The Victorian Farmers Federation (VFF) welcomes the opportunity to provide comment to the Independent Review of Water for the Environment Special Account (WESA).
Terms of Reference
The VFF acknowledge, the very narrow Terms of Reference of the panel and while it is outside the scope of the panel to take a view on the 450GL of upwater, it would be remiss of the VFF not to outline its position.
The VFF does not support the recovery of the 450 GL as we do not believe it can be delivered and will cause negative social and economic outcomes.
The VFF believes the full 2750 GL should be achieved first. It makes little sense for the Commonwealth to be pursuing the 450GL when there is no guarantee constraints will be relaxed and therefore the 450GL cannot be delivered.
Revised Social and Economic Criteria
While a revised social and economic criteria was developed in December 2018, the VFF believe its implementation is occurring inequitably.
The criteria ensures projects do not “reduce the overall productive capacity of the relevant program”, yet projects that are reducing the total consumptive pool are being approved and insufficient information on the projects are being provided.
Project proposals are providing generic answers to the socio-economic criteria. Total project costs are not being provided, nor is the Government funding contribution being made available, this makes it difficult to assess whether the 1.75 multiplier is being correctly applied.
The VFF believe the panel need to review existing 450GL project proposals and establish whether the socio-economic criteria are being correctly adhered to.
Summary of Recommendations:
Recommendation 1: The WESA Review panel ensure the revised socio-economic criteria is being adequately adhered to.
Recommendation 2 : The WESA panel identify the problems associated with on-farm projects and communicate these to the Commonwealth Government.
Recommendation 3: The VFF believe the WESA panel must acknowledge the challenges associated with the constraint relaxation projects, particualy the unrealistic timeframe of 2024
Recommendation 4: The VFF believe the WESA panel need to acknowledge the shortcomings associated with the 2018 Ernst and Young report.