QLDcoiwp£rmorMurHOR/ry 1 6 JUL 2012 OAT£ RECEIVED Queensland Competition Authority, file ref:444089 Level 19, 12 Creek Street, BRISBANE. OLD 4001 For the Attention of Angus MacDonald Dear Sir, Subject- Irrigation Prices for Seawater Central Brisbane WSS: 2013-17 We are stakeholders in the Central Brisbane WSS and hold a current license to draw water from the Brisbane River between Wivenhoe Dam and Mount Crosby. We would be extremely concerned should the QCA come to the conclusion that the documentation provided by Seqwater provides a justification for any charge to be made for water taken direct from the Brisbane River under the capped 7000M1 agreement. We note that the Fernvale Consultation meeting of 22nd June was attended by a very small proportion of the 130 License Holders. We consider that the views expressed about the level of charging per ML were not representative of our views or the views of the majority of license holders in the Central Brisbane WSS who attended a meeting of 10th July 2012. We support the views expressed in the attached submission and request the QCA accept this submission on our behalf. Yours faithfully, Signature \AeoJoVe_ Print Name of License Holder, Date /o~? (l^t JB vIR .I... j Promoting Effective Sustainable Catchment Management Submission to Queensland Competition Authority In relation to Seqwater Rural Water Supply Network Service Plan For the Central Brisbane River supply scheme On Behalf of The Members of Mid Brisbane River Irrigators Inc This submission is prepared under 3 main headings 1. Substantiation for there to be no charges for the 7000ML of irrigation water to be taken from the Central Brisbane River. 2. Reasons why the Seqwater submission outlining costs is flawed. 3. Suggestions as to how improved productivity(maximum use of current licensed allocations) can be addressed under a no charge regime. 1. Justification for the 7000ml irrigation water to be taken free of charge a) Neither Somerset nor Wivenhoe were financed and built for irrigation. (b) In the 70 years since the completion of Somerset Dam and 30 years since completion of Wivenhoe, irrigators have never been required to pay water charges for drawing water from the river, despite a number of attempts in the past to do so. (c) This matter was clarified once and for all in 1981 that the dams were constructed for domestic water supply and flood mitigation and not for the purpose, in part or whole, for irrigation, (attached submission 24-2-1981 to Minister of Water Resources & response to T.G. & LA. Matthews 21-10-1981) ( (c) Neither Seqwater, nor its predecessor have expended funds, either capital or operating, dedicated to the delivery of bulk untreated water for irrigation (d) This stretch of the river has never needed either Somerset Dam or Wivenhoe Dam or any other Infrastructure, to store water, and water has always been available for irrigation. (e) Seqwater cannot identify the cost of any service that is used by irrigators in drawing water for irrigation purposes. This makes the current proposed charge, struck on a per megalitre basis, unrelated to the actual cost of a service to irrigators, and therefore at law should neither be recommended nor allowed by the Queensland Competition Authority On the other hand the irrigators can point to several ways in which they have contributed to reducing Seqwaters costs and assisting with environmental obligations. (f) Involvement of irrigators with SEQCatchments in Catchment improvement. (g) During the millennium drought, raising the level of awareness and keeping the land adjacent to the river green, grassed, and productive. This action assisted in the control of treatment costs by reducing the volumes of sediment that accessed the river. (h) Delaying the closure of the Brisbane Valley Hwy at times of flood. (Zanow Quarry) (i)Members with local knowledge kept Seqwater informed about conditions on the river. (j) MBRI and its committee contributed $40000 in Counsel fees and 1000's of hours professional pro bono work to prepare submissions and be represented at the Queensland Flood Commission. We consider this work assisted Seqwater and was influential in the Final Report by the Flood Commission. 2. The following items directly address the relevance of the group of costs that Seqwater have submitted for QCA assessment, and which Seqwater state make up an appropriate contribution from the irrigators. (a) It is inconceivable that the Irrigators should be charged in any way for the cost of operation of Somerset Dam, Even if one discounts the reasons given in Section l(above) we are unable to see why QCA should consider it can reasonable, fair, appropriate, or even sensible, to charge irrigators for holding the same water twice? All Somerset operation maintenance and staffing costs should be removed. (b) Even if it is considered that a proportion of the operation and maintenance costs should be charged the current ratio of 2.4% is not sustainable. This ratio is based on allocation and covers all the variable costs allegedly resulting from these water volumes. However there is no proof of usage, no warranty on water quality or volume. There is no compensation should dam water damage our equipment, or our land, through mismanagement. No guarantee that irrigators will be warned about deliberate releases within dam management control with the potential to cause damage. There remains a right to for Seqwater to recover from irrigators costs in excess of those nominated, for matters beyond the control of dam management. These costs are more than likely to be a double penalty for the Irrigators who may already have incurred similar costs of their own. (c) In the period 2004 to 2012 there is no doubt that the full allocations have not been used. There are two primary reasons which are, reduced allocation available from Seqwater/DERM and extraordinary weather. Neither are within the control of the irrigator yet the result of these circumstances is that the irrigators cost of water under the Seqwater proposal would be $175,84. This would be on top of failed crops due to failed water supply, and a 75% reduction in income during probably 4 of those 7 years-another double penalty. (d) We understand from Somerset Regional Council that Seqwater resists requests from Council to increase the opportunity for the community enjoyment of their extensive areas of land for recreation. The reason is given, that it will Increase the cost of water treatment. Why should the irrigator pay towards the up keep of these community service provisions when they are under-used in order to save treatment costs to the benefit of Seqwater. 2{e) The Seqwater cost structure includes provisions for maintenance to redundant equipment which is contrary to our understanding of what would be considered eligible costs. (f) Seqwater see the cost of water harvesting (pumping into off-stream storage) in systems unconnected with Central Brisbane, as a legitimate part of irrigators costs. This seems extraordinary and inappropriate. (g) Seqwater documented the fact that the Lowood/Fernvale and the Central Brisbane Flood plain is used in a deliberate strategy, to be sacrificed to assist reducing flood levels in Brisbane. This information was not shared with Somerset Regional Council or the irrigators prior to January 2011. Neither is it planned to be changed. This created considerable cost to Irrigators from the Wlvenhoe Dam water releases in Jan 2010 & Jan 2011 due to damage/destruction of pumps, associated infrastructure & riverbanks where pumps were located resulting in disruption/cessation of production." After the flood, releases from Wivenhoe regularly incurred high operational cost and risk. This should be discounted against Seqwater's cost. 3. The MBRI considers there is a proportion of the 7000ML per annum not being used productively for a variety of reasons. It will support attempts to address ( improved productivity, review the reasons, and suggest a strategy that could reverse this trend. It would be wrong to use an unjustifiable price per ML in an attempt to improve the productivity, so that all irrigators pay an un-affordable unit price when the proper solution should be to encourage the use of these allocations. However it should be noted that the water Licenses issued under the provisions of the Water Act 2000 were not subject to a beneficial use condition, (see letter from Stephen Robertson to Mr Don Livingstone MP on 26th August 2003. ' y ' /> Jisybrr » Queensland Water Resources Commission References 8-1/8341/16 L9216 GPO Box 2454 Telephone 224 7378 Mr. B, Fawcett Brisbane Qijeersland 4001 21 at 0ctob«r, 1931 Messrs. T.G. 8t L,H. Matthews, M.S. 861, FSi&VALS. 4305 Dear ' Sirs, IHRIGATIOM FSCH BRISBANE RIVER wivagos DAM TO MT. GHOSBY WSIB • la April last, irrigators on the Brisbane River batveen V(iveaho« Dam and Mt. Croaby Wair wera advised that charges would be implainented after lat July, 1981 for water diverted from the Hiver for irrigation, I now have to advise that following repreat-ntationa from irrigrvtora, the QoveKmeat has decided that no charge will ha made for water diverted for irrigation. However, the total voluaa of water which may be diverted each year shall not succeed 7 000 oegalitres. Licensees may elect to have either an area allocatica or a. volumetric allocation. If the former is chosen, the area authorised on any property will not exceed 50 hectares vhich ia equivalent to 350 megalitres per year or 7 magalitraa per hectare per year. If an irrigator considers that his anmml use of water will be leas than 7 megalitres per hectare, he may ulect to have a volumetric allocation not exceeding 350 megalitrec per year which uill enable him to irrigate whatever area he wishes, ^providing his wnTmal use does not exceed his authorised allocation In such cases, the licensee will be required to pay for thy supply and installation oi a meter, which shall remain the property of the Cmami leioaer, to rocord annual water use* Because presently indicated requireoentB exceed 7 COO megalitres per year, it will be necessary to adjust some proposed allocations, either area or volume, to reduce the gross allocatisa to 7 000 aegalltres. 2/ • v Mineral House, 41 Geofge Street Brisbane Telex 4176' 2 - 'J'o t-i b" aatoud^d •)./ issued, it wiXl J4v *tx: ;i Loau.-.-et:a ai?6 ipplii yoifi to indicate nftKtth^x- chty ydsh b.t i; ..'u fj coa ci.t v'olujfit i;ru! ^llocfttioa and Rocordljjgly* x "J.orik xorvcej. J co {-AvArr-e .t': -ojt /oy nx-lhin t*J from t'r.j vUte f»x rscoipt oi chJ-f Tgb-LcrIS no xspl-t i;: recu'lvrA. :tt \rp 9flcain<Jd •HUat an nree. ocatioia ic iO"r-i jtuiUd'uSly t. T.? \ W K, Mer^dltUt ^KCHK^AHY. V r Submlaslon to the Honourable The Minister for Wjce- ; 4 Aboriginal and Island Affairs by a deputation apgolnteg by a meeting of landowners hold at Waaora on 24th February. 1981. Sir Irrigators on the Stanley or Brisbane Rivers cowzs-.rea. frora Somerset Dam have never been required to pay charges for the water used. Somerset Dam was constructed under the provisions of Section 6C of the Bureau -cf Industry Act. Tne purposes for which the daai was built are stated in that Section as "For the purpose of ensuring an adequate str^r for the supply of water t> the City of Briabane and the CUj? oi Ipswich, and for the further purpose of preventing as far ^— ' as may be destruction by flood waters in or about the siid cities." The provision of water for irrigatiop. was y-1, a purpose for which the dara was built. The Act for the construction of the ^Ivenhoe Dam does refer to "water storage amongst other things, but does not refer to storage for irrigation, and neither the Premier'a Rrx^rJ-i introducing it i: Parliament nor way other speeches made in relation to the 5ii: make any reference to the need for water for irripation. The financial responsibility for the construction of Somerset Dam was divided between the Government, the Brisbane City Council and the Ipswich City Council, with the BrisM ae City Council being responsible for the major part (SS.eTf! The dam became operational in 1943 but It was not until 1959 that responsibility for i ts control and maintenance was transferred to the Brisbane City Council. That Council was - "iiTO / - then required to bear sotnethlne over 90^ of the costs involved - the balance being made up by the Ipswich City Council Jormal control was handed over in 1950. At no time^befween 1943 and 1959, while the dan remained under Governcieat control, was any suggestion raade that irrigators downstreara should be charged for water. Immediately after control was vested in the Brisbane City Council it applied to the Ooverarnent for the right to cieter ajl pumps, between the dam and Mt. Crosby. The application was refused. There' were further requests on more than one occasion but on each occasio- permission was refused. Statements have been made to the effect that at least one reason for the refusals was the Government's view that there had.always been ample water " - ... for irrigation in the lower reaches of the river and that Somerset^jaapi had not been intended to improve and had'not la However, documentar fact improved the position of irrigators. support for these statements has not been forthcoming at present. Be that as it may, the fact that the statement about ample water, if made, was correct is illustrated by the events of drought years before Somerset came on stream in 1943. On a number of occasions, it is believed in 1902, 1915, 1923, 1937 and linally in 1942 the season was so dry that the Brisbane City Council could not get sufficient water at Mr. Crosby to supply its needs, ^hil© the normal flow in the river ivas adversely affected, there was plenty of water available in long reaches up to a mile or more in length and uj to 30ft. deep. These reaches, however, were separated by sand and gravel bars, preventing sufficient flow to keep Mr. Crosby treatment works supplied. Ilorse teams with scoops were sent