EO Whittle
“Alloway”
Narromine, NSW 2821
Tuesday, 15 July 2008
Email:
To the ACCC
RE: Issues Paper
Water Charges Rules
Changes payable for irrigation infrastructure operators
I have been involved in submissions to the ACCC on the first discussion paper and this one. The more I have been involved the more I have a fundamental mistrust of the whole process.
The ACCC has been assigned by the Federal Government to come up with the rules by which irrigation operators must let its members transfer water from their schemes and what charges that the operators can levy to allow these transfers to take place.
The process of being forced to allow water transfers from their schemes must eventually lead to the destruction of a lot of them leaving the schemes’ infrastructures stranded along with the on farm infrastructure.
My mistrust is centred around the fact that the ACCC is, on the one hand, should be looking at the history of the development of private irrigation schemes and the uncompetitive nature of the mechanism that governments have put in place over time to acquire scheme water at possibly a greatly reduced price. On the other hand the ACCC is in charge of making the rules that will lead to some schemes demise.
I feel the ACCC definitely has a great conflict of interest. I question whether the ACCC is the watchdog or the assistant predator or both.
Most private irrigation schemes were built around the principle of co-operative investment, where each individual investment in the scheme was an integral and inseparable part of the whole investment. Water was attached to each individuals land and could not be traded from it, even within the scheme. The knowledge that all investors were locked into the scheme provided the security needed for all those intending to invest in the schemes.
When water trading was allowed some twenty years ago, trading from and within the river was sanctioned while the schemes were to be dealt with at a later date. In the intervening period, until recently, nothing was done regarding water trading from the schemes. The process is now proceeding at an obscene pace and I believe that governments are acting in the predatory fashion in forcing water on to the market at a time when they have announced that they intend to buy huge amounts of water for the environment.
The ACCC in its watchdog role must allow that governments will make further legislative/regulative changes to the rules governing water. One new rule that I envisage would stipulate that all scheme operators must operate below a stated level of water delivery efficiency. With little water remaining, more schemes would become unviable.
If governments intend to destroy schemes they should approach each scheme in turn and offer them a package to close the scheme down. This package should include the purchase of water, compensation for unsaleable infrastructure including on farm unsaleable infrastructure and compensation for on going loss of profits.
If it is in the national interest that governments acquire water for the environment then the nation, through governments must pay the full cost.
A test the ACCC should use to determine whether the present process is fair and competitive is to ask: How many of the existing schemes would have been constructed if the present legislation was in place when the schemes were being planned? What hope would anyone have of constructing a scheme today?
In closing I implore the ACCC to take a wider view of this whole process so as to prevent another disaster in the long line of disasters that have been attached to the management of water.
Schemes need to have absolute control of their investment.
Yours sincerely,
E O Whittle