and Minister for Environment Water Security and Climate Change would include public comments and petitions in Notices of Decision and reviews of these decisions.

QUESTION 6

What do you find most useful in the Plan?

The Plan was most useful in regards to the::

• Map of the Groundwater Dependent Ecosystems Protection Area.
• Statement in the adaptive management plan that groundwater dependent cultural values need to be protected to the standard “The condition and extent of cultural values dependent on water is maintained”.
• Statement in the adaptive management plan that GDEs need to be protected to the standard “GDE condition and extent is maintained”.
• Risk assessment table which highlights the problems with this Plan.

QUESTION 7

How could the Plan be improved?

• Recognise that the shallow groundwater in the Western Davenport area is precious and defining to its landscape and people.
• Reduce the estimated sustainable yield.
• Re-establish the targets for GDEs and groundwater dependent cultural values to maintain their condition and extent.
• Ensure horticulture does not pollute the fresh groundwater resource for the environment or future generations.
• Require large licenses to be scaled back immediately.
• Be more cautious.  Increase the amount available for extraction very slowly and only when the consequences are known and there is social licence to do so.
• If there is any groundwater still available for extraction this must be set aside in the Strategic Aboriginal Water Reserve as local Aboriginal people are missing out.
• Make the rules in the plan enforceable through improvements to the Water Act.

Thank you for considering my feedback. I look forward to seeing my concerns reflected in the outcomes of the review.