To: Department of Environment, Land, Water and Planning on "Water for Victoria"

Made: 9 May 2016

EFN has welcomed the opportunity to be involved in Victoria’s new Plan for water, “Water for Victoria” and endorses the inclusion in the plan of increasing populations and climate change impacts, additional expenditure on waterway health and catchments and the continuing support for Victorian Environmental Water Holder (VEWH) and the Environmental Water Reserve (EWR).

We offer the following comments based on sectional layout of the “Water for Victoria” Discussion Paper (Summary).

1. Climate Change

  • Strongly support increasing the water sector’s focus on mitigation and ensuring that the water sector plays an important role in climate change mitigation with long-term emissions reductions
  • Supports building the communities understanding of current and future impacts of climate change by incorporating new knowledge into planning to facilitate adaptation.

 2. Waterway and Catchment management

  • EFN strongly supports the Victorian Environmental Water Holder and the Water Reserve. As is the case federally, the ongoing independence of the VEWH is paramount to EFN. The VEWH’s planning links with CMA’s appear to be working well. 
  • The Basin Plan and its implementation as agreed and intended is an important step for the ongoing sustainability of Victorian rural industries. Victoria must ensure that it achieves water recovery targets and facilitates constraints management   that achieve maximum environmental outcomes for Victorian rivers.
  • EFN supports the engagement of Indigenous communities in the Water for Victoria Plan and its implementation.  It is vital indigenous values and uses of water are fully considered in water resource planning.  

3. Water for agriculture

  • EFN supports sustainable, productive agriculture.
  • Irrigation modernisation has significantly improved water use efficiency and on-farm productivity where implemented as planned in the GMID. Unfortunately the contraction of the system footprint hasn’t been optimised in all examples, which in some cases will not achieve the planned outcomes and leave some areas vulnerable to future production challenges.

  • Water reforms over past years have vastly added to agricultures resilience and this is nowhere more evident that in the Millennium drought with the ability to trade water between industries leading to not just the underpinning of those industries but the development of management systems that continue today.

  • EFN strongly supports water reforms including the ability to “bank” entitlements from year to year, “carry-over”. 
  • EFN believes the irrigation industry would be best served by a single National Water Market, along similar lines as the ASX for permanent and temporary transfers of water entitlements. Transparency is critical in any market and having numerous “water markets” and brokers does not have the confidence of many irrigators. We strongly support the development of other water “products” such as leasing and other arrangements.
  • We believe more emphasis is required on the impact of land based catchment activities and their relationship to river health and strongly support more effective Whole Farm Planning and education options.  
  • The Southern based issues appear to emphasis the utilisation of water not already allocated which we believe requires caution particularly when considering Climate Change.
  • We support the investment in Werribee, Bacchus Marsh and Maffra irrigation systems and believe a strong emphasis on efficiency programs is required.

4. Resilient and liveable cities and towns

  • EFN supports the engagement and empowering of the community to better understand  the competing uses for water and to achieve sustainable water management outcomes.

5. Recognising and managing for Aboriginal values

  • EFN supports the establishment of an Aboriginal Water Program to identify Aboriginal values and uses of water and meet objectives through shared benefits.
  • The building of capacity within the water management sector to engage with Traditional Owners is important, as is the building of confidence and expertise within our aboriginal communities if we are to see genuine participation in water management.

6. Recognising recreational values

  • EFN supports water and waterway planning that considers opportunities for shared benefits for recreational water users whilst not impacting on existing users or the environment. 
  • The capacity for recreational water users to make informed decisions regarding their recreational activities in full regard of water availability, costs and third party impacts is critical.

7. Water entitlement and planning frameworks

  • EFN strongly supports the continuing improvement of Victoria’s water entitlement framework.  
  • Our Water Act sets out a clear process for the Long Term Water Resource Assessments (LTWRAs), due to begin in 2017, and 15 year reviews. The 15 year review due to commence in 2019 would be the ideal opportunity to review the Sustainable Diversion Limits (SDLs) and the methodology behind them, and to determine an Environmentally Sustainable Level of Take (ESLT) for Victoria’s rivers which would resolve how water is shared between users and guarantee a reliable share for the river.

  • The Victorian SDLs are not based on a determination of an environmentally sustainable level of take nor have they ever been reviewed to take the impacts of climate change into account.
  • EFN welcomes a review of water used for domestic and stock in the State. This review should include the impacts of catchment dams and consider the encouragement of reticulated on-farm watering systems.  
  • Any separation of land from water in unregulated and groundwater systems requires careful consideration given some experiences in our irrigation regions. This separation inevitably leads to increased use of the resource which in many regions is not understood, particular connectivity with springs and wetlands.
  • EFN is again cautious of allowing increased capture of water during high flow periods within existing entitlement volumes as this can affect natural flooding and as in NSW be a problem with the “shepherding” of environmental flows  

8. Realising the potential of the grid and markets

  • EFN supports improvements to the Victorian Water Register and further expansion of the Victorian water grid. 
  • The expansion of the water grid has been important for water security and the resilience of communities.
  • Any refinement and development of market trading rules supporting water movement must carefully consider impacts on both existing users and the ongoing condition of rivers and streams

9. Jobs, economy and innovation

  • Innovation and research are critical to the reduction of water use over time by using water more efficiently.
  • Any review of the governance arrangements of the VEWH must ensure the maintenance of the VEWH’s independence.

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