Keep Top End Coasts Healthy (KTECH) is dedicated to preserving the unique and precious coastal ecosystems of Northern Australia. This submission highlights the significant risks posed by the Draft Mataranka Tindall Limestone Aquifer Water Allocation Plan (Mataranka Plan). We aim to emphasize the ecological, economic, and cultural implications of this proposed water resource development and advocate for sustainable management practices to protect the health of our coastal and marine environments.

Environmental Risks and Ecosystem Health

The Mataranka Plan presents significant risks to the health of Northern Australia’s coastal and marine environments. The plan proposes substantial groundwater extraction, which threatens the natural flow regimes crucial for maintaining ecological balance. Alterations in these flow regimes can have severe consequences for species such as banana prawns, barramundi, as well as impacting threatened species like dugong, turtles and sawfish, and various migratory birds that depend on specific flow conditions for their life cycles.

The Mataranka Plan, in particular, has been criticized for its inadequate consideration of the interconnected nature of the Tindall Aquifer. By treating different zones within the aquifer as separate entities, the plan fails to account for the cumulative effects of water extraction across the entire system. This compartmentalized approach can lead to significant ecological disruptions, including reduced flows to the Roper River and Mataranka Springs, which are critical for sustaining the region’s biodiversity.

Groundwater extraction also poses a threat to fishery productivity and biodiversity. Altered flow regimes can degrade habitats, leading to declines in the abundance of commercially and ecologically important species. This risk is exacerbated by the expansion of agricultural activities, particularly cotton farming, which requires extensive water use and land clearing, further straining the already fragile ecosystems.

Furthermore, the National Environmental Science Program (NESP) research highlights the essential role of freshwater inflows in maintaining coastal productivity. Reduced freshwater flows can lead to lower primary productivity, affecting the entire food web. For example, prawn and barramundi populations, which are vital for both commercial fisheries and the ecological health of the area, could suffer due to changes in the nutrient delivery systems these species depend on.

Legal and Governance Concerns

The Northern Territory’s water governance framework has significant shortcomings in meeting the requirements of the National Water Initiative. The Draft Mataranka Plan, in particular, fails to set appropriate trigger limits and management rules to protect environmental and cultural values. The plan’s reliance on unsustainable extraction rates, based on insufficient scientific understanding, poses a significant threat to sensitive ecosystems dependent on the Tindall Aquifer and the Roper River.

The plan’s separation into different zones without adequate consideration of their connectivity and the cumulative effects of extraction undermines sound groundwater management principles. The interconnected nature of the aquifer means that increased extraction in one zone can have far-reaching impacts on the entire system, including the Mataranka Springs and the Upper Roper River.

Concerns raised by water scientists emphasize the plan’s deficiencies in treating the Tindall Limestone Aquifer as a single, interconnected system. The plan’s methodology, which uses separate calculations for sustainable yield in different zones, ignores the high degree of connectivity within the aquifer. This oversight risks substantial environmental harm, as increased extraction in one area can significantly affect groundwater levels and flow patterns throughout the system.

The plan also does not adequately account for the potential cumulative impacts of groundwater extraction under the Georgina Wiso Water Allocation Plan and other surface water take policies. Such comprehensive consideration is crucial for ensuring the long-term sustainability of water resources and protecting the delicate balance of the region’s ecosystems.

Social and Cultural Impacts

The proposed Mataranka Plan fails to adequately account for the social and cultural values of the communities dependent on these water resources. Widespread community opposition to the plan reflects a lack of social licence for increased water extraction. Traditional Owners and local communities have consistently called for better protection of cultural values and increased decision-making powers regarding water management.

The cultural significance of the Roper River and its associated ecosystems, including the Limmen Bight Marine Park located at the mouth of the Roper, cannot be overstated. These areas are vital to the cultural, spiritual, and economic well-being of Indigenous communities. The plan's failure to engage meaningfully with Traditional Owners and to protect cultural water requirements is a glaring oversight that must be addressed. Indigenous people from the plan area have not been afforded sufficient opportunity to identify the needs of culturally significant features and did not endorse the plan’s release.

Moreover, Traditional Owners have voiced strong concerns about the potential impacts of water extraction on their cultural heritage sites and the broader landscape. The lack of comprehensive engagement and consultation with these communities undermines the legitimacy of the water allocation plan and its ability to meet the needs and values of all stakeholders.

Coastal Health Impacts

The health of the Northern Territory's coasts is intrinsically linked to the management of inland water resources. Free-flowing rivers are the lifeblood of coastal ecosystems, supporting mangroves, seagrasses, and saltmarshes, which provide critical habitat for species such as shorebirds, dugongs, and turtles. These habitats are also essential for the productivity of commercial and recreational fisheries.

Water extraction poses a direct threat to these coastal ecosystems by altering the quantity and quality of freshwater inflows. Research by the National Environmental Science Program (NESP) has demonstrated the importance of freshwater flows in maintaining the productivity of estuarine and coastal fisheries. Reduced flows can lead to declines in primary productivity, affecting the entire food web, from algae to commercially important fish species.

The economic value of healthy coastal ecosystems is substantial. A 2018 report (here) found that the Northern Territory's coastal waters contribute over $2 billion annually to the economy, supporting more than 6,000 jobs in tourism, fishing, and other industries. Protecting these ecosystems from the impacts of upstream water extraction is not only an environmental imperative but also an economic necessity.

Furthermore, blue carbon ecosystems such as mangroves, seagrasses, and saltmarshes play a critical role in carbon sequestration. These ecosystems store significant amounts of carbon, helping to mitigate the impacts of climate change. Protecting freshwater inflows that sustain these habitats is essential for maintaining their carbon storage capabilities and supporting global climate goals.

Marine Health Impacts

Marine environments, such as the Limmen Bight Marine Park, in Northern Australia are also at risk due to the impacts of inland water extraction. These environments support a diverse array of species, many of which are economically important and culturally significant. The health of marine ecosystems is closely tied to the quality and quantity of freshwater inflows, which help maintain the delicate balance of salinity and nutrient levels necessary for marine life.

The extraction of large volumes of water upstream can lead to increased salinity levels in estuaries and coastal waters, negatively impacting marine species that rely on specific salinity ranges for their survival. Additionally, the reduction in nutrient-rich freshwater inflows can diminish the productivity of marine ecosystems, leading to declines in fish populations and other marine life.

The impacts of water extraction are compounded by climate change, which is already placing significant stress on marine environments. Rising sea temperatures, ocean acidification, and more frequent extreme weather events are exacerbating the vulnerabilities of these ecosystems. Sustainable water management practices are essential to mitigate these impacts and protect the biodiversity and productivity of marine environments.

Research has shown that maintaining adequate freshwater inflows is crucial for the health of species such as the endangered sawfish and other marine life that depend on estuarine environments. Any reduction in these inflows can disrupt breeding, feeding, and migration patterns, leading to population declines and potential species loss.

Primary Concerns about the Draft Mataranka Plan

1. Doubling of Water Licenses: The draft plan allows for the doubling of water currently licensed across the plan area to 62.5 GL a year, facilitating a sixfold increase in the amount of water currently taken. This dramatic increase poses a significant threat to the region's water resources and associated ecosystems.
2. Impact on Groundwater Flows: The plan would result in a fourfold increase in the amount of water taken from the Larrimah zone, reducing groundwater flows to Bitter Springs and potentially reversing the flow of water back towards Larrimah. This could have severe implications for the health of the springs and the broader ecosystem.
3. Lack of Clarity on Protection Measures: There is no clarity on how the proposed protection measures would secure environmental values across the catchment. The plan lacks detailed information on how the “Roper Discharge Zone” around Bitter Springs would prevent and mitigate negative environmental impacts from extraction in other parts of the plan area.
4. Inconsistency with Community Values: The plan is inconsistent with the stated values and positions of many groups across the plan area and beyond, including Traditional Owner groups from the Roper catchment who have called for ‘no more water out’ and better protection of cultural values. The lack of social licence is evident from the strong opposition from local communities and stakeholders.
5. Inadequate Scientific Basis: The plan relies heavily on modeling predictions without sufficient transparency or independent verification. There is a need for more robust scientific data and a comprehensive understanding of the ecological water requirements to make informed decisions about sustainable extraction levels.

Recommendations

1. Reject the Draft Mataranka Water Allocation Plan: The plan represents a significant threat to the health of the Roper system and is based on an overly optimistic view of the water budget. It fails to consider the cumulative impacts of water extraction, fails to consider the impact on important downstream environments like the LImmen Bight Marine Park, and is not consistent with the requirements of the National Water Initiative. The Northern Territory Government should reject this plan and develop a more sustainable and community-driven approach.
2. Commit to No More Water Out: The government should commit to maintaining current extraction levels and banning any increased water extraction licenses, surface water harvesting, and new dams. This precautionary, values-driven approach is essential to protect the Roper catchment's ecological sustainability.
3. Conduct a Comprehensive Review of Current Water Licenses: A thorough review of current water licenses should be undertaken, with a pause on issuing new licenses until this review is completed. The review should incorporate community views and scientific evidence to ensure sustainable water management practices.
4. Expand the Protected Area to Include Bitter Springs: The draft plan proposes a "protected environmental area” around Mataranka and Bitter Springs, but without detailed protection measures. The government should clearly define the instruments underpinning this zone and establish ongoing management bodies to ensure effective protection of the area’s social, cultural, and environmental values.
5. Meaningful Consultation with Traditional Owners: The government should engage in meaningful consultations with Traditional Owners and their representative bodies to ensure Free, Prior, and Informed Consent on water management decisions. This includes declaring the entire Mataranka Water Allocation Area a Protected Environmental Area under Section 36 of the Environmental Protection Act 2019, with clear mechanisms for consultation and oversight.
6. Implement Tangible Steps in Response to the Roper River Water Statement: The government should endorse and implement tangible steps in response to the Roper River Water Statement. This includes adopting best practice models of river governance and ensuring compliance with the National Water Initiative, particularly in terms of proper consultation and engagement with Aboriginal people and their representative organizations.
7. Establish Transparent Monitoring and Reporting Systems: Implement robust monitoring programs to track groundwater levels, spring and river flows, and the health of groundwater-dependent ecosystems. Make this data publicly available to ensure transparency and accountability in water management decisions.
8. Adopt an Integrated Water Management Approach: Develop a comprehensive water management strategy that considers the interconnectedness of surface water and groundwater systems, as well as the cumulative impacts of water extraction across different regions. This approach should prioritize the health of ecosystems and the sustainability of water resources.

Conclusion

The health of Northern Territory's coasts and rivers is at a critical juncture. The decisions made today will have lasting impacts on the region's ecosystems, communities, and economy. The Northern Territory Government has an opportunity to lead the way in sustainable water management and preservation of receiving marine environments by rejecting the current draft plans and developing a more integrated and community-driven approach.

We urge the Northern Territory Government to take decisive action to protect these invaluable resources for current and future generations. Thank you for considering our submission.

Sincerely,

Adele Pedder
Keep Top End Coasts Healthy
[email protected]