The recognition that regional differences might require different approaches is a big step forward; this will allow areas with potentially severe water shortages to develop their own solutions regarding drought management, water sharing agreements, etc. The question who will be in charge of developing regional solutions will, however need to be clarified.
- Regulating groundwater use (mostly in regions of limited water supply) can protect the resource for current and future users. Good information on aquifer capacity will however be required. Existing wells have to be grandfathered and I would like to see the ability to transfer surface licenses to groundwater, if desired by the licensee.
- Developing instream flow regulations will hopefully bring some clarity to what the requirements should be; some consideration will have to be given to natural stream flow fluctuations. The positive aspect to this is that it may free up some funding for storage expansions.
- An Agricultural Water Reserve has the potential to secure access to water for ag lands over the long term. This is, however going to be a difficult task to accomplish in areas of full or over allocation. The agricultural sectors will need to be intimately involved in developing this concept.
Some of the things that worry me:
- Using economic instruments and incentives: the use of economic instruments ( substantially increasing licensing fees, progressive price increase based on volume per acre, increased pricing per volume, etc.) are not in the interest of agriculture. As it stands, very few, if any sectors could afford a substantial increase in water rates. All other fixed costs seem to be on a steady increase, without being offset by increased prices at the retail level. Progressive pricing structures could be implemented by water purveyors, but would be practically impossible to implement for producer owned and developed systems. If progressive pricing is to be implemented, price increases should only take place for amounts used above the normal allocation.
- Conditions for existing and new licenses (e.g. license expiry dates, cutbacks on water allocations) in chronic problem areas could cause more than a few of us to mount barricades; implementing licence expiry dates or cutbacks on existing water right holders is inconceivable to me and would be political suicide, although I am curious how MOE would propose to implement this. Temporary reductions across the board in times of serious drought is appropriate; but not permanent limitations on license.
- Reporting requirements may face a fair amount of opposition, depending on how far they go.
- Some users in the agricultural sectors may view many of the proposed economic instruments as a new form of taxation and not as a means to encourage conservation.
- Uncertainty over allocations for First Nations reservations. Will this be part of the proposed Agricultural Water Reserve or will it be treated separately?
Some of the issues not addressed in the policy proposal
- Trading of water rights: Trading of agricultural water rights to other user groups should be prohibited. I am personally uncomfortable with the selling of licenses for money, even within agriculture, although this is allowed under the current act.
- That cross border trading of water rights should be prohibited.