Public submission

to water market rules issues paper

Prepared by

Lyn Davies

Greenhide Joint Water Supply Scheme

PO Box 84

TRANGIE NSW 2823

.

9 May 2008

The Greenhide Joint Water Supply Scheme (GHJWSS) is part of the Macquarie River Food and Fibre, the peak irrigation body representing all irrigators in the Macquarie valley, and wishes to advise that it has had substantial input into and supports its submission fully.

GHJWSS an off-river Scheme holding a Water Access Licence (when it is issued by DWE) totalling 7500 megalitres with 4 members and draws water from the regulated section of the Macquarie River.

GHJWSS has approximately 20 kilometres of channel and was setup and paid for by its members to irrigate land away from the river. Its operating structure is an unincorporated association bound by a Deed of Constitution dated 24 September 1974. A committee is elected from the members and operates GHJWSS on a day to day basis, setting fees and charges and keeping all records. Members on GHJWSS have varying size entitlements and GHJWSS was created around a socialised transmission loss as well as capital and operating expenses being charged on a pro-rata basis.

GHJWSS members fully support and promote efficient use of water, and has allowed water trading between its members since it was established in 1968 except where physical constraints apply. GHJWSS also allows water to be traded outside to the riparian areas on a temporary annual basis however places certain constraints such as a loss factor and still collects there fees and charges. It is simple for GHJWSS to collect fees and charges because unless a member pays his fees and charges GHJWSS will not sign transfer forms.

GHJWSS reject any suggestion that water can be transformed from a combined Water Access Licence (WAL) to individuals WAL’s unless they have paid a termination fee and relinquished an agreed loss component of their entitlement, otherwise, this would undermine the whole integrity of GHJWSS, leaving existing members with stranded assets.

It should be noted that GHJWSS does not have a separate allocation for transmission losses like the operators in the south and therefore as members transform their entitlements, remaining members are left with the burden of increased fees and charges as well as higher transmission losses. This could mean their right to irrigate is removed if enough members transform their entitlement.

GHJWSS does not agree with tagging after consultation with GHJWSS solicitor. With the separation of land from water and the privacy laws it appears there is no simple solution of recovering fees and the associated legal costs would be prohibitive.

With several of these schemes of varying sizes on the Macquarie River allowing transformation would create a large economic loss to the region and leave large areas of good irrigation country exposed, creating further economic hardship to the towns of Narromine, Trangie and Warren.

GHJWSS believe there was a total lack of understanding and consultation by Department of Water and Energy when amending the Water Act and believe there ability and on going management of the process of conversion and licence transfers should be the subject of an external audit.