To: Victorian Environmental Water Holder.

Letter concerning the potential sales of water for the 2018-2019 season

Made: October 2018

Our EFN members are concerned that under the current drought conditions, restricted water allocations and the upcoming State election, your office will come under increased pressure to trade water into Northern Victorian irrigation areas.
The recent sale by the CEWH in the Goulburn system was made possible in part by unusually high inter-valley transfers of water to downstream users substituting for environmental flows over the spring period.  Whilst we have concerns with this sale we believe the independence of the CEWH has been maintained despite political, industry and irrigator pressure and we respect the decision.
We do contend though, that the sale of this water did not reduce the trading price of water on the market and most likely went to horticulture and cotton industries across the southern connected basin, hence doing little to assist fodder production for drought areas.
We accept the VEWH’s authority to trade water in excess of requirements to meet annual environmental watering objectives and the water cannot be carried over, but are concerned that past decision making processes and modelling may no longer be appropriate.
Changing climatic conditions has made long term modelling predictions obsolete and raised the importance of risk management, risk management that includes planning for extended drought conditions.
We must remember that environmental water entitlements available to the VEHW are limited at the best of times and reduced to the servicing of habitat refuges under severe drought conditions.
EFN believe this is not a time to be putting the health of rivers and streams at risk of further damage.


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