The Victorian Farmers Federation (VFF) welcomes the opportunity to provide comment on the Long-Term Water Resource Assessment for Southern Victoria.
The Water Act 1989 requires a long-term water resource assessment every 15 years to assess whether water availability has declined or if waterway health has deteriorated for reasons related to changes in flow.
A long-term water resource assessment considers whether:
- A long term reduction in water availability needs to be shared more equitably between consumptive users and the environment; or
- Water sharing arrangements need to respond to a deterioration in waterway health related to changes in flow.
A draft technical assessment is prepared and made available for public comment, with the Environment Protection Authority (EPA) also providing an assessment.
Following a technical assessment a panel can be established which involves a number of review processes. The Minister then must determine a ‘program of implementation’, which allows for the permanent qualification of rights under Section 33AAB.
The VFF never supported this provision in the Water Act when it was changed in 2005 and the VFF believe this is an outdated piece of legislation that should be removed from the Long Term Water Resource Assessment process.
Victoria has worked tirelessly to establish a strong water market framework, where farmers are able to manage their own risk through carryover and reserve policies. Other water users, including environmental water holders also have the same ability.
The VFF strongly opposes the Minister’s powers to permanently qualify rights because they:
- Undermine the integrity of the market
- Are inconsistent with the approaches taken in the Basin Plan
- Further politicise water management
- Enables the Minister to pick winners and losers.
Summary of Recommendations
Recommendation 1: The Victorian Water Act (1989) is amended to ensure the permanent qualification of rights clause as a result of a long term water resource assessment is removed.
Recommendation 2: The Victorian Water Act (1989) is amended to ensure waterway health considers riverbank vegetation, aquatic life and water quality rather than just flows.
Recommendation 3: The Government examine waterway health using its Index of Stream Condition metric rather than simply reviewing flow.
Recommendation 4: The Government review changes in environmental health in wet, dry and average years.
Recommendation 5: The Government review the need to change environmental objectives before recovering more water for the environment.