To: Draft Northern Sustainable Water Strategy (Victoria)

Made: December 2008

The Environmental Farmers Network gives voice to a growing number of farmers dedicated to the environmental health of rural regions whose views are not being represented by traditional farmer organizations.
We consider the Northern Region SWS critical to both adapting to and acting to minimize global warming and climate change in rural Victoria.
The current dry spell and climatic predictions of a dryer future have brought to a head the condition of rivers and streams in Northern Victoria.
The community had growing concerns of over allocation of water for consumptive use prior to this period which led to the Living Murray and other water for the environment programs.
We are concerned that the environments share of water entitlements are disproportionately affected in dry times. The environments historic 50% share of the resource falls to 39% in dry times compared to the consumptive users share rising to 61%.
We are concerned that this “balance” between consumptive use and the environment does not meet community expectations. 

We recognize and applaud the efforts of those responsible for presenting the community with the Draft Strategy for comment.
We agree with the general thrust of the Strategy and make the following comments for consideration.

Chapter 5: Managing Risk and Uncertainty
We support all proposals however make the following comments.

5.10 Changing Environmental management objectives.
The statutory15 year review of water resources due in 2119 should brought forward if no improvement is seen in climatic outlook or the Federal buy back fails to provide necessary water to the environment. We suggest this review be brought forward to 2112.
The buy back of water for the environment has been handicapped by barriers to trade. Victoria has the 4% rule, others barriers are scattered throughout the Murray Darling Basin.  It is important that to achieve equity amongst States and the best use of the resource nationally these barriers be simultaneously attended to by the Federal Government.

 Chapter 6: Moving Water between Uses
We support all proposals with the following comments

6.2 Commonwealth Water Purchase for the Environment
This will require the close co-operation between Federal, State and reconfiguration implementation to best achieve multiple benefits for the environment, economy and the community.

 6.4 Upper Limits on Trade
We support the proposal and suggest the setting of maximum flow rates for all natural carriers used to deliver water for consumptive use, be considered. This will prevent further adverse impacts on rivers streams and wetlands.

Chapter 7: Maximizing Opportunities for Water Use
We support all proposals.

We support less human intervention in complex natural systems not more.
The weather system is complex and even without conflicting claims, human politics is already at a complexity that may exceed our capacities to organize co-operation of all parties. We are not in favor of cloud seeding!

We do not support the enlarging of Lake Buffalo and Lake William Hovell.
This decision takes into account adverse environmental impacts on the Ovens River, adverse impacts on the Barmah Forest and Victoria’s compliance with the MDBC Cap. 

Chapter 8: Clarifying Rights to Water
We support all proposals however with the following comments.

8.3 The Murray-Darling Cap-Groundwater

The fast growing use of ground water for stock and domestic purposes poses a serious risk to the groundwater resource. The entitlement rights to groundwater for Stock and Domestic purposes should be controlled and its use confined to closed reticulated systems.

8.5  Improving Bulk Entitlements for Unregulated Streams

The harvesting of more water in wet periods on unregulated streams will add to water storage losses. 

8.9 Properties of Environmental Entitlements                               

The properties of environmental entitlements should be no less favorable than consumptive entitlements and where possible more favorable, providing, there are minimal adverse effects on third parties.

It is important to maximize the effectiveness of environmental entitlements by mimicking natural flow regime as closely as possible.

        8.13 Goulburn 80 GL Flood Release                                                                                   
The effectiveness of the 80 GL bulk environmental entitlement on the Goulburn River is questionable given triggers on use and climate predictions.
If the effectiveness of this entitlement cannot be increased we suggest it not be tagged environmental water as this is misleading.

Farm Dams for stock and domestic use should be licensed.
To prevent a rush of dams prior to legislation, a retrospective date for licensing introduction be announced well in advance.
Entitlement requirements should be sourced by way of trade.


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