The Natural Sequence Association (NSA) has laid out its concerns in a submission. Martin Royds Chair of the NSA governing body says it is worrying that the draft proposes taking power from the Minister to approve any works in minor waterways.

The submission says, "We are concerned with Part 13 Section 78 sub-clause (1) of the unregulated river water sources Draft Water Sharing Plan. This sub-clause "prohibits the construction of new in-river dams requiring approval, except for approvals sought by either a local water utility or a major utility for the purpose of town water supply,... an in-river dam is defined as a dam on a 3rd, 4th or higher order river."

Mr Royds continued that "Natural system management practices, such as natural sequence farming, replicate Australia's natural hydrological processes to reinstate the 'chain of ponds' system that once dominated our landscape. Unsuitable land management practices applied post-European settlement, including alluvial gold mining, has left us with the current degraded 'drainage' system. A fundamental constituent of natural sequence management is the construction of in-river structures (dams, berms, weirs, fascines etc.) to re-establish the 'chain of ponds' system. In-river structures are used to create vegetated ponds, which laterally rehydrate the landscape, repair incisions, cleanse water, reconnect water with floodplains, capture valuable nutrients, sustain biodiversity, prevent salinity outbreaks, sequester carbon, and minimise flood damage. The complete prohibition of the construction of in-river structures, however, renders natural sequence management inoperative, despite its clear economic and environmental value to the greater metropolitan region."