Context

NIC published our review of the Basin Plan in 2025 – “Moving Forwards: A Review of the Murray Darling Basin Plan by National Irrigators Council”.

This submission is made in addition to the formal submission of the NIC Basin Plan Review, covering 6 chapters (based on the themes of the MDBA’s Early Insights Paper published in 2024):

• sustainable water limits,
• regulatory design,
• environment,
• climate change,
• community and agriculture,
• contemporary topics (such as water quality, managing the Northern Basin, and First Nations water management).

This submission, and the NIC Basin Plan Review, are backed by a large body of work led by NIC in the lead up to this process, including a series of published journal articles (which are also formally submitted to this public consultation), such as:

• “The hydro-illogical cycle: Breaking the crisis mindset of water policy with the Triple Crown of Water Reform Framework”
• “Contemporising best practice water management: lessons from the Murray-Darling Basin on participatory water management in a mosaiced landscape”

This submission directly responds to the Discussion Paper, bringing together this comprehensive, evidence-based program of work, developed over many years. NIC seeks for this Review to be an opportunity for constructive, evidence-based, and positive approaches to water management in the Basin – recognising past successes and learnings - and moving forwards - together with Basin communities and industries. This is the approach NIC has taken and expects the same of others. Identifying the drivers of ecological risks is critical to identifying the right responses.

NIC strongly supports the MDBA's outcomes-based approach taken to understand drivers of risks in the initial SDL assessments, which recognises many of those risks are beyond what can be solved via further SDL changes.

NIC notes the divisive approaches to past reform, which have pitted our industry and environmental or other interests as ‘in-conflict’. This is not the reality of today’s Basin. We too care about the environment, want to see positive changes (alongside healthy communities and industries), and are a vital part of the solution – not a “problem to be solved”. We look forward to working together on a new vision for the Basin that captures the importance of water security for farming and regional communities; alongside important ecological outcomes for the landscapes in which we live, work and enjoy.

Key Recommendations

No further changes to SDLs (including SDLAM-adjusted SDLs) are needed. This means no more water recovery, via any means.

After three decades of reform, now is the time for stability.

The MDB priorities have shifted to optimise the existing investment through complementary and integrated land and water management – as well as restoring confidence in water security for agriculture.

Moving Forward for Basin Plan 2.0 involves:

Providing stability via no more changes to current SDLs (including SDLAM-adjusted SDLs), with no further reductions to the consumptive pool, nor any reductions to the reliability, availability or accessibility of water for all water access entitlement holders.

Investment in a range of strategic and coordinated package of actions targeted to minimising risks to environmental outcomes - known as complementary measures; including but not limited to:

• Investment in a coordinated, industry involved, MDB Native Fish Strategy focused on invasive species control, strategic fish passageway, government supported fish screening, practical cold water pollution measures, and riparian land management practices to support native fish;

Community-supported Constraints-Management-Projects[1]  to optimise the opportunity for delivery and environmental outcomes including:

• Strong commitment to continue community supported projects under-way (New South Wales’ Murrumbidgee Reconnecting River Country program and extend the Gwydir Reconnecting Watercourse Country program beyond December 2026); and
• Further work with communities to undertake, participatory, local program for staged constraints programs and novel solutions in other areas (Goulburn and Murray) recognising and reflecting any changes to downstream environmental objectives;

Expand opportunities to optimise environmental outcomes through improved partnerships including:

• Direct investment in supporting landholders, industry and Irrigation Infrastructure Operators to undertake voluntary land and water management partnerships, based on current exemplars;
• Enabling opportunities to strategically target environmental outcomes utilising novel, temporary market-based solutions such as lease or temporary purchase in partnership with water users; and
• Fostering collaboration with First-Nations in the above, such as through Indigenous Caring for Country programs or projects like the Billabong Project.

Moving forward will necessarily require working together in partnership with Basin communities, landholders and industries – given the nature of issues to be addressed. This will need to involve further work to develop detailed and targeted response options on a valley and local level, particularly for those areas where environmental risks are identified.

It is unlikely that specific detailed options can be finalised, with proper community input, prior to required timeframes for a recommendation to the Minister on next steps. Lessons learnt from the Plan to date caution against rigid legislation with premature program design, or linking project delivery to threats of further recovery which erodes community trust.

NIC recommends the design of any Basin Plan 2.0 (as an integrated water management plan to optimise water recovered for the environment rather than a further water recovery plan) must be a process for empowering communities to be part of future solutions to achieve improved environmental outcomes whilst valuing their social, economic and cultural interests through co-design, and participatory processes  – within a defined scope set of high-level programs, rather than the current inflexible, legislative outputs like SDLAM.

Basin Plan 1.0 – must also move forward:

The evidence-base developed through the Basin Plan Review process must also be used to inform the remainder of Basin Plan 1.0 – specifically, the SDLAM shortfall, and potential further water purchases under the 450 GL of additional HEW.

Without change, the status quo will result in further water recovery of an estimated 635 GL, despite today’s science showing water recovery is no longer the environmental priority (and with large cost, and socio-economic impacts). This requires:

• Re-prioritisation of funding away from any further water recovery (including both the recovery of additional HEW (‘the 450GL’), and any SDLAM-shortfall) towards complementary measures and community-supported constraints programs.
• Removing the ability to recover additional HEW, and detaching supply and constraints projects from volumetric-equivalent water-recovery fallbacks, to recognise their benefits which cannot be substituted by further water recovery.