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COMMENTS RE. WMLR DISCUSSION PAPERS

Tony Dickson 1/11/07 ferretfarm@bigpond.com ph. 0410 501484

Environmental Issues.
o I fully endorse the intentions regarding The Plan. The rationalisation of our use of water resources is long and sadly overdue. I also endorse the majority of the proposals and options considered. However, from the perspective of an environmental activist of some thirty-five years and farmer for more than a quarter of a century, I have encountered a number of confusing and contradictory statements, self-defeating assumptions and a generally narrow and myopic environmental focus. o Given the constraints of terms of reference and the compromises that are the inevitable results of the committee process, these deficiencies are both understandable and commendably few. They do however, subtly but profoundly, undermine the long-term success of this vitally worthwhile endeavour. I shall attempt to address a few of these issues.

o Narrow environmental focus

The discussion paper rightly emphasises the need to maintain biodiversity, but only makes passing reference to the most significant threat to global and particularly, local ecological health. Global heating promises an ecological disaster to make your average biblical cataclysm look like a bad hair day. Recent studies project that in an ecosystem as large as Kakadu, extinction rates over the next hundred years may be as high as 90%. In the MLR where remnant vegetation is reduced to pockets, that combined, totals only a tiny percentage of the land area, the consequences may be expected to be far worse. When a hot fire takes out a piece of isolated scrub, it is pretty much curtains for the terrestrial inhabitants. The implications of Global heating have dominated my consciousness since I was at school in the late 1960s. All these years later it is incomprehensible that this issue is not the touchstone that predicates everything we do.

o Water dependent ecosystems

The environmental focus of the proposed plan is, understandably, water dependant ecosystems. The unfortunate corollary of this is that insufficient attention is paid to the whole ecology of the area. Whilst the water dependant systems are vitally important to dry land ecologies, the reverse is also true and consequently the most obvious structural problem with our current landscape is the discontinuity between remnant ecological systems, i.e. a lack of corridors. Perhaps the most serious long-term consequence of this, apart from fire threat, is that, because most of the remnant vegetation is situated on the poorer, drier land, sufficient numbers of pollinating birds cannot survive the lack of

2 flowering plants over summer. The wetter land that allows summer flowering has mostly been lost to farming. Thus the lack of habitat and the isolation of the remnant pockets is clearly the most serious long-term issue for biodiversity in the MLR. Lack of appropriate vegetation is the base problem. The provision of water is the means of addressing that problem; it should not be seen as an end in itself.

o Self defeating assumptions Non-commercial forestry

In discussion paper 6, the consideration of non-commercial forestry for land rehabilitation is confined to one sentence: Due to its low volume plantings and focus on degraded sites, (my emphasis) forestry for land rehabilitation has been assessed as low risk in relation to its demand on water resources. If the rather obvious observation, that the most egregious threat to biodiversity is excessive land clearance, is accepted, then surely the assumption inherent in the above statement is both an admission of defeat and self-fulfilling prophecy. If the option of significant rehabilitative revegetation were precluded from consideration at this stage of the plans development, what would become of its possibility at a later time? What benefit to the environment if a large scale, carbon credit driven plan to create an artificial national park, had to compete with a vineyard for a water licence? It only requires a little imagination to foresee that Global Heating heralds economic and social changes so profound that they resonate with historical echoes from the Great Depression, the collapse of the Roman Empire and the Industrial Revolution. Expect the unexpected. Compared to the whimsical and horrendously expensive ideas currently abroad that we can solve our problems with nuclear power, clean coal technologies, or piped water from East Timor, large-scale rehabilitative plantings are a very probable reality. The said statement is confused by the introduction of a secondary concept: that of degraded sites. Whilst the size of such plantings is obviously germane to potential demands on water resources, how is their focus on degraded sites a relevant consideration? The obvious implication is that broader environmental benefits are recognised as a factor that should be taken into account when considering how water is allocated. Thus, presumably, the plan embraces the idea that a land use that promised a disproportionate benefit to ecological values may justify an increased investment of water, sourced either from EWP, or from a less ecologically positive use. This is a significant qualification to the rest of the proposed policy.

Farm forestry
With respect to the intention of the Plan to preserve and enhance ecological values and given that the policy papers specifically

3 acknowledge the environmental, ecological and land care benefits of farm forestry, it seems odd that the same consideration that is given to noncommercial forestry is not extended to this important alternative. The ecological values of farm forestry are obviously lower than those of purely ecological plantings, however, realistically, the choice is not between ecological plantings and forestry, but between forestry and other commercial land uses, such as introduced pasture species, olives or vineyards. If one considers that it is estimated that 95% of all terrestrial species are to be found below the ground, and that recent estimates of arthropod fauna alone, in the canopies of Australias eucalypt forests, suggest that the number of species could exceed 250,000, the potential significance of farm forestry in providing the structural requirements for biodiversity enhancement should be clear. NB. With regard to the above, another assumption that should be avoided is that models for forestry design and management are not capable of adaptation to meet different priorities. Whilst farm forestry is more flexible in this regard, this potential also applies to industrial plantations. (Eg: I have been developing a management regime specifically designed to enhance the structural complexity of my woodlots and thus maximise the biodiversity therein.) If this is accepted and given that in the short term at least, significant ecological plantings are unlikely, then farm forestry, with its added economic incentives, is our best hope of increasing the extent of native vegetation. However, farm forestry, like any other commercial enterprise has its economic thresholds. To apply strict per property areas or percentages to such enterprises will impose strong disincentives to their establishment. It is imperative that the plan applies any quotas for forestry establishment on a per-catchment basis and not on a per property one. The catchment is the logical unit for ecological management.

Does privatising the commons help the environment?

It should not be assumed that transferable water licenses and therefore the market place, is an appropriate mechanism for delivering environmentally advantageous outcomes. Our economic history has largely been a repetition of the enclosure laws, whereby the commons are progressively privatised. Will the stewardship of the land be enhanced by the legal separation of land from water? The discussion paper lists the following benefits of forestry: land rehabilitation, ecological, environmental, social and economic. A tradable licensing system would put forestry in direct competition with land uses such as irrigated pasture and vineyards. It is unlikely that irrigated pasture in the MLR has a long-term future, which largely leaves viticulture as the main competition for commercial water use. This is a competition that forestry is unlikely to win. If this is the case, how is the environment or

4 ourselves better off, given that the recreational drug industry has only one bottom line? Socially and environmentally the wine industry is a disaster. To the market economist all economic activity is equal, but to the environment, some activities are more equal than others. Thus a permit system, whilst not without its commercial disadvantages, is best placed to serve the long-term interests of the community and the environment.

Water Metering
The assumption that metering water extraction from farm dams is particularly relevant to the provision of environmental flows would seem completely erroneous. The provision of EWPs as far as dammed surface water is concerned, is determined by the extent of water yield interception, which occurs at the point at which it flows into a storage dam. Assuming that most such dams are situated on ephemeral watercourses, the subsequent use of the water is likely to occur in summer when the watercourse has ceased to flow. Whether the water thus stored is used, or left to evaporate will make no difference to the subsequent EWP in typical farm dam situations. Often the metre or so of evaporation accounts for more water than is used. The critical issue is the amount of water intercepted, and that can only be varied in a significant way by rationalising the size and distribution of dams. The fact that legislation may be required to allow the retirement of existing dams is no excuse for introducing intrusive but inherently ineffective measures. There are no constitutional barriers to such legislation; it just requires political will. Metering is also a flawed concept because of the complexity of its practical application and the costs of administration.

In conclusion, I urge decision makers to broaden their vision to ensure that the fragile remnants of the whole ecological system are considered in the Plan, that they may be made more resilient in the face of ever increasing stressors and threats consequent to the demands of human exploitation and a rapidly changing environment. Appropriately designed native forestry can be hugely beneficial in this endeavour. This potential should be accounted for in the water budgeting process, in the form of a favoured status compared to land use activities of less environmental benefit. It is essential that forestry be recognised as part of the solution, rather than part of the problem.