Reducing the administrative and licensing complexity of the Plan
Simplification of the Lower Limestone Coast Water Allocation Plan is needed. The success of the plan is dependent on you being able to understand it and our ability to implement and administer it.
The number of components is significant, comparative to other plans, and how they are treated and interact is complex. The system is overly complicated and contributes to confusion and a lack of transparency around how the Plan works and what is possible for a licence holder. For many licensees, administrators and other stakeholders the array of components and associated rules around their use, transfer and reporting in the Plan is too confusing to easily understand and apply.
Licensing components provided transparency at adoption:
The reason for the number of components was to create transparency in the volumetric conversion process and give licence holders confidence in that process. It sought to honour, in a transparent way, what a licence holder had before the Plan so they could understand what they would have under the Plan when it was adopted in 2013.
This appears to have been successful for the conversion process but the transparency it provided on adoption has been eroded through time. Many licence holders today are seemingly unaware of or have a low understanding of the rationale behind the components or how they work.
Examples of complexity in the Plan include:
Administration and implementation should be underpinned and guided by a clear set of objectives. The Plan would benefit greatly from a single set of objectives with clear and transparent intent.
The application of the Plan can be reliant on interpretation and assumptions where it is silent on an area of policy, the intent of the Plan is not clear or principles are complex.
There is a particular lack of understanding of how delivery supplement and specialised production requirement allocations are to be used and the limitations on transfers. The Plan also includes different rules for the multiplicity of components and purposes of use. This has resulted in a cautious approach where licensees opt not to change their business in case they may lose some of their allocation.
Although there are multiple types of delivery supplement and specialised production requirement allocations only the specialised production requirement for frost protection is administered and reported separately. Other usage volumes are not reported separately to the tradeable component usage volumes. This limits the capacity to undertake compliance activities and to assess the use of these components as part of the Plan’s review. It also questions the need to retain separate components.
The reporting periods for water (taking) licences and forest water licences differ. Water (taking) licences are managed on a financial year and forest water licences on a calendar year. This creates challenges in data collection and accurate analysis.
Transfers involving delivery supplement and specialised production requirement allocations are difficult to administer as different rates apply to different management areas. Hence the volume of the allocation differs for the transferee and the transferor. These calculations are managed outside the Departmental database.
Temporary transfers of a tradeable component linked to a delivery supplement, where it is not a like-for-like transfer (e.g. flood to flood), require the delivery supplement component to be forfeited to the Minister and then granted back to the transferor on return. This process is manually administered.