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Submission: Western Davenport Water Allocation Plan Review

The purpose of the Western Davenport Water Allocation Plan is to ensure that water resources are managed in a way that protects and maintains environmental and cultural values, allocates water for future public water supply and supports ecologically sustainable regional economic development.

ALEC’s submission to the Western Davenport Water Allocation Plan Review highlights that the current Plan is not fit for purpose and has failed to meet its objectives. Our submission provides recommendations to address our key concerns and focuses on four key themes. Read ALEC's full submission here.


The core areas central to the Western Davenport WAP are not well understood, namely: water quantity; water quality; cultural values; terrestrial and aquatic groundwater dependent ecosystems. The level of uncertainty within the WDWAP does not provide a sound basis for establishing the Western Davenport Water Control District as a major strategic agricultural precinct, and leaves the area vulnerable to water over-allocation which has significant environmental, social and economic costs.

Protection of groundwater dependent ecosystems (GDEs)

One of the four key objectives of the WDWAP is the protection of groundwater dependant ecosystems (GDE). However the key mechanism for GDE protection - the ‘limit to change in groundwater conditions rule’ – has been undermined with the release of Guideline document that was approved in 2020 without any public consultation.

Adaptive management

While adaptive management has an important role to play in ensuring long term sustainable use of natural resources, it should not be used to overcome uncertainty regarding environmental responses to groundwater extraction.  The reliance on the adaptive management framework for the approval of the Singleton Station water licence contravenes the NT Environment Protection Agency’s own guidelines.

Water mining

ALEC strongly opposes the thresholds outlined in the Water Allocation Planning Framework (WAPF). The policy is over 20-years old, is outdated, crude and is not linked to the sustainable use of water resources. There is no scientific justification for the implementation of the WAPF, and there should be no alignment between any future WAP with the WAPF.

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