“public submission on the water charge rules … irrigation.pdf · “public submission on the...

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“PUBLIC SUBMISSION ON THE WATER CHARGE RULES POSITION PAPER, SEPTEMBER 2008

MURRUMBIDGEE IRIGATION LTD

9 December 2008

Murrumbidgee Irrigation Limited Submission Water Charging Dec 2008

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INTRODUCTION

Murrumbidgee Irrigation Ltd is an unlisted public company providing water supply, drainage and

environmental services to approximately 3200 customer/shareholders in the MIA. The Company

manages $500 million of infrastructure assets servicing over $2.5 billion in water entitlements.

The Murrumbidgee Irrigation Area (MIA) is one of the most diverse and productive regions in

Australia contributing over $5 billion annually to the national economy. The MIA was first established

in 1912 following the commissioning of Burrinjuck Dam. Further expansion occurred in the 1970’s

with the completion of the Snowy Mountains Scheme and construction of Blowering Dam. The region

has played a significant role in fostering cultural diversity with over 50 different nationalities now

resident in the region. The region also played a significant role during and after WW1 and WW2 in

terms of national security and repatriation.

Murrumbidgee Irrigation Ltd continues to recognise its regional and national responsibilities in

ensuring an open and competitive water market, in making this submission to the ACCC.

Some facts on MIA value adding

Chicken meat - $300 million annually, 1.2million chickens / wk and 1500 jobs (4500 Aus)

Feedlots - $450 million, 75,000 cattle (150,000 through abattoir) and 800 jobs.

Wineries – 13 wineries, 1500 jobs, 60 containers / day, $2.9billion annually.

Citrus 130,000 tonnes – 1500 jobs and $170M annually inc juicing and packing.

Sunrice - $800million annually, 1800 jobs (1,100 Aus),

Walnuts - $35m expanding to $400M in 10 years,

Vegetables – farm gate $40million annually.

Livestock (non-feedlot) – 650,000 hd

Also cereal crops, pulses and oilseeds.


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Principles

MI seeks the following principles to support the proposed water charging rules:

1. The rules should not drive outcomes in terms of the direction and volume of trade. In particular

this requires:

Universal application of the market rules to all operators and individual entitlement holders,

without resulting in uniform mediocrity, or unreasonable transaction costs.

Establishment of minimum standards with a capacity to review and lift standards in future,

(rather than impose impossible targets for some operators or allow differential rules).

Market disclosure from operators to ensure market neutrality in the operation of the water

charging rules.

2. The rules must take account of the need for operators to manage the changes that will inevitably

follow the introduction of basin wide trade. The outflow of water will result in marked reduction

of economic activity and wealth in irrigation dependent communities. But people cannot move as

quickly as water. MI recognizes the long term benefits to the nation of allowing water to move in

order to maximize profitability.

However, such benefits will be mitigated – and potentially compromised – if short term costs to

the losers (including the community) in this process are not recognised and managed effectively.

3. The water charging rules should not work against previous agreements that have been reached

between communities and Government such as the NWI. These have often involved costly

negotiation between operators, regions and States. It would benefit all if the market rules were

to build on these arrangements rather than ignore or discard them.


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General Comments

Private irrigation corporations in NSW and South Australia have for some time maintained that the

ACCC has no role in regulating the process and quantum of price setting inside these businesses. The

ACCC acknowledges in this report that the natural checks and balances created by our structure,

where customers are typically shareholders, “reduces the incentive to maximise monopoly profits”.

Given the sorts of advances that have been achieved in NSW and SA corporations prior to ACCC

involvement, the question must be asked, “What benefits will accrue through greater regulation?”

On the other side, the compliance costs for our business are increasing exponentially.

Below is a graph of MI’s cost performance since privatisation in 1999, in comparison to CPI and bulk

water costs. Real reductions of 42% have been achieved in this time. This is becoming increasingly

difficult under the new regulatory regime.

It would appear from this position paper that the ACCC envisages a role in regulating not only the

establishment of market rules, but also price setting, infrastructure planning, customer consultation,

service standards, dividend policy and financing. MI directors and management have the ultimate

responsibility to the customer / shareholders to govern the business to acceptable standards

including the functions described above. We see no role for the ACCC in regulating how these

functions are undertaken in private sector companies such as ours, where there are effective, self-

regulating checks and balances.

It is somewhat perplexing that in the interests of competition the ACCC is seeking such high levels of

uniformity across a range of issues in the rural water sector.


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We repeat that we welcome a focus on competitive diversity instead of uniform mediocrity.

Member owned operators do not require the level of regulation deemed necessary by the ACCC for a

government owned business model in the water industry. The only legitimate role for the ACCC

inside locally owned businesses like MI is to regulate the pricing of service termination and related

impacts on trade, presumably for the broader national interest. This can be done quite

independently of the annual business processes described.

Summary of ACCC Position Paper

Murrumbidgee Irrigation Limited is included in Tier 1 and 2, and not Tier 3.

To address these (ACCC) concerns, the ACCC is recommending a three-tiered approach for the regulation of the various types of operators. The three tiers are to apply to operators depending on the type of market failure that the rules are addressing and the materiality of any resulting inefficiencies.

Tier 1 rules will address issues of discriminatory pricing and transparency and will apply to all operators. The tier 2 rules will address more material concerns about asymmetric information and discriminatory behaviour and will apply to the larger member owned operators (and any medium sized non-member owned operators not captured under tier 3). Tier 3 rules will address the potential misuse of market power and resulting inefficiencies and will apply to the larger non-member owned operators.

ACCC preliminary positions—form of regulation

A tiered approach will be adopted for the water charge rules:

Tier 1—Tier 1 rules prohibit unfair discriminatory pricing and require operators to publish their fees and charges. Tier 1 will apply to all operators.

Tier 2—In addition to the tier 1 requirements, tier 2 includes procedural requirements and the publishing of an explanatory statement. Tier 2 is to apply to larger member owned operators (and medium sized non member owned operators not captured under tier 3).

Tier 3—Tier 3 rules will provide for the ACCC to approve or determine regulated water charges. Tier 3 will apply to large non member owned operators.

1


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How will the Proposed Rules Work? The paper describes the Tier One Rules as:

The paper describes the Tier Two Rules as:

ACCC preliminary positions—tier 2 rules

Tier 2 rules apply to all large member owned operators and any medium sized operators not subject to the tier 3 rules. These are termed ‘tier 2 operators’.

Tier 2 rules will come into effect one year after the rules are registered on the Federal Register of Legislative Instruments.

Procedural requirements

Operators subject to tier 2 rules are required to implement and document certain procedures when setting prices. The procedures include:

ACCC preliminary positions—tier 1 rules

Publishing of fees and charges

All operators are required to publish a schedule of their regulated fees and charges annually. For operators only subject to tier 1 rules, the provision of this information to their customers will be sufficient.

The published schedule is required to:

provide details of the fees and charges, including fixed and variable components of charges, made in relation to regulated water charges (MI is currently complying)

include sufficient information to enable a customer to calculate their total bill based upon an estimate of demand (MI - This currently possible for MI customers)

show any rate differentials applying across regions or customer segments within the operator’s network (MI is currently complying)

include details of discounts, rebates or surcharges and the circumstances in which they apply. (MI is currently complying)

Non-discriminatory pricing

Differentials in regulated water charges payable to an operator are permitted under the condition that such differentials:

are based on differing costs of service provision which may include a cost of capital or costs of services of different standards (MI - Why so restrictive? If MI agrees with some or all of its customers to structure pricing on a model other than cost recovery this should be permissible.)

are not based solely on the identity of the customer/s to whom the differential rate applies. (MI - The meaning of “identity” requires further explanation.)

All other types of differentials are prohibited. (MI - This blanket rejection seems excessive without at least some statement that parties can agree to various differentials.)

Commencement of tier 1 rules

Tier 1 rules will take effect from the day after the rules are registered on the Federal Register of Legislative Instruments.


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development of a network service plan proposal that evaluates servicing options for the

network and the charges associated with those options (MI - MI does not currently

publish a formal network servicing plan and nor have our customers requested such a

plan. MI does however liaise closely with customers regarding any changes to servicing

in response to seasonal conditions and industry needs, such as season duration and

areas of supply restriction due to drought. The ACCC proposal for a formal annual plan

is a matter for each business and presumably would be implemented if broadly

supported by customers.)

customer consultation on network options (MI - This takes place but is not formalised in

terms of annually published procedures)

an expenditure program for the finalised network service plan (MI - This is a matter for

MI Directors not customers – MI is a public company not a government authority)

a tariff schedule and explanatory statement that provides customers with information on

the main drivers giving rise to changes in fees and charges. (MI -Whilst this is desirable it

is not considered a matter for which the ACCC needs to mandate – in the interests of

competition this should be something which helps differentiate service provision

between regions.)

Publishing requirements

Operators subject to tier 2 rules are required to publish, on the internet or in a daily paper circulated in the region of network operation, their schedule of fees and charges prior to coming into effect, at least annually. The content of the schedule is to be consistent with the requirements under tier 1. (MI - MI does this but for good reason it does not take place at the start of the year. We allow time for customers to rationalise their holdings in order to reduce fixed costs and therefore charges, e.g. eliminating outlets, amalgamating holdings etc. MI will be publishing fixed and variable pricing by about August / September each year under the new pricing framework, recognising that customers currently pay in arrears some 6 months later.)

Operators subject to tier 2 rules are required to publish annually an explanatory statement that provides:

changes, including to service standards and regulatory and other obligations that will

occur over the year (MI - With public corporations it is a function of our board to review

such material, not customers.)

major operating and capital expenditure cost drivers affecting current prices, including

for outcomes beyond the current year (for example, annuity contribution to new

investments); this is to be linked to the network service plan (MI - with public

corporations it is a function of our board to review such material, not customers)

the aggregate change in operating and capital expenditure between the current and

previous year and the impact of that change on the revenue required by the operator;

details of how that impact is calculated (for example, annuity calculation) (MI - we

establish an annual budget which is approved by Directors and incorporates water and

non-water income. Much of this is commercial in-confidence and will not be published

ahead of the annual activity. We will continue to report annually in arrears to

shareholders. MI reports annually in arrears on its full operations including OPEX and

CAPEX)

details of all grants, subsidies and contributions paid to the business (MI - with public

corporations it is a function of our board to review such material, not customers. We

establish an annual budget which is approved by Directors and incorporates water and

non-water income. Much of this is commercial in-confidence and will not be published

ahead of the annual activity. We will continue to report annually in arrears to

shareholders)

any rationale not included above for the variation in a regulated water charge from the


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Generally in relation to the Tier 2 rules and communications, the ACCC needs to identify other

Generally in relation to the Tier 2 rules and communications, the ACCC needs to identify other

private industries where this level of regulation is mandated and the clear benefits that such

regulations have provided for consumers and the economy. Most of the issues raised are matters for

reporting to and decisions by Directors. The last time we looked at an account from our gas or

electricity provider they did not provide details of budget matters that had a material impact on the

charges, nor did they produce details of the infrastructure CAPEX and service plan. The requirements

are clearly designed around government service provision where customers have no choice and no

shareholder rights.

Comments from the review of the ACCC Paper

What is the market failure? (Page 10)

The market failure per the ACCC appears to be attributed to:

natural monopoly infrastructure

lack of scope for conventional competitive forces

natural economies of scale in size for irrigation networks

large and lumpy capital investments, that are sunk once made

lack of competition within irrigation districts for the delivery of water

potential discriminatory behaviour against customers

The ACCC has not provided any evidence for member owned operators market failure, despite the

above observations. The most current benchmarking study completed by the National Water

Commission 1 does not provide evidence of market failures when assessing member owned

operators.

In terms of market failure, MI has a commitment to define, monitor and report service standards to

our customer/shareholders and in so doing strive to improve such services over time. MI sees no

obligation to report such standards to anyone else. Ultimately, if standards drop, our customers will

1 National Water Commission, National Performance Report, 2006-07, Rural Water Service Providers

preceding year or across customers within the current year, including any return on

equity or tax impacts (MI - this is a matter for Directors)

a breakdown of the change in an average or representative irrigator’s bill into

components based on the major drivers of the price changes. This must provide

sufficient detail to enable customers to identify the factors (such as service standards,

climate change and/or drought recovery, network growth or rationalisation) that have

led to the change. (MI - this is a matter for Directors)


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firstly exercise their democratic right to change company directors and direction and in the absence

of success they can remove their investment from the district.

Is regulatory intervention proportionate to the problem?

Before one can answer this, let us refer to the Productivity Commission2 where they issue guidance

for government intervention.

Four criteria for assessing and designing policy instruments are appropriateness, equity, effectiveness and

efficiency (table 3.1). Transaction costs are important to consider and should not be overlooked in any

analysis.

A proposed policy instrument is likely to be less effective and efficient if its design does not consider

existing policies to address the problem (including non-regulatory approaches), or if it causes unintended

distortions in the market.

Table 3.1 Key principles for designing and assessing policy instruments

Principle Description

Appropriateness Is government intervention warranted? Is the goal worth achieving?

Effectiveness Does the policy achieve the stated objectives (that is, is it likely to result in

desired changes in behaviour or achieve targeted outcomes)?

Efficiency Taking into account the costs of designing, implementing and monitoring a

policy (or transaction costs), does the policy achieve the highest net benefit of

all the alternative policies?

Equity Are there equity considerations?

Costs associated with designing, implementing, monitoring and enforcing a policy instrument include:

• information costs required by policy makers to design policy — for example, to set an appropriate tax

level or quantity restriction

• administration, enforcement and monitoring costs incurred by agencies — for example, to assess

auction bids, monitor adherence to contract terms or enforce non compliance with regulation

• search and negotiation costs incurred by market participants — for example, to search for other

parties with whom to trade water allocation rights, environmental credits or pollution permits

• compliance costs — for example, costs incurred by irrigators when providing information to regulators

regarding contract adherence.

How does the ACCC respond to this type of guidance when balancing the need to intervene with a

cost benefit justification?

2 Australian Government, Productivity Commission, Irrigation externalities: pricing and charges, 2006, Gavan

Dwyer, Robert Douglas, Deborah Peterson, Joanne Chong, Kate Maddern


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The positive features of member owned corporations are clearly stated in the Position Paper, and the

arguments for intervention appear to be:

• unfair discriminatory conduct against members and non members, and minority groups

• possible existence of cross subsidies

No evidence to substantiate the arguments for intervention has been provided by the ACCC in the

Position Paper. However, the Paper refers to the recent COAG agreement to allow the ACCC to deal

with the determinations or approvals of all regulated water charges within the Basin.

Assessment of Available Options

The Position Paper then proceeds to assess the available options and to identify the benefits arising

from any ACCC intervention.

MI has already noted in earlier submissions that:

• MI is concerned about the excessive burden that new regulations are imposing on our business and

therefore our customers. The increase in costs through federal regulation is of particular concern.

• MI is confident that private diverters and other infrastructure operators, due to their different

structure, are not facing the same regulatory and administrative burden.

• MI and other private operators now have over a decade of demonstrated success regarding efficiency

reform, service improvement, water trading development and commitment to regional environmental

protection. All of this has been achieved in the absence of significant regulation. It is unfortunate that

MI and other private operators are now having to accommodate the lowest common denominator

when it comes to regulatory intervention and policy reform.

In summary, the ACCC has adopted the three tier proposal to oversee the regulated water charges by

operators.

What remains to be seen from the three tier approach are the benefits to the water market, to

irrigators and to the operators. MI favours consistency, a low cost irrigator model, openness and

transparency in its dealings with all MI shareholders and irrigators, reinforced and driven by the

irrigator owned business model. In addition, for Australia to be globally competitive in agriculture,

cost management is the greatest challenge facing farmers daily.

In respect of bulk water pricing and the role of the ACCC, MI favours an approach which provides

greater rigour in respect of pricing principles such as cost sharing and enables companies such as MI

an opportunity to challenge monopoly pricing from government-owned providers. MI has had good

success with the NSW IPART in respect of pricing principles but only modest success in respect of

scrutinising costs and cost sharing. For example, MI holds two meters on the Murrumbidgee River

out of some hundreds of meters in total, yet costs such as metering control and compliance are

shared on the basis of entitlement, of which we own approximately half. Clearly there is a need to


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revisit the sharing logic. More recently, MI picked up over $1M in MDBC river operations costs yet

we receive no service from MDBC in terms of operations. We look forward to participating in a

process which allows more scrutiny of these issues.

Determination or approval of regulated water charges

Pricing Principles

MI asserts that it is meeting the basin water charging objectives and principles stated on Page 30 of

the Paper. Disclosure of designed or inadvertent subsidies is in effect achieved by publishing water

charges for each zone with MI. Disclosure of any other commercially sensitive information is done

within the constraints of any confidentiality agreements entered into by MI.

Refer to earlier comments in this submission about meeting customer standards.

MI currently does not charge customers a rate of return on capital, but includes an annuity based

sinking fund charge to help recoup future infrastructure investment. Both depreciation and the

sinking fund annuity are currently based on the engineering life of the assets as this results in the

lowest sustainable cost to current customers, avoids problems with intergenerational equity and

avoids monopoly rents via the use of economic lives. Depreciation is not funded from water charges.

The impact of termination fees is also critical to cost recovery analysis. Whilst this issue is covered in

the ACCC termination fees rules, assumptions about the number of future customers and water

availability are critical to the setting of annual charges and termination fees, and the irrigators’

capacity to pay.

Comments in earlier submissions include:

MI has sought to remove, as far as practicably possible, cross subsidies in its pricing of services. In the absence of 3200 individual unit rates, a different rate for each customer, it is impossible to completely eliminate cross-subsidies. In MI’s view, supported by our customers, the new system successfully groups those customers that demand similar services and therefore drive similar costs within the business. Within these groups, which combine elements of service levels, geography and system type, postage stamp pricing is the only practical means of sharing costs without a massive increase in the administrative burden for MI. Even with additional intellectual effort and improved data collection, many aspects of cost in a highly integrated network are simply not black and white as to key drivers.

MI does not have any “formal” community service obligations although we have previously reported on a range of activities that the company undertakes which arguably go beyond the realm of good corporate citizenship.

The approach taken is a matter for each operator and will be determined by expenditure profiles, preferences to risk and consideration of intergenerational equity.

MI uses the annuity approach to future CAPEX planning. The model was developed by an external consultant with the close involvement of MI technical and financial staff. The policy concept has the broad support of our customer/shareholders. MI provided details on this model to the ACCC in our last submission, including the assumptions used therein.

The annuity will be reviewed and adjusted every five years in the absence of major changes to the underlying assumptions, in which case a specific review will be undertaken.


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Our current accelerated CAPEX program, using what remains of the NSW Government asset funding deed for deferred maintenance, is externally audited by the NSW Government. This process includes an ex-ante review of forward estimates of 2 years, a detailed ex-ante review of the annual works program and an ex-post audit of works completed.

MI does not recover the value of past investments in future prices, unless specific cost sharing agreements were reached to provide levels of service above the standard. Such agreements are few in number.

MI predominantly uses the annuity approach to capital finance. Decades of mismanagement by successive governments precipitated the changed approach under local ownership. MI is confident that the current approach provides the greatest security and equity for current and future generations. Our system is characterised by long life assets and “lumpy” expenditure profiles. The annuity approach suits this CAPEX profile.

Where specific assets are required over and above standard levels of service, MI has and will continue to seek developer contributions towards such assets.

Application of the pricing principles

Tier 3

As the Tier 3 requirements do not impact on MI at this stage, MI makes no comment. The only

suggestion MI makes is for the ACCC to commence its role with an assessment of the operating

efficiencies of the large operators in the Basin, to ensure that the starting point for intervention is

sound.

Transparency and non-discriminatory pricing

This chapter of the Position Paper outlines the publishing requirements and non-discrimination rules

that will apply to operators under tier one and tier two rules. MI is specifically included in tier 2

rules, against which we have provided comments earlier in this submission. MI is currently

complying with the majority of Tier 1 requirements.


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ACCC preliminary positions—tier 2 rules Publishing requirements

5.5 Operators subject to tier 2 rules are required to publish, on the internet or in a daily

paper circulated in the region of network operation, their schedule of fees and charges prior to coming into effect, at least annually. The content of the schedule is to be consistent with the requirements under tier 1.

5.6 Operators subject to tier 2 rules are required to publish annually an explanatory statement that provides:

changes, including to service standards and regulatory and other obligations, that will occur over the year

major operating and capital expenditure cost drivers affecting current prices, including for outcomes beyond the current year (for example, annuity contribution to new investments). This is to be linked to the network service plan

the aggregate change in operating and capital expenditure between the current and previous year and the impact of that change on the revenue required by the operator; details of how that impact is calculated (for example, annuity calculation)

details of all grants, subsidies and contributions paid to the business

any rationale not included above for the variation in a regulated water charge from the preceding year or across customers within the current year, including any return on equity or tax impacts

a breakdown of the change in an average or representative irrigator’s bill into

components based on the major drivers of the price changes. This must

provide sufficient detail to enable customers to identify the factors (such as

service standards, climate change and/or drought recovery, network growth

or rationalisation) that have led to the change.

5.7 The network service plan to which the explanatory statement relates should be published.

5.8 Operators subject to tier 2 rules are required to implement and document certain procedures when setting prices. The procedures include:

development of a network service plan proposal that evaluates servicing options for the network and the charges associated with those options

customer consultation on network options

an expenditure program for the finalised network service plan

a tariff schedule and explanatory statement that provides customers with information on the main drivers giving rise to changes in fees and charges.

5.9 Tier 1 rules will take effect from the day after the rules are registered on the Federal Register of Legislative Instruments.

5.10 Tier 2 rules apply to all large member owned operators and any medium sized operators not subject to the tier 3 rules. These are termed ‘tier 2 operators’.

5.11 Tier 2 rules will come into effect one year after the rules are registered on the Federal Register of Legislative Instruments.


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Transaction Costs and Water Reform

A technical report issued by CRC for Irrigation Futures3 provides a detailed and interesting insight into

the challenges facing the water reform process. To quote:

“This investigation demonstrated that whilst in principle there are options for improving the

performance of irrigation systems through innovation, in practice change is frustrated by institutional

impediments, which generate high transaction costs, which in turn inhibit innovation in the use and

management of water. These include:

1. Complexity associated with a large number of regulations, market instruments and

organisations many of which are not water-focused;

2. The political and administrative interests associated with these arrangements, and the power

associated with control of information and water as property.

3. Impediments to obtaining mandatory licenses, or alterations to planning and administrative

arrangements (of which only some are water specific); and

4. Conflict from institutional competition and the absence of effective coordinating mechanisms.

The conflicts are not confined to water trading or water governance, but reflect broader

natural resource management institutional arrangements.

Our research has highlighted that the reform of transacting systems, rather than limiting the focus of

reform to water institutions forming part of those systems, is a key concern. In this regard our

methods are complementary to those used by the National Water Commission, but we suggest a

broader set of reforms is needed to ensure that our national water policy goals are met.

What is being tested in irrigation is our national business model for sustainable resource

management. The model that is institutionally embedded remains focused upon government as the

central decision maker and lead investor. The model that is being advanced through water reform is

one in which decisions of the private sector, and investments by the private sector, are the focus. A

contest of philosophies is occurring in regional natural resource management, and in deliberations

about Australia’s response to the challenges of climate and the decline of biodiversity. In the

emerging alternative model government is a seed investor, facilitator and guarantor of institutional

integrity.

However this emergence is far from inexorable. The roles of government and the private sector are

continually being redefined and intensively debated. The lack of a clear national business model for

the environment is resulting in confusion and high transaction costs. We suspect that it is also

resulting in wasted opportunities to efficiently conserve and to use what we have not yet destroyed...

3 Cooperative Research Centre for Irrigation Futures, Technical Report No. 08/08, Transaction costs and water

reform: the devils hiding in the details, Paul Martin, Jacqueline Williams and Christopher Stone, 2008


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Page 32 -This in turn focuses our attention on the importance of good design of rules frameworks and

organisational arrangements. It suggests something not highlighted in the literature, that the

coordinating mechanisms between these entities and their rule sets are significant in themselves. The

observed gap between modelled ex-ante outcomes for market instruments or regulation, and the ex-

post results, could be substantially explained by the types of institutional issues that have been

highlighted by these case studies. Many of the delays in implementation of the National Water

Initiative highlighted by Mr. Matthews can be in large part be explained by these factors.”

The report provides two examples of transaction costs, Macintyre Brook, NSW Qld Border Rivers

Region (irrigation), and South Creek, Western Sydney, NSW (urban water reform). Figure 4 in the

report demonstrates the complexity of framework that irrigators are subject to. Put simply, it is a

nightmare for a small business person to confront on a daily basis.

Figure 5, reproduced below, highlights the second nightmare confronting the management of South

Creek.

The report substantiates MI’s earlier claims of the problem of unwarranted intrusion and greater

complexity that may be created by the proposed ACCC Water Charge Rules.


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Member Owned Operators

The experience of privatised NSW irrigator owned corporations has been to see a reduction in the

inefficiencies that accompanied the government owned irrigation authorities. The lesson from this

experience is that clarity and efficiency is best viewed with one’s own eyes, in order to get a business

into order. The merging of the environmental, NWC, social and economic objectives may benefit

from more rather than less input from motivated and driven irrigators to reduce the complexities

described in the aforementioned Irrigation Futures report.

Further clarification on any aspect of this submission can be obtained by contacting the Griffith office

on 0269620200 or Leeton office on 0269530100.

Brett Tucker Managing Director 15th July 2008

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