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Chapter 3

Environmental water


A key aim of the Basin Plan is to reset the balance between environmental and consumptive uses of Basin water resources and deliver additional water to the environment. The Basin Plan builds on previous State and joint Basin Government reforms to address the over-allocation of water resources and plan and manage environmental water in the Basin.1
As explained in the previous chapter, the Basin Plan sets Sustainable Diversion Limits (SDLs) that determine how much water can be extracted for consumptive purposes while still leaving enough water for the environment.2 In order to meet the SDLs, the Australian Government is recovering water to protect and restore the rivers, wetlands and floodplains of the Murray-Darling Basin. This water becomes part of Commonwealth’s environmental water holdings which is managed by the Commonwealth Environment Water Holder (CEWH).3
Environmental outcomes are also achieved through the SDL adjustment mechanism. The SDL adjustment mechanism involves a suite of projects that are being developed to ensure water delivery systems are more effective and water losses are reduced by removing river system constraints, and environmental water is delivered more efficiently.4 The SDL adjustments mechanism is discussed further in Chapter 2.
This chapter considers:
the roles and responsibilities of key parties involved in environmental water recovery;
processes used to plan, coordinate and deliver water;
how environmental outcomes are assessed and monitored;
the impact of drought and climate change on environmental watering;
how Indigenous values and uses are incorporated into environmental water planning and management; and
the role of complementary projects to achieve environmental outcomes.

Key parties in the recovery of environmental water

There are a range of different parties involved in environmental water management and delivery that have responsibilities under the Water Act 2007, the Basin Plan, state legislation and a range of intergovernmental agreements.
The Basin Plan Environmental Management Framework, contained within Chapter 8, Part 4 of the Basin Plan, sets out the guiding principles and processes to coordinate the planning, prioritisation and use of environmental water.

Murray Darling Basin Authority

The MDBA has responsibility to plan, coordinate and prioritise environmental water at a Basin-scale. This includes the development of the MDBA Basin-wide Environmental Watering Strategy (BWEWS) and the Basin Environmental Watering Priorities.
The MDBA is also the operator of the River Murray system on behalf of Basin governments and manages the Living Murray (TLM) program on behalf of the Basin Governments and the Commonwealth. TLM delivers environmental water to improve the health of six key sites in the Basin. 5
The MDBA further reports on compliance with environmental requirements under the Plan, including assessing WRPs for environmental water compliance and examining Statements of Assurance from Commonwealth and State Environment Holders.

Commonwealth Environmental Water Holder

As noted in Chapter 1, the CEWH is a statutory position established under the Water Act. The CEWH, supported by staff from the Commonwealth Environmental Water Office (CEWO), is responsible for the management and use of Commonwealth environmental water (entitlements and allocations) recovered under the Basin Plan and the Environmental Water Holdings Special Account. In collaboration with state and local water managers and river operators, the CEWH delivers environmental water to achieve environmental outcomes. In doing so, the CEWH is guided by the Basin Plan, long-term environmental watering plans and annual watering priorities.6
When managing its environmental water, the CEWH has three overall options:
deliver water to a river or wetland to meet an identified demand (‘delivery’);
leave water on the accounts and carry it over for use in the next water year (‘carryover’); and
trade water by selling it and using the proceeds to either:
buy water in another catchment or in a future year (‘trade’), or
use the proceeds from selling water to invest in complementary environmental activities (‘investment’).7

Basin States

State Environmental Water Holders manage state water portfolios and allocate their water to achieve state priority outcomes.8
Basin states are required to complete long-term watering plans (LTWP) for each surface-water WRP. The states’ long-term watering plans are developed in consultation and collaboration with holders and managers of environmental water, state and Commonwealth government agencies, river operators and local communities. Long-term watering plans:
must be consistent with the Basin-wide Environmental Watering Strategy;
include regional watering requirements and priorities;
identify the watering requirements of priority environmental assets and environmental functions in the region; and
identify possible cooperative arrangements between Basin states.9
The Basin Plan also requires that Basin states identify annual environmental watering priorities (State AEWPs) in each WRP Area that contains surface water, to help guide the annual planning, prioritisation and use of environmental water at the catchment level.10 The responsible bodies for environmental water in each Basin state are as below:
Table 3.1:  Responsibilities for held environmental water11
Responsible entities
Governance arrangement
New South Wales
Office of the Environment and Heritage
Government department
Victorian Environmental Water Holder
Statutory body corporate
South Australia
Department of Environment, Water and Natural Resources
Government department
Australian Government
Commonwealth Environmental Water Holder
Statutory office holder within government department
Source: Productivity Commission, Murray-Darling Basin Plan: Five-year assessment, Inquiry report, No, 90, December 2018, p.158

River operators and waterway managers

River operators and waterways managers store, manage and deliver water (including environmental water) within the Basin. This includes:
monitoring flows, the weather, system demands, system limitations and the natural environment to help make daily water release decisions;
managing flows to reduce the risk of property damage from flooding; and
ensuring that water gets to where it needs to be for towns, farms, stock and the environment.12

Local environmental asset managers and environmental assets

Local environmental asset managers manage the delivery of water to environmental assets to achieve on-ground outcomes at the local scale.13
The Basin contains approximately 400,000 water-dependent ecosystems, commonly classified as environmental assets. Environmental assets support the healthy functioning of the Basin and also support Basin communities. The Basin Plan classifies a subset of the ecosystems as 'priority environmental assets.'14
The Basin Plan sets out three overall environmental objectives for water-dependent ecosystems. These are to:
protect and restore water-dependent ecosystems of the Murray-Darling Basin;
protect and restore the ecosystem functions of water-dependent ecosystems; and
ensure that water-dependent ecosystems are resilient to climate change and other risks and threats.15

Planning for environmental water

The successful delivery of environmental water is complex and is relies on robust planning and up-to-date scientific and local on-ground knowledge. To achieve the best outcomes with environmental water, there must be efficient and effective management, collaboration and planning.
The success of the Basin Plan's environmental goals relies upon effective engagement between the MDBA, the CEWH, river operators and waterway managers, Basin States and communities.16
In planning and delivering environmental water, the CEWH sources information from the Bureau of Meteorology (BOM), the MDBA and Basin states. At the committee's public hearing on 18 October 2019, the CEWH assured the committee that the CEWO had access to the necessary information to plan and deliver environmental water and that 'from our [the CEWO's] perspective we have the information to allow us to operate, we think, in a fairly sophisticated way.' 17
There are a number of plans and frameworks that guide environmental watering in the Basin. These can be broadly categorised as either annual planning or long-term planning and are summarised below:

Long-term planning

The Basin-wide Environmental Watering Strategy (BWEWS) is prepared by the MDBA. The strategy sets out the expected environmental outcomes at a whole-of-basin scale and strategies to achieve them, including how various partners will work together to plan and manage environmental water.18
Long-term watering plans are developed by Basin states for each WRP area to guide the management of environmental water at a regional level. They include objectives, targets and watering requirements for priority environmental assets and functions, and must be consistent with the BWEWS.19
Long-term asset plans are developed by local asset managers to set out environmental water demand at a local scale. These plans may also identify complementary benefits of environmental water use, potential risks, and on-the-ground delivery arrangements. These plans are not required by the Basin Plan but can assist with the development of State level long-term watering plans.20

Figure 3.1:  Long-term environmental water planning architecture

Productivity Commission, Murray-Darling Basin Plan: Five-year assessment, Inquiry report, December 2018, p. 277

Annual planning

Basin annual environmental watering priorities (Basin AEWPs) are prepared by the MDBA to guide the management of environmental water at a Basin-scale for each year. Basin AEWPs must be consistent with the BWEWS.21
Basin state annual environmental watering priorities (State AEWPs) are prepared by Basin states for each WRP area with surface water and guide the annual planning, prioritisation and use of environmental water at a catchment scale. State AEWPs must be in line with the BWEWS and relevant LTWPs.22
Although not required by the Basin Plan, there are a number of other plans and strategies that are commonly produced to inform the development of watering priorities including site watering proposals developed by asset managers. Figure 3.2 provides an overview of the annual environmental water planning architecture for the Basin.

Figure 3.2:  Annual environmental water planning architecture

Productivity Commission, Murray-Darling Basin Plan: Five-year assessment, Inquiry report, December 2018, p. 285
In its five-year review of the Basin Plan, the Productivity Commission made a number of recommendations relating to planning, coordinating and prioritising water for the environment at a Basin Scale. These recommendations are summarised as below:
Strengthen the BWEWS: The Productivity Commission suggested a number of changes to the BWEWS to provide clearer objectives and guidance on priorities.
Develop materials to assist in the development of LTWPs: These materials should help guide the Basin state in reviewing and revising the LTWPs. The MDBA should also maintain a register of LTWPs on their website.
Reconsider the usefulness of the Basin annual environmental watering priorities: The Productivity Commission notes that these are released too late to be considered by environmental water managers and are becoming redundant as environmental water holders introduce multi-year plans.23
The BWEWS is reviewed every five years and the 2019 strategy is currently being developed. The MDBA has chosen to stage the updates to the strategy, with the first to be published in 2019 (five years after the first strategy commenced) and the second to be published in 2022. The MDBA sought submissions on the draft strategy and are now considering the responses.24

Coordinating the delivery of environmental water

While water holders plan and prepare the delivery of water through long-term and annual plans, the approach needs to be dynamic to adapt to changing hydrological, socio-economic and ecological conditions. A range of committees meet on an ongoing a basis to plan water delivery and coordinate watering events across different WRP areas and between jurisdictions.25 A summary of these committees is provided below.

Coordination Committees

The Southern Connected Basin Environmental Watering Committee (SCBEWC) includes representatives from agencies responsible for environmental water across the Commonwealth, NSW, Victorian, and South Australian Governments. The SCBEWC coordinates environmental water in the southern connected system and have shared decision-making on the use of jointly held water available under TLM, the River Murray Increased Flows and the River Murray Unregulated Flows.26 Since SCBEWC was established, the number of watering events that have been coordinated across multiple water holders has increased.
Following a recommendation from the Productivity Commission's five-year review to establish a body similar to SCBEWC for the Northern Basin, a Northern Basin Coordination Committee has recently been established.27
The Environmental Water Working Group (EWWG) is a subcommittee of the Basin Plan Implementation Committee which comprises officials from Commonwealth and Basin state governments. The EWWG's role is to provide advice on policy and planning issues relating to the Environmental Watering Plan (including the BWEWS, LTWPs, and AEWPs). They may also provide advice on local engagement, accounting for environmental water use and environmental water delivery.28
Catchment-scale advisory groups operate at catchment scales and meet regularly to discuss proposed or upcoming watering events, including identifying potential issues, the outcomes of past watering events, and future opportunities.29 These groups bring together people with a wide range of knowledge and might include, for instance, water managers, landholders, Aboriginal groups, independent scientists and local government representatives. Environmental Watering Advisory Groups (EWAGs) are the key consultative bodies for environmental watering in NSW and some Victorian catchments.30
Operational Advisory groups (OAGs) support operational decisions in the real-time management of environmental water delivery at environmental sites in the South Basin. OAGs include representatives from State agencies, State water authorities, river operators, site managers, environmental water managers, and scientists.31

Monitoring and measuring the impact of environmental watering

Effective monitoring of environmental watering, including measuring and demonstrating outcomes for the environment, is essential to give Basin communities and taxpayers confidence that the investment in environmental water is worthwhile.
There are three main ways that environmental outcomes are monitored and evaluated across the Basin:
operational monitoring – gathering information on current river system conditions, water flows and verifying environmental water delivery;
intervention monitoring – observing and verifying how environmental water has changed rivers, wetlands, the surrounding environment and fulfilled Basin Plan objectives; and
knowledge and research – to improve the understanding of ecological processes.32
The MDBA, Basin States, the Bureau of Meteorology (BOM) and the CEWH all have a role in monitoring and evaluating environmental outcomes.
Basin States report on the achievement of the environmental objectives of the Basin Plan. From 2020, Basin states will be responsible for reporting against the achievement of environmental outcomes at an asset scale. It is anticipated that this reporting will ultimately be against the objectives and targets established in the LTWPs.33 Basin states also report on a range of state-level monitoring programs funded by state governments.
Commonwealth and State environmental water holders provide the MDBA with annual Statements of Assurance that they have performed their functions and exercised their powers in a way that is consistent with the BWEWS.34
The MDBA is responsible for reporting on the achievement of the environmental objectives of the Basin Plan at a Basin scale. This includes a section of the Basin Plan annual report dedicated to environmental outcomes and a five-yearly evaluation of the Plan that include a detailed examination of environmental outcomes.
The MDBA also reports on compliance with environmental requirements under the Basin Plan, including assessing WRPs for environmental water compliance and examining Statements of Assurance from Commonwealth and State Environmental Water Holders. They also report on the progress with TLM program, water quality and quantity and produce twice-yearly Basin 'report cards.' 35
The CEWH works with third parties to gather operational monitoring data. Operational monitoring is undertaken for every watering action, which includes on-ground data about the environmental water delivery action such as volumes, timing, duration, location, flow rates and river highs.
The CEWH also conducts monitoring, evaluation and research activities to look at both the short and long-term response to environmental watering (intervention monitoring).
The CEWO are further undertaking a program of on-ground monitoring and research activities delivered as an integrated program called the Monitoring, Evaluation and Research (MER) Program.36 The MER Program commenced on 1 July 2019 and aims to continue and build on the work undertaken through the Long-Term Intervention Monitoring (LTIM) and Environmental Water Knowledge and Research (EWKR) Projects (2014 – 2019).37

Effectiveness of environmental watering

Previous inquiries have revealed there are concerns from stakeholders that environmental water delivery is not as precise as needed and there is a lack of transparency in how environmental outcomes are measured. There have also been calls to further develop the scientific understanding of environmental flows as this is a relatively new area of research. 38
For instance, the Wentworth Group of Concerned Scientists (Wentworth Group)39 published a study in early 2019 that evaluated whether environmental water recovery has led to observable increases in river flows at two sites in the Murray-Darling Basin. Their assessment found that, despite 2,016 GL of water being recovered for the environment between 2010 and 2018:
environmental flow targets set by the MDBA have not been achieved;
excluding natural flood events, annual average flows can be up to 40 per cent to 60 per cent smaller than expected under the Basin Plan; and
observed flows are similar (or less than) the baseline (pre-Basin Plan) model results, and there has been no improvement or a decline in water flows since the Plan's implementation.40
In their report, the Wentworth Group suggested that insufficient progress in relaxing constraints,41 especially in New South Wales and Victoria, and insufficient water shepherding,42 particularly in the Barwon-Darling area, might have contributed to environmental water recovery not influencing river flows as expected.
The final report of the South Australian Royal Commission argued the need for a comprehensive Basin-wide environmental monitoring program to monitor outcomes. In making this case, the Commissioner contended that there are currently gaps in the scientific understanding in the Basin environment, and in relation to evaluation and monitoring generally. The Commissioner further noted the need for adequate government funding to support evaluation and monitoring activities and suggested that evaluation should be conducted both by the MDBA and by independent experts.43
The compliance compact44 (discussed further in Chapter 5), included a commitment for the Commonwealth and Basin States to (by 30 September 2018) develop a proposal for a Basin-wide system to provide publicly accessible, real-time advice on environmental water. 45 However, as at December 2018, the Independent Assurance Committee (IAC) 46 identified that there had been insufficient progress in developing this proposal. While the MDBA completed a scoping specification report in October 2018, this work has not been progressed jointly with states and the IAC identified a lack of commitment from the Basin states to develop a Basin-wide system, with some states seeking funding to develop their own individual portals. The IAC highlighted the importance of a collaborative approach and encouraged jurisdictions to re-commit to a Basin-wide system.47

Communicating the purpose and impacts of environmental watering

Communication and engagement builds an increased understanding about environmental water, how it is used and the outcomes being achieved. This can further help manage stakeholder expectations, address misconceptions and justify the financial investment in environmental water programs.
Previous reports and inquiries have highlighted some of the ways in which the CEWH could strengthen communication and community engagement.48 Similarly, there may be scope for Basin states to improve the way they communicate the purpose and impacts of environmental watering.

CEWH communication and engagement

Submitters to previous inquiries have generally regarded the CEWH's communication approach as being successful.49 Examples included the CEWH's 'good neighbour' policy, their bottom-up planning processes and interactions with community reference groups, as explained further below.
The CEWH's 'good neighbour' policy aims to 'promote mutually beneficial relationships with other water users and landholders' and includes:
not releasing water that would flood private land, without the consent of the landholder; and
flexibility in the use of channel capacity to minimise impact on other water orders from third parties.50
The CEWH has six local engagement officers working alongside state and local land and water management officers, providing outreach to local communities throughout the Basin. 51 The local engagement officers work with communities to gain local knowledge and provide landholders and the broader community with access to information from the CEWO.
The CEWH publishes a range of information on the Department of the Environment's website about watering actions and their environmental outcomes. This information includes ‘snapshots’ of the CEWH’s activities across the Basin, and a multimedia gallery containing videos, photos and podcasts.52
The CEWH also maintains and publishes a newsletter to update the public with the CEWO's activities.
The 2017 review of the CEWH's operations and business processes (Byron Review) recommended the CEWO increase its communication with stakeholders about the purpose and outcomes of environmental watering, including discussion about activities that did not achieve the expected outcomes.53
Similarly, the House of Representatives inquiry into the management and use of Commonwealth environmental water recommended that the CEWH develop an updated communication and engagement strategy and review the adequacy of existing mechanisms for consultation with the community. The MDBA and Department of the Environment and Energy advised that all twelve environmental water management agencies are in the process of collaboratively developing an overarching communications framework for water for the environment.54

Drought and the independence of environmental water holders

In response to drought conditions throughout the Basin,55 there have been calls from some stakeholders for environmental water to be released to assist farmers.56 These calls have raised questions about the independence of Environmental Water Holders and the use of environmental water during drought.
The sale or reallocation of environmental water purely for the purpose of drought relief is inconsistent with the National Water Initiative (NWI). Paragraph 35 of the NWI explicitly states that environmental water should only be traded when not required to meet environmental and other public benefit outcomes.57
There have been questions raised about the adequacy of current processes to protect environmental water from being sold to assist with drought relief, including whether the intended purpose of individual environmental water trades is transparent enough.58 For instance, in October 2018, the NSW Office for Environment and Heritage sold 15 GL of environmental water allocations in response to dry conditions. The Productivity Commission noted that 'it was unclear whether the 15 GL sold was surplus to meeting environmental needs, as the sale was described as "assisting [farmers] during the drought", with all proceeds earmarked for drought-related projects.' 59
The Water Act prevents the CEWH from disposing of water entitlements unless they are surplus to meeting environmental needs. The CEWH is also not subject to the direction of the Department of Agriculture or the Australian Minister for water when undertaking water trading. Further, while the CEWH is housed in the Department of the Environment and Energy, it is supported by the CEWO, which allows the CEWH to brand itself as an entity separate from the department.60
In its 2017 inquiry into National Water Reform (NWR inquiry), the Productivity Commission noted that the Water Act does not preclude the Minister from directing the CEWH to make water available, 61 and argued that this could challenge the CEWH's role to deliver environmental outcomes:
…this could mean that the Minister could direct the CEWH to deliver water to assist graziers experiencing dry conditions. While the Water Act (Cth) should prevent this happening unless the water would also benefit the environment, the CEWH could not refuse such a direction on the basis that an alternative use would achieve a better environmental outcome.62
In its submission to this committee, the CEWH highlighted that while the trade of Commonwealth environmental water must be undertaken for environmental purposes, and the CEWH cannot trade as a profit-making enterprise, the trade of environmental water can also provide a benefit to other market participants. For instance, the trade of 10 GL of Commonwealth environmental water allocations in the Gwydir catchment in NSW was possible because the needs of the environment had largely been met and there was a strong demand for water from irrigators due to dry conditions. The sale of the environmental water meant irrigators could have access to water to finish off their crops.63
The NWR inquiry further highlighted apparent weaknesses within the governance arrangements for environmental water in NSW. In NSW there are no formal arrangements to ensure the independence of decision-making on environmental water as the holdings are managed within the Environment Department and can be subject to ministerial direction.64
To help address these challenges, the NWR inquiry recommended institutional separation between environmental water holders and government, so that decisions regarding environmental water could be made without being subject to political interference:
Where governments own significant environmental water that can be actively managed, they should ensure that decisions on the use of this water are made by independent bodies at arm’s length from government. The Australian and New South Wales Governments should review current governance arrangements to ensure that held environmental water and environmental contingency allowances are managed:
a. independently of government departments and political direction
b. by statutory office holders with an appropriate range of expertise. Australian, State and Territory Governments should enhance the National Water Initiative to align with this recommendation.65
The Australian Government response to the NWR Inquiry agreed 'in principle' to these recommendations, but did not commit to any changes to governance arrangements.66

Protection of environmental water in NSW

There has been considerable media attention about low flow extraction practices in the Barwon-Darling and whether the current rules adequately protect environmental water. 67
Following the 2017 Four Corners episode on water theft in the Murray Darling Basin, in which NSW featured prominently, the NSW Natural Resources Commission (NRC) 68 was asked by then NSW water minister, the Hon. Niall Blair MLC, to bring forward a statutory review of the Barwon-Darling.69
In September 2019, the NRC released its review of the Barwon-Darling Water Sharing Plan.70 This review described the Barwon-Darling as an 'ecosystem in crisis' and argued that an intense drought, significant volumes of upstream water extractions, an apparent climate shift and the rules within the water sharing plan have all contributed to insufficient ecological, social and cultural outcomes in the Barwon-Darling. The NSW Natural Resources Commissioner stated:
There is an urgent need to remake the plan so the current trend of a river system heading towards collapse is reset and the river and its dependent species, communities and industries are put on a path towards long term health and resilience.71
The NRC report discussed the current rules of the Barwon-Darling water sharing plan, which allow irrigators to pump water during low flow periods. The NRC recommended raising the cease-to-pump threshold to protect the environment during times of low flows.72 The cease-to-pump levels proposed by the NRC would require adjustment to the rules for A Class licenses.73
Like the NRC report, the Murray-Darling Basin water compliance review also found that the Barwon-Darling water-sharing plan failed to “provide adequate protection for environmental water, particularly during low flows”, potentially inhibiting achievement of the environmental and social outcomes of the basin plan.74
The NSW government is currently considering the recommendations made in the final NRC report.

Maximising the benefits of environmental water

Implementing the pre-requisite policy measures and northern basin toolkit

Under the Intergovernmental Agreement on Implementing Water Reform in the Murray-Darling Basin 2013,75 Basin States agreed to the implementation of additional policy measures (known as pre-requisite policy measures (PPMs) or unimplemented policy measures) that would enable the efficient and effective use of environmental water. The PPMs allow for:
the credit of environmental return flows for re-use at downstream environmental sites (protection of environmental water); and
the ability for environmental water holders to order water from storages to top up or 'piggy-back' on naturally occurring flow events.76
In July 2019, the MDBA noted that while policies and procedures are in place for the PPMs, further work is required to improve the PPM implementation.77
While the PPMs are limited to the Southern Basin, the Northern Basin toolkit measures, offer similar benefits in the northern Basin.78 As discussed in chapter two, the toolkit includes, among other initiatives, measures to protect environmental flows, address operational constraints and improve infrastructure to improve fish habitat.79
The CEWH's submission to this inquiry emphasised that the successful implementation of the PPMs and the toolkit's measures are critical to maximise the outcomes of environmental watering.80

Incorporating Indigenous values and uses into environmental water planning

In addition to its role in improving environmental outcomes, environmental water can provide a number of secondary benefits. For instance, environmental watering can also provide for Indigenous water values.
Chapter 8 of the Basin Plan includes several provisions that aim to incorporate Indigenous values and uses into environmental water planning and management. Sections 8.15 and 8.29 specify that the MDBA is required to have regard to Indigenous values and uses when preparing the BWEWS and the Basin AEWPs.
The Basin Plan also contains principles to be applied by environmental water managers, one of which is to have regard to Indigenous values as a way to maximise the benefits of environmental watering.' 81
Under the Plan, Basin States are also required to identify Indigenous water objectives and outcomes through the development of WRPs.
Under the Water (Indigenous Values and Use) Direction 2018 the MDBA must annually report on how, when planning for environmental watering, holders of held environmental water considered Indigenous values and Indigenous uses and involved Indigenous people. The first of these reports was published in June 2019. 82
In its five-year review, the Productivity Commission recommended that the MDBA strengthen the next iteration of the BWEWS in 2019 by including a secondary objective that, where environmental outcomes are not compromised, environmental watering should also seek to contribute to social or cultural outcomes. This change was not included in the MDBA's proposed changes for the 2019 Environmental watering strategy but has been included in the proposed changes to be made in 2022.83 The final version of the 2019 BWEWS has not yet been published.

Progress in incorporated Indigenous values and uses

In the northern Basin, the MDBA are working with the Northern Basin Aboriginal Nations (NBAN) on the First Nation Environmental Watering Guidance Project (FNEWG). This project will collate the environmental watering objectives of 21 northern Basin Aboriginal Nations across five environmental watering themes. NBAN are partnering with the MDBA and CEWO to integrate these First Nations’ objectives into the 2020–21 Basin AEWPs and long-term environmental water planning.84
In the southern Basin, the MDBA and the CEWO are working in partnership with the Murray Lower Darling Indigenous Nations (MLDRIN) on the First Nations’ Environmental Water Objectives (FNEWO) project. This project builds upon work commenced in 2018 to first identify and then incorporate First Nations environmental watering objectives in the environmental watering framework for the Basin. The project aims to have detailed objectives included in the 2020–21 Basin annual environmental watering priorities and long-term environmental water planning.85

Complementary projects

Complementary waterway management activities or 'complementary works' are additional activities (outside of environmental watering) that help meet environmental outcomes. This might include, for instance, the management of pest plants and animals, habit restoration and water quality improvement.86 Complementary works are important because the provision of environmental flows is not always sufficient to deliver the desired environment outcomes.
Despite their importance to achieving environmental outcomes, complementary works operate outside the formal requirements of the Plan and are the responsibility of Basin State Governments. The Productivity Commission review found that a number of stakeholders raised the lack of explicit requirements for complementary works in the Basin Plan as an issue.87
The Environmental Defenders Office of Australia noted that while complementary methods are necessary, they had concerns that certain stakeholders wished to substitute ‘complementary measures’ for environmental flows, including in systems vulnerable to water scarcity. They highlighted that complementary measures must be clearly identified as complementary only, not as a ‘substitute’ for environmental flows.88
The Productivity Commission found that there was not a consistent or coherent approach to complementary works across Basin States. Environmental water and complementary works tend to be managed by different bodies and there is often a lack of incentives or authority to coordinate these two areas of work.
The Productivity Commission recommend that States more closely align the work of environmental water managers and natural resource managers so environmental outcomes can be achieved. As a first step, the Productivity Commission concluded, this can be achieved by including details of complementary works in LTWPs. 89
The Joint Basin government response to the Productivity Commission inquiry report agreed with this recommendation and noted that Basin state legislation anticipates that water planning should have regard to other natural resource management planning and vice versa. The response further noted that:
Considerable work is planned or underway on a range of complementary environmental projects as part of the Basin Plan's processes, such as environmental works and measures in the northern Basin, environmental works and measures through the SDL adjustment mechanism and state priority projects.90

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