2026 Basin Plan Review Submission

Have Your Say, Murray-Darling Basin Authority

Submitted by Helen Dalton MP Independent Member for Murray NSW Legislative Assembly April 2026

Terms of Reference

The Discussion Paper explores:

  • initial assessment of sustainable diversion limits

  • water for the environment

  • river connectivity in the northern Basin

  • floodplain and wetland health

  • native fish decline

  • water quality

  • water infrastructure and critical human water needs

  • regulatory design

  • improving science and knowledge

Introduction

The Murray electorate covers approximately 110,000 square kilometres and is Australia's most significant agricultural region. Centred along the Murray River, Murrumbidgee, Lower Lachlan and Lower Darling rivers and its irrigation systems, the area is widely recognised as part of the food bowl of Australia, producing a substantial share of the nation's irrigated agriculture.

Primary industries include dairy, beef, cotton, prunes, table grapes, sheep (wool and fat lambs), grains, rice, citrus, stone fruit, almonds, olives, vegetables and wine grapes. The region also supports extensive food processing and value-adding industries, including dairy processing, rice, fruit packing and juicing, grain handling, wine production, nut processing and vegetable packing facilities. This list is not exhaustive.

Agriculture and associated supply chains form the backbone of the regional economy, supporting thousands of jobs across farming, transport, logistics, manufacturing and export industries. Reliable water management in the Murray-Darling Basin is therefore critical not only for local communities but also for Australia's national food security and export capacity.

This submission represents the views and concerns of local farmers, agricultural businesses and rural families whose livelihoods depend upon access to reliable irrigation water. The people of Murray are deeply concerned that the Murray-Darling Basin Plan (MDBP) has failed to achieve an appropriate balance between environmental objectives and the social and economic sustainability of basin communities.

These concerns are widely shared across basin communities and have been consistently raised by grassroots organisations such as the Speak Up Campaign, which was formed to highlight the impacts of water policy on food production and regional communities. Speak Up has brought together farmers, businesses and regional towns to advocate for transparency and community involvement in basin water management decisions.

Likewise, local councils have repeatedly raised concerns that current Basin policies continue to harm rural communities while failing to address fundamental structural problems in water management.

Background

This document is a formal submission to the Inquiry into the Murray-Darling Basin Authority (MDBA) on behalf of the Member for Murray, Helen Dalton MP.

Griffith: A Regional Food Production Hub (A Case Study)

Location and Development

Griffith is located in south-western New South Wales and has a population of approximately 28,000 residents, servicing a wider regional population of around 80,000.

The city was established in 1916 as part of the Murrumbidgee Irrigation Area (MIA), one of Australia's most significant irrigation developments.

Key water infrastructure supporting Griffith and MIA includes:

  • Burrinjuck Dam

  • Berembed Weir

  • The Main Canal irrigation system

  • Blowering Dam

  • The Snowy Mountains Hydro-electric Scheme

Together, these projects created one of the most efficient gravity-fed irrigation systems in the world.

Agricultural and Food Production

The MIA supports some of the most productive irrigated agriculture in Australia.

Rice

Almost all Australian rice (98%) is produced in the Murray and Murrumbidgee valleys of southern NSW. The industry produces up to 1 million tonnes annually, exports up to 80% of production and supports thousands of regional jobs.

Griffith growers contribute roughly 20% of national rice production. Australian rice farmers are also among the most water-efficient rice producers in the world, using around 50% less water than the global average per kilogram of rice produced.

Horticulture and Vegetables

Griffith's irrigation system enables large-scale vegetable production supplying domestic and export markets.

Produce includes:

  • Tomatoes

  • Onions

  • Carrots

  • Lettuce

  • Broccoli

  • Garlic

  • Sweet corn

  • Pumpkins

  • Potatoes

The region also produces gherkins used in major fast-food supply chains.

Citrus and Fruit

Approximately 70% of NSW citrus production comes from the Griffith region.

Exports include:

  • Valencia oranges

  • Navel oranges

  • Lemons

  • Mandarins

  • Grapefruit

The region is also Australia's largest producer of prunes and a major supplier of fruit for juice processing.

Food Processing

Major food processing industries operate within the Griffith region, including poultry production, packaging and value-added food manufacturing. These businesses depend heavily on the consistent supply of agricultural produce from local irrigated farms.

Wine Production

Griffith is one of Australia's largest wine-grape growing regions.

The district produces around:

  • 300,000 tonnes of grapes annually

  • 65% of NSW grape production

  • 20% of Australia's total production

Numerous wineries operate within the region, forming a major export industry.

Multicultural Community

Griffith is one of the most culturally diverse rural communities in Australia.

Migration associated with irrigation agriculture has produced strong Italian, Indian, Pacific Islander, Turkish, Afghan and Pakistani communities. There are 80 different nationalities located in Griffith and surrounding districts.

More than 50% of Griffith residents claim Italian heritage, reflecting early migration linked to the development of irrigated farming. This diversity contributes significantly to the economic and cultural strength of the region.

Key Issues

1. Basin Plan Recovery

I submit that current water recovery figures under the Basin Plan are materially understated, and that total recovery already exceeds 4,600 GL when all measures are properly accounted for.

In my view, existing reporting does not fully capture the cumulative impact of water recovery initiatives, including efficiency measures, rule changes and other mechanisms that effectively reduce water available for consumptive use. This has resulted in a gap between reported recovery volumes and the real-world reduction experienced by Basin communities.

The failure to transparently and comprehensively account for all forms of recovery undermines confidence in the Basin Plan and its implementation. It also places an unfair and disproportionate burden on rural communities, industries and irrigators, who are already operating under significantly reduced water availability.

Before any further recovery is pursued, there must be a clear, independently verified accounting of total water recovered to date. This should include all direct and indirect measures that impact water availability, not just those traditionally classified under headline recovery targets.

I therefore call on the MDBA to:

  • Provide a transparent and complete accounting of total water recovery across the Basin.

  • Acknowledge that recovery is already in excess of 4,600 GL when all factors are considered.

  • Halt any further recovery until this baseline is clearly established and publicly understood.

A sustainable Basin Plan must balance environmental outcomes with the social and economic viability of Basin communities. Accurate accounting is a critical first step in restoring that balance.

2. Lack of a Clear Environmental Watering Plan

Many Basin communities remain concerned that the MDBP has been implemented without sufficient clarity regarding environmental objectives.

Key questions remain unresolved:

  • Which environmental assets will benefit?

  • How will environmental water be delivered?

  • What are the measurable outcomes?

Physical constraints such as the Barmah Choke significantly limit the volume of water that can move downstream without flooding surrounding land. Without addressing these constraints, environmental watering risks damaging private property and infrastructure.

Furthermore, environmental water delivery often coincides with peak irrigation demand periods, creating additional system pressure.

3. Arbitrary Water Recovery Targets

Many irrigators believe the 2750GL plus 450GL recovery target was determined politically rather than through transparent scientific assessment.

Local communities feel that water recovery targets were established first, with environmental justification developed afterward.

Recent flood events across the Basin have also demonstrated that natural flow events already deliver significant environmental outcomes.

4. Water Buybacks vs Infrastructure Investment

The continued use of water buybacks remains one of the most contentious aspects of the Basin Plan.

Community groups, including the Speak Up Campaign, argue that buybacks remove productive capacity from irrigation districts and reduce economic activity in regional towns.

Instead, basin communities have consistently advocated for investment in irrigation infrastructure and efficiency improvements.

These investments could achieve environmental outcomes without permanently removing water from production.

I have also strongly advocated for complementary measures such as carp control, fish ladders, thermal pollution to be addressed and swapped out for water recovery.

5. Socio-Economic Impacts on Regional Communities

The socio-economic impacts of water recovery in irrigation districts have been significant.

Concerns include:

  • Job losses in agriculture and processing industries

  • Reduced farm productivity

  • Declining business activity in rural towns

  • Falling land values

  • Reduced investor confidence

  • High suicide rates in the Murray and Murrumbidgee areas compared to the rest of Australia

The Basin produces approximately $26 billion in food and fibre annually, representing a major component of Australia's agricultural exports. Policies that significantly reduce irrigation capacity therefore risk national food security and export earnings, not just local economic stability.

Why Rural and Regional Areas are More at Risk?

The Basin Plan has contributed to a range of social impacts across rural and regional communities, particularly where water recovery has intensified economic and environmental pressures. These effects intersect with existing structural challenges, compounding risks to community wellbeing and mental health.

A key issue is the reduced access to mental health services in affected regions. Rural and remote communities already face limited availability of mental health specialists, psychiatrists and emergency care. As economic conditions tighten and populations decline or disperse, service access can become even more constrained, reducing early intervention and support options.

These challenges are reinforced by sociocultural factors characteristic of many Basin communities. Strong norms of self-reliance, stoicism, and a reluctance to seek help, particularly among men, contribute to lower engagement with mental health services and higher levels of perceived stigma. This can delay treatment and exacerbate mental health conditions.

At the same time, communities are dealing with significant environmental and economic stressors, including the impacts of water policy changes alongside climate variability. Prolonged and severe drought has had a well-documented effect on mental health outcomes. Research indicates that each additional month of extreme drought within a 12-month period is associated with a 32% increase in monthly suicide rates in rural areas, highlighting the acute sensitivity of these communities to environmental stress.

Taken together, the interaction of reduced service access, cultural barriers to help-seeking, and heightened environmental and economic pressures suggests that the Basin Plan's impacts extend beyond economic adjustment, contributing to increased mental health risks and social strain in affected communities.

As indicated by the statistics outlined in the images below, the Murray Primary Health Network suicide death rate has remained above the national average in recent years.

The Murrumbidgee Primary Health Network suicide death rate also rose over the past decade and remains above the national average.

[INSERT IMAGES FROM PAGE 8 OF THE PDF: Murray PHN and Murrumbidgee PHN suicide death rate charts]

6. Failure to Recognise Past Water Reform

Over the past three decades, irrigators have already contributed substantial volumes of water to environmental flows through reforms and water recovery programs. For example, Voluntary Contributions.

In 2002 irrigators in the Murrumbidgee and Murray regions were coerced into contributing water entitlement to the State Government on the proviso that it would be reviewed after one year and then again after five years. Time has passed and these "Voluntary Contributions" (VC) were just rolled into what now is the NSW Water Sharing Plans with no review. The State Government was gifted much of this acquired water and despite the fact that most of it was General Security Entitlement, these significant parcels of water have the highest priority in any watering year. However, irrigators are still required to pay the fixed fees and charges for this water. Allocation announcements in our valleys are impeded at the start of each season to cover off these amounts.

Irrigators and rural irrigation communities bear the financial burden for providing politically inspired, ecological goods and services.

The MDBA sets the basin rules and NSW Department of Climate Change, Energy, the Environment and Water (DCCEEW) manage this acquired water with little transparency or accountability. There has been no socio-economic monitoring or research to quantify the impact on NSW communities.

DCCEEW has the ability to sell water to cover costs. This water is being sold back to regional rural communities at inflated prices when it was originally allocated to communities in the first instance.

Rural Communities want this water returned to their rightful owners i.e. General Security and High Security irrigators in the Murray and Murrumbidgee.

We now have the overarching MDBP where we watch Federal Government buying vast amounts of productive water and squirreling it away, resulting in allocation announcements being further impeded.

Farmers believe their contribution has not been adequately recognised. Instead, irrigators are often portrayed unfairly as environmental threats despite significant investment in efficiency and sustainable farming practices.

7. Infrastructure Built for National Food Security

Major dams such as Burrinjuck and Blowering were built with a clear purpose:

  • Support irrigation

  • Generate hydroelectric power

  • Secure national food production

The Murrumbidgee Irrigation Area remains one of the most efficient gravity-fed irrigation systems globally. Reducing water available to this system effectively undermines decades of national infrastructure investment.

8. Lower Lakes Management

Many Basin stakeholders believe that the management of the Lower Lakes requires serious reconsideration.

Issues requiring investigation include:

  • A review of the science associated with the SA Lower Lakes

  • Operation of barrages

  • Evaporation losses

  • Water management for Adelaide

  • Potential estuarine management options

These matters have also been raised by Basin advocates, including myself, who has proposed returning the Lower Lakes closer to their natural state while improving desalination capacity for South Australia.

9. Loss of Farming Skills and Future Generations

Uncertainty surrounding water policy has discouraged young people from entering agriculture.

Generational farming knowledge is at risk as families exit the industry due to policy uncertainty.

This loss of experience and expertise will have long-term consequences for Australia's agricultural productivity.

10. The Water Act

Many stakeholders believe the Water Act 2007 places disproportionate emphasis on environmental outcomes without adequate consideration of social and economic impacts.

Restoring confidence in Basin communities will require revisiting the Act to ensure a genuine triple bottom line approach.

11. Climate Variability and Data Interpretation

The MDBP has largely been justified using data from drought periods. However, Australia's climate is characterised by extreme variability, including cycles of drought and flood.

Recent flooding in the Wentworth district highlights the need for long-term hydrological analysis rather than short-term datasets.

12. Conveyance Water

The classification of conveyance water within the Murray-Darling Basin water accounting system needs to be reviewed. Conveyance water, when delivering water for environmental purpose, should be included within the environmental water category rather than treated as a separate operational category.

Currently, conveyance water is allocated and tracked separately from environmental, consumptive and urban water. However, this system creates a disconnect between the actual volume of water extracted from the system for environmental purposes and the volume that is counted as "environmental water."

The water delivered to an environmental site does not arrive in full, and yet the system loss is not attributed to the environmental account. This results in an understated environmental water footprint and may skew accountability for how much water is needed to achieve genuine environmental outcomes.

As the MDBA clearly outlines, conveyance water accounts for losses from evaporation, transpiration and seepage between the point of release and the point of delivery. These losses can be significant, especially in dry and hot years. When water is delivered for irrigation or urban use, these losses are built into total delivery volumes. However, when delivering water for the environment, these losses are drawn from the conveyance pool, not from the environmental water account itself.

Accounting methods should be revised so that:

  • Conveyance losses incurred in the delivery of environmental water are recorded against the environmental water account, just as they are for other users.

  • The total environmental water take reflects the actual system impact of environmental watering.

    • The loss of this conveyance water from the productive sector is counter-productive to the environment because it forces more intensive farming practices to make up for the loss in production. This includes more use of chemicals, fertilisers and so forth.

    • The Basin Plan is predicated on improved accounting and accountability. Despite the obvious evidence to the contrary, the ongoing failure to recognise that conveyance water is returning to the environment is not just a significant economic drag, which is undermining communities within my electorate and throughout the Basin, it is a failure in responsible governance.

    • There is an opportunity to label and control a significant volume of water to demonstrate how it has been returned to the environment and how the objectives of the Basin Plan have been met.

Incorporating conveyance into the environmental water category would not reduce the amount of water reaching environmental assets. It would simply ensure that the environmental water footprint is measured in the same way as other users, such as irrigators, who already account for these losses.

This change would improve the fairness, transparency and accuracy of environmental water accounting in the Murray-Darling Basin and help ensure a more balanced approach to managing the river system for all stakeholders.

13. Metering and Monitoring

The Federal Government need to include proper metering and accountability for water entering the Southeast Drainage network in South Australia, with consideration for redirecting appropriate flows to the Coorong to support environmental outcomes. These savings could contribute to the water buyback program.

The Commonwealth should strongly encourage the NSW Government to make up its commitment to the buyback shortfall by selling Government-held water, available for the 450GL buyback water recovery, rather than sourcing this water from the private irrigation market.

Market-based buybacks continue to place enormous pressure on NSW's food-producing regions. When buybacks target private entitlements, they push water prices higher, increase the cost of Australian-grown food and fodder, reduce disaster resilience and undermine already strained sectors such as dairy, rice, horticulture and broadacre cropping. These impacts cascade into job losses, weakened regional economies and declining national productivity.

A direct transfer of the buyback shortfall from NSW-held accounts to the Commonwealth is the practical and least damaging way to meet Basin Plan obligations. This approach protects rural irrigation communities, stabilises markets and prevents further economic and social decline in regions that already shoulder a disproportionate share of water reform impacts.

NSW is falling behind in productivity. Further erosion of irrigated agriculture will worsen this trend. A State-to-Commonwealth transfer avoids unnecessary harm while delivering certainty to Basin planning.

The Commonwealth should urge the NSW Government to establish a public, unified water transparency dashboard, accounting for all State and Federal holdings, trades and environmental flows. Public confidence requires clarity, current data and accessible science.

Meeting Basin Plan requirements should not come at the expense of the communities that sustain Australia's food security and regional economies. Metering and redirecting the drains to the Coorong and a direct transfer of NSW-held water to the Commonwealth to make up NSW's shortfall is the responsible path forward.

14. Reconnecting Rivers Program Concerns

The proposed Reconnecting Rivers Program represents a fundamental shift in land and water use that will have serious and irreversible consequences for landholders, agricultural production and regional communities.

At its core, the program relies on acquiring easements over private land to allow managed inundation, in some cases as frequently as every second year. This approach raises critical concerns.

The "Reconnecting Rivers" program was conceived as an ambitious environmental restoration effort aimed at reversing decades of human interference in natural waterways. By removing dams, restoring floodplains, and re-establishing natural flow patterns, the initiative promised ecological renewal, improved biodiversity and long-term sustainability. However, in practice, the program has become a nightmare for landholders highlighting when planning, execution and stakeholder alignment fall short.

At the core of the program's failure was an underestimation of system complexity. Rivers are not isolated entities; they are deeply interconnected with agriculture, urban infrastructure, energy systems and local economies. Removing or modifying river barriers without fully modelling these dependencies led to unintended consequences.

Another major issue was fragmented governance and poor coordination between stakeholders. The program involved multiple agencies, private contractors, environmental groups and local governments, each with different priorities and timelines.

Data mismanagement has further compounded the problem. The program relied on outdated or incomplete environmental data, and there was no centralised, real-time monitoring system to track the impact of interventions.

Local communities are often directly affected by the changes and often excluded from meaningful participation. Ultimately, the disaster of this program lies not in its vision, but in its execution.

Among the most pressing concerns raised by landholders and regional communities are the following:

  • Loss of usable farmland: areas may be permanently or seasonally inundated

  • Reduced agricultural output: especially for crops or grazing on affected land

  • Changes to property access: roads or crossings may be impacted by water flows

  • Uncertainty and risk: unclear long-term impacts on land value and productivity

  • Infrastructure adjustments: need to modify fences, pumps, levees, or irrigation systems

  • Potential financial burden: costs associated with adapting to new conditions

  • Need for consultation: importance of involving landholders in planning decisions

  • Compensation and incentives: critical for maintaining fairness and participation

15. Floodplain Management Program

The Floodplain Management Program, as currently implemented alongside the Reconnecting Rivers approach, has raised serious concerns across the Murray electorate.

Rather than delivering coordinated outcomes, it has created uncertainty, disruption and escalating costs, with insufficient engagement of the very communities most affected.

Limited and Inadequate Consultation

Across communities such as Deniliquin, Finley, Berrigan and Wakool, landholders consistently report:

  • Consultation occurring late in the process, after decisions are effectively made.

  • Information provided that is technical, contradictory, incomplete, or difficult to interpret.

  • Limited opportunity to influence outcomes.

  • Lack of genuine consultation, it's just a tick-the-box exercise.

Community Disruption

The program is already creating disruption at a local level, including:

  • Uncertainty around land use and future viability.

  • Strain on relationships between agencies and landholders.

  • Anxiety for families unsure about long-term impact.

In irrigation-dependent areas, even the prospect of flooding regimes and easements affects:

  • Property values

  • Succession planning

  • Business confidence

This uncertainty alone is having a real economic and social cost.

Excessive and Unclear Costs

There is growing concern about the cost-effectiveness of the program, including:

  • Significant public expenditure with unclear measurable outcomes

  • Administrative and compliance costs across multiple agencies

  • Potential duplication with other Basin Plan initiatives

At the same time, landholders are expected to bear ongoing productivity losses and communities face economic contraction. The question remains: who is carrying the cost and who is benefiting?

Poor Coordination and Governance

The Floodplain Management Program appears to operate across multiple layers of government and agencies, leading to:

  • Confusion about roles and responsibilities

  • Delays in decision-making

  • Inconsistent messaging to landholders

This fragmentation undermines confidence and accountability.

Lack of Clarity on Long-Term Outcomes

Key uncertainties include:

  • Frequency and extent of inundation under proposed plans

  • Long-term impacts on soil health, salinity and productivity

  • Measurable environmental outcomes versus projected benefits

Without clear benchmarks, there is a risk of significant disruption without proven gain.

In summary there is limited consultation processes in place to ensure early and genuine engagement with Murray communities, or to provide clear and accessible information on impacts, risks and timelines. The program should:

  • Undertake a full cost-benefit analysis, including regional economic impacts

  • Streamline governance to ensure clear accountability across agencies

  • Guarantee no forced participation or indirect coercion of landholders

  • Establish transparent reporting on environmental outcomes vs costs

Across the Murray electorate, the Floodplain Management Program is not being experienced as a collaborative environmental initiative. Instead, it is being experienced as a top-down process that is creating uncertainty, cost and disruption.

Without meaningful consultation, clear accountability and demonstrable outcomes, the program risks losing community confidence entirely.

An urgent recalibration is needed. One that respects both the environment and the people who live and work within it.

16. European Carp

The widespread presence of European carp continues to have a devastating impact on our river systems. Carp disturb sediments, increasing turbidity and making the water muddier. This reduces light penetration, damages native aquatic plants and increases sediment and nutrient suspension, which contributes to poor water quality.

Despite long-standing awareness of the issue, there has been limited effective large-scale control and populations remain high across the Murray system.

Any program increasing floodplain connectivity must also address the risk of expanding carp habitat and breeding opportunities.

Declining Water Quality

Across many parts of the Murray and associated systems, landholders are observing:

  • Increased turbidity

  • Reduced dissolved oxygen levels

  • Greater variability in water quality

These conditions are not conducive to:

  • Native fish populations

  • Livestock watering

  • Irrigation use

  • Human health

Environmental water delivery without water quality safeguards risks doing more harm than good.

17. Blue Green Algae

There is increasing concern about the frequency and severity of blue-green algae (cyanobacteria) outbreaks:

  • They are linked to warm, slow-moving, nutrient-rich water

  • They pose risks to human health, livestock and irrigation systems

  • They can render water unusable for extended periods

Changes to flow regimes, including managed inundation and altered delivery patterns, may:

  • Increase stagnant water conditions and mobilise nutrients from floodplains

  • Exacerbate algal bloom events

These risks must be explicitly addressed in program design.

18. Disconnect Between Water Recovery and Outcomes

There is a growing perception that water recovery (GL targets) is being prioritised. Other measurable ecological outcomes such as water quality, native fish recovery and reduced algal events should also be included.

Without clear improvements in these indicators, the effectiveness of current policy settings must be questioned.

What needs to be done is to:

  • Prioritise water quality outcomes as a core success metric of all Basin programs

  • Implement a coordinated carp control strategy alongside any floodplain reconnection

  • Require independent monitoring of turbidity, dissolved oxygen and nutrient levels

  • Incorporate algal bloom risk assessments into all flow and inundation planning

  • Ensure environmental water delivery is adaptive and responsive to water quality data

  • Increase transparency with public reporting on ecological indicators, not just water volumes.

The health of the Murray-Darling Basin cannot be measured solely in gigalitres recovered.

19. Sustainable Diversion Limit (SDL) Program

The intent of the Sustainable Diversion Limit (SDL) under the Murray-Darling Basin Plan was to strike a balance between environmental sustainability and productive water use.

However, the implementation of the SDL framework has failed to deliver genuine environmental outcomes on the ground, particularly across inland NSW.

SDLs are being met "on paper", not in rivers

While governments report compliance with SDL targets, this is largely achieved through:

  • Accounting measures

  • Modelling assumptions

  • Offsets via SDL Adjustment Mechanism (SDLAM) projects

There is a growing disconnect between reported compliance and actual river health, evidenced by:

  • Increased fish kill

  • Declining water quality

  • Reduced river connectivity

SDLAM projects have weakened real environmental flows

SDLAM projects allow Governments to reduce the volume of water returned to the environment by claiming equivalent outcomes through infrastructure. In practice:

  • Benefits are often modelled rather than measured

  • Projects prioritise site watering over system-wide flows

  • Large sections of river are left stagnant or disconnected

This has resulted in less functional water in the system, despite claims of compliance.

Environmental water is not reaching where it is needed

Significant volumes of environmental water are:

  • Held in storage

  • Delivered infrequently

  • Used to meet system constraints rather than ecological needs

This means critical assets such as Creeks, Anabranches and Terminal lakes are often deprived of timely flows, contributing to ecological stress.

Lack of accountability for environmental outcomes

There is no clear mechanism to:

  • Audit whether environmental outcomes are actually achieved

  • Hold agencies accountable for ecological decline

  • Respond effectively to repeated fish kills

The focus remains on volumes recovered, rather than outcomes delivered.

Community and regional impacts ignored

The SDL framework has:

  • Reduced water availability for productive use

  • Created uncertainty for irrigators

  • Delivered limited visible environmental benefit

  • Hollowed out rural irrigation communities

At the same time, communities report:

  • Poor consultation

  • Increased flooding risk from infrastructure projects

  • Loss of confidence in water governance

In summary the SDL program, as currently implemented, has become a system of compliance reporting rather than environmental recovery. Without reform, it risks:

  • Continued ecological decline

  • Ongoing community disillusionment

  • Misallocation of public funds

20. The Need for a National Agriculture Plan

Australia currently lacks a coordinated, long-term national agriculture plan, leaving the sector exposed to fragmented policy, rising input costs and increasing climate volatility.

This is particularly evident across the Murray-Darling Basin, where water, energy and food production policies operate in silos rather than as part of an integrated system.

Food security is not being treated as a national priority

Australia produces high-quality food, yet there is no overarching plan to guarantee domestic food security. Without a national framework:

  • Productive water is reallocated without considering food production impacts

  • Prime agricultural regions face declining reliability

  • Australia becomes increasingly exposed to global supply shocks

  • A national agriculture plan must recognise that water policy is food policy.

Water policy is disconnected from agricultural outcomes

The Murray-Darling Basin Plan has focused heavily on water recovery targets, but:

  • There is limited alignment with agricultural production needs

  • Environmental outcomes are often modelled rather than realised

  • Productive capacity in key regions is being eroded

A National Plan must ensure that water recovery does not come at the cost of long-term food production.

Sovereign capability is at risk

Agriculture depends on:

  • Water

  • Fuel

  • Fertiliser (urea, phosphate)

  • Transport and logistics

  • Chemicals

  • Suitable land

Australia has reduced its domestic capacity in these areas, creating strategic vulnerability. A National Agriculture Plan should include:

  • Domestic fertiliser production strategies

  • Fuel security for regional industries

  • Protection of critical supply chains

Regional economies are being undermined

Agriculture is the backbone of regional Australia. Policy instability has led to:

  • Reduced investment confidence

  • Job losses across supply chains

  • Declining regional populations

Without a coordinated plan, regional communities carry the burden of policy decisions made without local consideration.

Climate variability requires coordinated national planning

Droughts, floods, and extreme weather are increasing in frequency and intensity. A national plan must:

  • Support resilient irrigation systems

  • Encourage water storage and reuse

  • Integrate environmental and agricultural water use, not treat them as competing priorities

Fragmented governance is failing outcomes

There are multiple Federal and State agencies involved in water and agriculture, resulting in:

  • Duplication

  • Conflicting objectives

  • Poor accountability

A National Agriculture Plan must streamline governance and ensure clear responsibility for outcomes, not just policy delivery.

Australia cannot continue to rely on piecemeal policy in a sector as critical as agriculture. A National Agriculture Plan is urgently required to:

  • Protect food security

  • Align water policy with production

  • Strengthen sovereign capability

  • Support regional communities

Without it, Australia risks becoming a nation that exports raw commodities while importing food.

21. Constraints

While it is acknowledged that the MDBA has begun to recognise some of the concerns raised, significant issues remain unresolved. Most critically, the modelling underpinning the Basin Plan, particularly the flow targets for South Australia, the Coorong, Lower Lakes and Murray Mouth, appear fundamentally flawed. Until this is properly addressed, the constraints relaxation process risks becoming an expensive exercise that fails to deliver meaningful outcomes.

There are ongoing concerns about the practical risks associated with relaxing constraints. Proposed flow ranges of 25,000 to 45,000 ML/day leave very little margin for adjustment if conditions turn wet, significantly increasing the likelihood of flooding. This risk is compounded by the lack of clarity around the timing and duration of flows. The current emphasis on spring environmental releases is particularly concerning, as this is already the highest-risk period for natural flooding. At the same time, other periods may experience reduced flows, declining water quality and increased environmental stress.

A key concern for landholders is the potential introduction of river operator immunity. If operators are protected from liability, this would effectively weaken, or override, existing protections for landholders, leaving them exposed to risk without meaningful recourse.

Confidence in the modelling and mapping used to guide decision-making also remains low. In many cases, data has proven to be inaccurate or inconsistent with on-ground experience. Incorporating local knowledge is essential to ensure a realistic and reliable understanding of how water moves through these systems.

The justification for higher flows under climate change scenarios also warrants closer scrutiny. Relaxing constraints during already wet conditions appears unnecessary and may further increase flood risk, particularly when combined with rainfall events. This approach requires more careful evaluation.

Consultation to date has not met expectations. Landholders require genuine engagement, clear communication and access to reliable information. There must also be fair and practical pathways for compensation or mitigation where impacts occur. Concerns relating to farm productivity, land access, safety and long-term land value are legitimate and must be properly addressed.

At the same time, there is an opportunity to pursue more targeted environmental outcomes. Leveraging existing irrigation infrastructure to deliver water with greater precision, such as to on-farm wetlands, could achieve improved results without relying on broad, high-risk flow events.

In summary, there must be a stronger focus on getting the fundamentals right: accurate modelling, genuine consultation, fair protections for landholders and clear evidence that proposed actions will deliver intended benefits without causing unnecessary harm. Without this, there is a real risk the current approach will fall short for both communities and the environment.

Pushing flows of 80,000 ML/day across the South Australian border for five weeks is not realistic without significant consequences. At that scale, flooding is not a possibility, it is inevitable. Large areas of private land, towns and critical infrastructure would be inundated. The plan itself acknowledges this, outlining extensive mitigation measures such as relocating pumps, raising roads, upgrading crossings, installing stormwater systems and negotiating with landholders to permit inundation of their land.

Even with these measures the impacts would be substantial, including community disruption, infrastructure damage and long-term land degradation, including erosion. The extent of the mitigation required highlights that the system is not designed to accommodate flows of this magnitude.

22. Bureaucracy

More than 30 different agencies now control water across the Murray and Murrumbidgee. These range from the Murray-Darling Basin Authority to State departments, Environmental Water Holders and delivery bodies, many of which duplicate roles, shift responsibility and add layers of cost. The result is a system where no one is clearly accountable, decisions lack transparency and the growing bureaucracy is driving up water prices. In the end, it is not the agencies that pay, but rural irrigation communities which are being priced out of existence by a system that is supposed to support them.

Below is an example of the complexity of water management. It is difficult to include every organisation involved, but the lack of responsibility and accountability is stark.

For example:

  • There is no single agency exclusively responsible for measuring and reporting on all aspects of water quality.

  • Water holdings are not located on a single portal, so tracking of environmental water accounts and environmental outcomes is difficult.

[INSERT IMAGE FROM PAGES 20 TO 21 OF THE PDF: water agency complexity diagram]

23. Murray Darling Basin Authority

When it comes to the Murray-Darling Basin Authority, there is a growing concern that the system is not as independent or transparent as it needs to be. At the moment, the Authority is often in the position of both delivering Basin policies and then turning around and assessing how well those same policies are working. That kind of "marking your own homework" setup naturally raises questions. Without clear independence in oversight and evaluation, it becomes difficult to have full confidence that outcomes are being measured objectively. There is a real risk that institutional pressures, or even just unconscious bias, can shape how success is defined and reported.

For communities across the Basin, including farmers, rural towns and environmental stakeholders alike, this lack of independence can feel frustrating and, at times, erode trust in the system. People want to know that decisions about water use, environmental flows and compliance are being checked by parties who are genuinely at arm's length.

Strengthening independent review processes, whether through external audits or more transparent reporting structures, would go a long way toward rebuilding that confidence.

Ultimately, ensuring that the Authority is held to account by truly independent mechanisms isn't about criticism for its own sake, it's about making sure the Basin is managed in a way that is fair, credible and sustainable for the long term.

Solution

I have identified seven essential principles that any reform must include. DO THESE 7 THINGS TO FIX THE MURRAY-DARLING BASIN:

1. No Buybacks If They Hurt Communities

It used to be illegal for the Federal Government to buy water from the Murray-Darling Basin system if those purchases were going to have a negative socio-economic impact on communities. But recently, Federal Labor quietly scrapped this law so it could buy up water for political reasons, even though it will mean destroying rural towns and cities. This law preventing social hardship needs to be re-instated immediately.

2. No More Fake Lakes

The entire Murray-Darling Basin system is rigged to provide fresh water to South Australia's Lower Lakes which have been proven to be historically estuarine, naturally filled with tidal salt water and fresh water. They are fake lakes, closed off from the sea by man-made barrages. This is unnatural and is destroying the Coorong.

3. Let SA Make Its Own Water

South Australia has a desalination plant it barely uses. This plant could provide half of all the water needed for the State. South Australia is the driest State in the driest continent on earth. It needs to start making its own water. "It's not hard. It just needs common sense."

4. Count Each Drop Properly

The accounting of water in the system is a disaster. Floodplain harvesting in the north isn't monitored and accurate water metering doesn't happen in many parts of the Basin. Meanwhile environmental flows are estimated and not measured and flood events don't contribute towards these flows. This is made worse by the fact that different Governments count the flows in different ways. We need one trusted entity to count each drop properly so we can make sensible decisions about the Basin.

5. Quality Over Quantity

The Federal Government has been obsessed with having more water while ignoring poor water quality issues like pollution, salinity, and invasive species like carp. We must rid our rivers of carp and pollutants so we can have better quality water for farming, the community and the environment.

6. Ban Government Floods

As part of its disastrous mismanagement of the Murray-Darling Basin, the Federal Government now wants the right to flood private properties, year after year, to get water to certain rivers, wetlands, and floodplains. These Government floods will devastate regional communities and cannot be allowed to happen.

7. Increase Water Capacity and Downstream Storage

One of the key solutions to addressing water shortages in the Murray Darling Basin is to expand water capacity and improve downstream storage. By increasing the storage capacity of key infrastructures like Burrinjuck Dam and utilising Lake Coolah as an additional water storage facility, we can ensure a more reliable supply of water for irrigation, communities, and the environment.

Unfortunately, many Basin communities believe these principles have not been adequately incorporated into the Plan's implementation.

This submission will use Griffith as an example, but this is only one part of the story of Murray. Right across the Murray electorate agricultural production and processing underpins the community producing 4 billion of economic output.

Conclusion

Key reforms should include:

  • Streamlining bureaucracy with distinct areas of accountability

  • Federal Royal Commission in the Murray Darling Basin Plan

  • A moratorium on harmful water buybacks

  • Increased investment in irrigation infrastructure

  • Transparent environmental watering strategies

  • A comprehensive review of Lower Lakes management

  • Reassessment of the Water Act to restore triple-bottom-line principles

  • An audit of all environmental water to be located on the one portal

  • An end to the Reconnecting Rivers Program

  • A review of Flood Plain Management plans

  • The beginning of genuine consultation

  • A review of the duplication of water agencies

  • Carp control: introduce the herpes virus

  • Inclusion of all other complementary measures

  • Rainfall to be counted and netted off against environmental commitment

  • Water losses downstream of the choke should be borne by those requiring the water rather than those general security irrigators above the choke

  • Improved water management

  • An independent assessment of the Murray-Darling Basin Authority rather than marking their own homework

  • Honesty from the MDBA chair

The Basin is not only an environmental asset; it is the engine room of Australia's food production. Any policy framework must therefore protect both the river system and the communities that depend upon it.

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Submission to the Review of the Water Act 2007 (Cth)