Fundamentally, we believe there has been an overallocation of licensed extraction in the Orara River which occurred without due consideration of the harvestable rights of all properties along that river for domestic and stock purposes. The Clarence WSP appears to be trying to mask the problems that water extraction poses for that river by including it in a broad, catchment-wide water sharing plan. The CEC believes that the Clarence WSP is also flawed by the lack of lack of fine detail in defining the extraction management units, which has allowed the dealing (or trading) in water access licences between disparate sub-catchments and micro-catchments.