The requirements in division 2 of part 3 have been redrafted to make them clearer and easier to implement. They explain how the quantity of actually taken is allocated so that use does not exceed the SDL, and how this is accounted for each year, including the use of accredited models. The requirements for water resource plans are set out in the proposed Basin Plan in a way that allows water resource plans to be prepared in the most appropriate manner for that area. To provide further assistance, the MDBA is preparing a handbook for practitioners in consultation with Basin states to provide guidance in the application of chapter 9 provisions and the preparation and accreditation or adoption of water resource plans, and respond to the needs of the States. Submissions expressed dissatisfaction that water resource plan requirements did not specifically require Basin states to consult with local communities when preparing water resource plans. RESPONSE MDBA supports comprehensive consultation with communities. A revised provision in chapter 9 requires each water resource plan to set out the consultation that has occurred in relation to its preparation and requires certain consultation to occur in specific circumstances. the various state planning frameworks that states will use to develop water resource plans for accreditation or adoption under the Basin Plan, stakeholder consultation is already a clear requirement to be reflected in the water resource plan. If MDBA is required to prepare a water resource plan (under the relevant provisions of the Act), then section 4.03 of the proposed Basin Plan requires that it do so ‘based on best available knowledge and in consultation with relevant stakeholders’. Also, chapter 9 of the proposed Basin Plan includes some more-specific provisions related to consultation: Part 6 of the chapter states that, in relation to environmental watering, the water resource plans must be prepared having regard to the views of local communities; and Part 14 includes provisions requiring the plan to identify the objectives and management outcomes desired by Aboriginal people for the water resources, having regard to Aboriginal values and uses for those water resources, determined through consultation with relevant Aboriginal organisations. A new provision in chapter 9 requires each water resource plan to set out the consultation that has occurred in relation to its preparation.
RESPONSE The water trading rules provide that water access rights may be traded within a regulated system, between regulated systems, or within an unregulated system, free of any restrictions (including volumetric limits) on changing the location at which the water may be taken. However, the rules provide that certain types of restrictions may be permitted if they are necessary because of physical constraints, the need to address hydrologic connections, the level of hydraulic connectivity and water supply considerations, or for environmental reasons. Any allowable restriction must still be consistent with the general right to free trade of surface water. The commencement of the water trading rules on 1 July 2014 is consistent with the National Water Initiative which allows Victoria to maintain a 4 per cent limit on the volume of water shares each year traded out of irrigation districts in northern Victoria. An earlier commencement date would otherwise result in Victoria operating inconsistently with the water trading rules. Submissions queried whether the water trading rules permitted trade between regulated and unregulated systems. RESPONSE The water trading rules do not prevent trade between regulated and unregulated systems. The trade of these rights remains at the discretion of state governments. Submissions expressed concern that groundwater trading rules were too prescriptive. RESPONSE The rules governing groundwater trading differ to those for surface-water trading. This is partly because of the relative lack of knowledge about connectivity in groundwater systems and partly because groundwater markets tend to be less developed than surface-water markets. The rules impose conditions considered necessary as a prerequisite for such trades, to avoid undesirable impacts on third parties or on the resource itself. the water trading rules, groundwater trading is prohibited unless certain conditions are met. The conditions differ depending on whether the trade is within the same groundwater sustainable diversion limit (SDL) resource unit, between two different units or between a groundwater SDL resource unit and a surface-water SDL resource unit.
... an explicit and organised action by a group or organisation to encourage people to send in submissions advocating a particular viewpoint or position. Campaign organisers usually provided content for the submissions and encouraged submitters to send that content either as complete submission or as part of their own submission. Following feedback from the public that it was difficult to find non-campaign submissions for viewing, MDBA published submissions it considered to be part of organised campaigns with the ‘campaign submission’ included with the submitter’s name. In all other ways, campaign submissions were treated in the same way as other submissions. Accessibility issues In some instances people were unable to make their submission in writing because of language or other barriers, and MDBA responded to these on a case-by-case basis. See also section 4 of this appendix. Preparing submissions for publication Database management MDBA used a custom-built database to receive, manage and publish submissions. The database allowed members of the public to lodge their submissions online. It also provided a secure administration interface for MDBA staff to manage and track submissions. Submissions lodged online were entered directly into the submissions database. Submissions made by email, fax and post were entered into the database by MDBA staff. All attached text files were converted to PDF and attached to the submission for uploading to the website. Confidentiality and other requirements Once submissions were received and entered onto the database, MDBA read them closely to determine whether they contained private, confidential, legal or other sensitive material (e.g. health or financial details, or the names and locations of family members). To protect submitters’ privacy, MDBA removed personal contact details of individuals (e.g. number, email and postal address) from submissions before publishing them online. Where a submission contained personally sensitive material, MDBA contacted the submitters to confirm that they indeed wanted this material published online. Submissions were also checked to ensure that they did not contain illegal material or defamatory content. Reviewing and summarising submissions