Please accept my submission to the public consultation for the WA Government’s Fitzroy River Water Discussion Paper.

The Fitzroy River is of outstanding value to Western Australia and the nation. This value is not reflected in the suite of regulatory tools for management of development that are presented in this discussion paper as a substitute for protection. The river should not be opened up for the benefit of a small minority at the expense of Traditional Owners, recreational fishers, the broader community, and the river's outstanding natural and cultural values. An adequate protection mechanism for the river is needed.

The approach outlined in the discussion paper Managing water in the Fitzroy River Catchment fails to provide a mechanism for adequately protecting the National Heritage listed cultural and natural values of the Fitzroy River or its critically endangered species such as the freshwater sawfish. It also fails to provide Native Title holders with the full and engaged consultation, consent and ongoing role in management that they have called for.

This paper does not in my view outline an adequate pathway for the protection and sustainable development of the Fitzroy River.

Specific points I would like to raise are:

• I support the Government’s ‘no dams’ commitment but this is not adequately reflected in the discussion paper. To the contrary, large dams are considered that would capture surface flows from the river and floodplains via overland flow, pumps and channels. These types of dams are known to have had major impacts in the Murray-Darling and elsewhere. The definition of ‘no dams’ needs to be extended to cover all dams larger than stock dams.
• The proposed methodology of using water allocations to manage the river is designed to facilitate extraction for irrigation; not to protect the river. This is the methodology that has failed to protect the Murray-Darling rivers and many other freshwater systems. Instead, spatial land use restrictions such as a legally enforceable buffer zone are needed to stop water extraction and dams beyond those needed for stock and communities.
• The impacts of pollution from agricultural development are not considered. This would likely be a significant risk; especially to dry season pools.
• The Fitzroy River is Western Australia’s longest listed Aboriginal Heritage site and there are numerous listed sites along the river and on the floodplains. This is not mentioned in the paper; nor is protection of this heritage considered.
• The health of the river is essential to the survival of a vital population of critically endangered freshwater sawfish. The extreme risk to this species and other threatened and endangered flora and fauna from water extraction and pollution from agriculture on the floodplains is not reflected in the discussion paper. In particular, recent research shows that sawfish recruitment is dependent on peak flood years; and yet these are the flows that are targeted for extraction.
• The unique and National Heritage listed cultural values of the river are dependent on the relationship between Traditional Owners and water. This relationship is not adequately understood in the discussion paper; not are mechanisms to incorporate it into protection and management frameworks presented.
• The health of the river is essential to an iconic recreational barramundi fishery that is of significant social and economic value to the region and to WA. This is not discussed or considered in the paper.
• The paper has failed to capture the input of scientists, Traditional Owners and the broader community over the past four years. Specifically, the Fitzroy River Declaration; the Martuwarra Fitzroy River Council Statement the Fitzroy River Science Statement from100 leading scientists; recreational fishers public comments; and environment groups submissions supporting protection of the river and opposing irrigation development because of the low chance of economic success and high risk to the river’s health.
• Surface water extraction is not a sustainable development pathway and not needed for economic development; and the volumes of water suggested in the discussion paper are completely unnecessary. 300GL is more water than Perth and the Southwest use in a year. Prior studies by CSIRO and UniSA show that development based on water would be high risk and unlikely to make profits and provide few jobs. The Ord Irrigation Scheme uses less water than is proposed, and this has only been possible with a dam to regulate flow and some $1.5 billion in Government subsidies.
• Traditional Owners have proposed a Statutory Authority to enable and empower cultural authority over the protection of the Fitzroy River. The Discussion Paper fails to represent any inclusion of these requests and instead offers a weak substitute to engage with Traditional Owners through a poorly defined advisory group.

I strongly urge the WA Government to recommit to a co-design process with Traditional Owners as the driver of the protection of the Fitzroy river's cultural values and economic development; and to protect the river through a mechanism for spatial land use restrictions and protections of river and floodplains rather than a technical water planning process that has failed to protect rivers and wetlands elsewhere. Water planning is an incomplete tool for delivering the WA Government's election commitment to protect the Fitzroy River and support sustainable development in the Fitzroy River catchment.

Yours sincerely,
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