[Your Name]
[Address line 1]
[Address line 2]
[email contact]
Water Reform Project, Water Policy Division
Department of Natural Resources and Mines
PO Box 15216
City East QLD 4002
Email: waterreform@dnrm.qld.gov.au; edoqld@edo.org.au;
[INSERT date]
Dear Sir/Madam,
Submission on Consultation Regulatory Impact Statement – Strategic Review of the Water
Act 2000
Thank you for this opportunity to provide comment on the proposed changes to the water regulatory
framework in Queensland under the Water Act 2000 (Qld) (Water Act).
Water is an important natural resource and a precious ecological asset in Australia. The
amendments proposed in the Consultation Regulatory Impact Statement (RIS) include many highly
concerning elements which weaken the regulation of our water resources. A policy of making
business easier for industries and other water users must not be implemented at the cost of our vital
resources.
I outline these key issues for your consideration:
1. Water users given too much power to assess and regulate. It appears the responsibility
to assess and monitor water is proposed to be largely given to water users themselves. This
is a dangerous move that may result in abuse of these powers and unsustainable
management of our water. To avoid this, government or government certified third parties
must be adequately empowered and funded to monitor water use. Caution must be taken
particularly around proposals to require landholders to self-regulate the metering of their
water use, the cumulative impacts in areas where certain water use activities will no longer
require licences, and the increased reliance on the environmental impact authority studies
produced by the proponent of large scale water use projects to assess water use, as
discussed further below.
2. Weakened assessment of large scale water users. The assessment of water use by large
scale water users will be undertaken only using information prepared by the proponent, or
consultants paid by the proponent, in their environmental impact assessment. Large scale
water use, which needs the most thorough assessment, will not have to go through the
Water Act assessment process.
3. Maximum take amounts must be ensured for mineral and coal resource projects. The
proposal to give mineral and coal resource projects a statutory right to take associated
groundwater, in line with petroleum and gas water use regulation, must provide for maximum
volumes of associated water that can be taken by these companies, to protect water
resources from unregulated taking of precious groundwater supplies.
We support the monitoring and reporting obligations on these users being extended to all
areas in which use occurs, not limited only to where groundwater management areas exist.
We further support the move to provide statutory obligations for mineral and coal proponents
to enter into make good agreements with bore owners in order to protect bore owner rights.
4. Certainty in water regulation. We support the transition from Special Agreement legislation
to having all water rights established under the Water Act. This will allow for greater certainty
and consistency in the regulation of water use.
5. Increased regulation of unnecessary water use by petroleum and gas industry. The
proposal to take away the statutory right to use non-associated groundwater, currently held
by the petroleum and gas industry, should be taken up to ensure groundwater reserves are
sustainably used, particularly in light of the significantly higher demand the increasing shale
industry will place on these reserves.
6. Environmentally sustainable management of water must remain the key purpose of
the Water Act. Economic considerations are already adequately provided for in the existing
purposes of the act. The central purpose of the act must remain the management of this vital
resource in a way that sustains it in perpetuity.
7. Public notification procedures must be clear and consistent. While we support the
move to provide notification opportunities in one place on the internet, the move towards
more ‘flexible’ public notification procedures must still ensure that the public clearly
understands how to easily inform themselves of opportunities for public comment in decision
making around water regulation issues.
8. Reductions in regulation of low risk projects may lead to high risk impacts. The
proposal to remove assessment and licence obligations, including public notification
procedures, for ‘low risk’ water use activities must be managed to ensure it does not lead to
cumulative impacts on water resources.
9. Great Artesian Basin must be adequately protected until better understood. There
have been insufficient studies done to properly understand the water resources of the Great
Artesian Basin. We do not support proposals to promote significant use of GAB water while
this important water system is not yet understood.
I urge the Government to address the concerns outlined above. There have not been adequate
studies done to properly understand our water resources, particularly groundwater resources.
Adequate regulation is integral to ensure our water supplies remain sustainable for today’s users
and future generations.
Yours sincerely,
[insert name]