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Submissions close 11:59PM, Wednesday 8 October 2025.
Background: This submission addresses proposed changes to cease-to-pump rules across several unregulated river water sources in NSW (Gwydir, Macquarie/Wambuul Bogan, Namoi/Peel, and Lachlan). The changes include replacing several “no visible flow” rules with gauge-based thresholds to improve fairness, transparency, and ecosystem protection.
Make your online submission here
Guide for making an online submission:
First page - Fill in confidentiality preferences
Second page - Contact details
Third page-
- Comment on all of the below
- Do you support the proposed revised CTP rules? Yes
- Will you be directly affected by the proposed rules? As appropriate
- Will the proposed rules have any impacts (positive or negative) on your community? Answer and comment as appropriate
- Do you have any additional suggestions for sharing water access while reducing environmental risks in your area? Leave unsure or answer and comment as appropriate.
- Attach your written submission.
Supported Rule Changes
Support replacing existing flow rules or “no visible flow” rules with measurable, gauge-based cease-to-pump thresholds:
Gwydir Water Sharing Plan 2025
- Moredun Creek: cease-to-pump at ≤80 ML/day (Bundarra gauge).
- Tycannah Creek: cease-to-pump at ≤2 ML/day (Horseshoe Lagoon gauge).
- Copeton Dam Zone: cease-to-pump at ≤80 ML/day (Bundarra gauge).
Namoi & Peel Water Sharing Plan 2025
- Cockburn River Zone: cease-to-pump at ≤36 ML/day (Kootingal Bridge Weir).
- Maules & Horsearm Creeks: cease-to-pump at ≤75 ML/day (Maules Creek at Avoca East).
- Macdonald River (upstream Woolbrook): cease-to-pump at ≤60 ML/day (Woolbrook gauge).
- Macdonald & Namoi Rivers Zone: cease-to-pump at ≤16 ML/day (North Cuerindi gauge).
Macquarie/Wambuul Bogan Water Sharing Plan 2025
- Cudgegong River Downstream Zone: cease-to-pump at ≤3 ML/day (Rylstone gauge).
- Lower Bogan River: cease-to-pump at ≤48 ML/day (Gongolgon gauge).
Lachlan Water Sharing Plan 2025
- Lower Mandagery Creek Zone: cease-to-pump at 10 ML/day (Eugowra gauge) with 2-day “first flush” before pumping resumes.
- Boorowa River & Hovells Creek: cease-to-pump at ≤6 ML/day (Prossers Crossing gauge).
Equity and Fairness for Water Users
- Uniformity: all licence holders face the same restriction thresholds.
- Transparency: gauge data publicly available, reducing disputes.
- Fairness: ensures upstream users cannot disadvantage downstream irrigators.
Environmental Protection
- Improved ecosystem resilience: minimum flows secure refuge pools and food webs.
- Protection of threatened species: including Murray Cod, Eel-Tailed Catfish, Purple-Spotted Gudgeon, Booroolong Frog, Bell’s Turtle, and multiple endangered frog and fish species across catchments.
- Alignment with legislation: supports the Water Management Act 2000, which prioritises ecological protection.
Addressing Overstated Irrigator Impacts
- Current impact modelling is misleading as it uses gauged flows already influenced by extraction, “Additional lost pumping days” therefore exaggerated.
- Fails to highlight downstream benefits to irrigators under new rules.
Broader Reform Needs
- Over 400 unregulated water sources need stronger cease-to-pump rules.
- Current reliance on costly, slow “gold standard” gauges delays reform.
- The practice of downgrading risks due to absent gauges is unacceptable.
Overall Recommendations
- Update all four Water Sharing Plans with the proposed gauge-based cease-to-pump rules.
- Revise DCCEEW consultation materials to correct overstated impacts on irrigators.
- Expand reform efforts across NSW unregulated water sources by installing low maintenance, low tech and more cost-effective gauging solutions.
- Prioritise installing gauges in unregulated systems.
- Adopt a precautionary approach prioritising ecosystem protection.