Reducing the administrative and licensing complexity of the Plan

Simplification of the Lower Limestone Coast Water Allocation Plan is needed. 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.

Considering changes to management zones

Under the revised Plan management areas will become management zones. In this change there is an opportunity to consider boundary changes. This could include amalgamating some smaller management zones.

Management zones are identified for the purpose of managing resource conditions and impacts associated with the take, extraction or use of water in, or in association with, that zone.

Management zones allow for rules, limits and management responses to be set for particular zones allowing for targeted management at an appropriate scale.

Considering the introduction of water classes

A simplification of the water licensing system proposes that the components and purposes of use be replaced by three classes. Each class allows for a different level of security with the highest level of security restricted to public water supply. The lowest level of security may be used for any purpose.

ClassDescriptionExamples of purpose of use to be allocated to class
1

Highest level of security. Not tradeable.

Only available to protect critical human needs.

Not subject to reductions or restrictions.
Public water supply
2Provides comparable protections as current Plan. Limited trade.

May have specific conditions relating to particular uses.

Not subject to restrictions.

Industrial

Recreational

Intensive animal keeping
3

Lowest level of security. Fully tradeable.

May have specific conditions relating to particular uses (e.g. aquaculture).
Subject to reductions or restrictions.

All tradeable components excluding public water supply, industrial, recreational and intensive animal keeping

All delivery supplements

All specialised production requirements

Provide feedback on the proposal to introduce classes:

Do you support the concept of water classes to replace components and purposes?
Do you agree that public water supply should have the highest level of security?
Do you support delivery supplements and specialised production requirements being made tradeable?

The success of the plan is dependent on you being able to understand it and our ability to implement and administer it.

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.

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.


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