The Concerned Waterways Alliance (CWA) has lodged its submission on the Draft Third Victorian Waterway Management Strategy, welcoming several important advances while arguing that the final strategy must do more to guide CMAs in halt the continuing decline of Victoria's rivers, wetlands, estuaries and groundwater-dependent ecosystems.
The draft strategy represents the first time Victoria has formally recognised waterways as "living and connected entities" within its overarching waterway policy framework. This is a significant step forward and reflects a long-standing recommendation advocated by the Alliance and many community waterway groups across the state. The strategy also includes welcome reforms such as stronger recognition of environmental watering, improved consideration of Ramsar wetlands, a dedicated estuary framework, cumulative impact assessment provisions, and commitments to develop guidelines for emerging contaminants.
However, the Alliance believes the strategy does not yet fully align its policies and decision-making framework with the implications of recognising waterways as living entities.
The central theme of the CWA submission is that while the draft strategy adopts stronger language around ecological protection, many of its key policies remain framed around balancing competing values and uses. The Alliance argues that environmental condition should not simply be one factor weighed against competing interests, but rather the foundation upon which all social, cultural and economic benefits ultimately depend.
The submission questions whether a strategy built around "balance", "transition" and "transformation" risks normalising ecological decline rather than preventing it. In particular, it calls for clearer decision-making frameworks to ensure waterways are not prematurely written off when restoration or recovery remains possible.
Farm Dams and Environmental Flows
One of the strongest concerns raised by the Alliance is the absence of a dedicated policy response to farm dam proliferation.
The submission argues that cumulative interception from farm dams remains one of the most significant and least addressed threats to environmental flows in many Victorian catchments. It highlights the Moorabool catchment as an example where significant environmental water gains have been offset by continued growth in farm dam storage capacity. The Alliance contends that the final strategy should include stronger accounting, monitoring and regulatory mechanisms to address cumulative interception impacts.
The submission also calls for periodic reviews of environmental entitlements, passing flow arrangements and bulk entitlement settings to determine whether they remain sufficient under a drying climate.
Protecting Ramsar Wetlands
The Alliance welcomes improved monitoring commitments for Victoria's internationally significant Ramsar wetlands but expresses concern that the draft strategy could allow ecological decline to be accepted where maintaining ecological character is considered not "cost-effective".
The submission argues that Victoria's approach should be consistent with Australia's obligations under the Ramsar Convention and emerging Commonwealth environmental standards, which require ecological character to be maintained and, where already declining, restored.
Groundwater Cannot Remain an Afterthought
Despite the strategy's recognition of connected systems, the Alliance believes groundwater remains underrepresented throughout the draft.
The submission calls for stronger recognition of groundwater-surface water interactions, groundwater-dependent ecosystems, hyporheic zones and stygofauna. It also argues that the concept of waterways as living entities must explicitly include vertical connectivity between groundwater and surface water if it is to genuinely reflect the full hydrological cycle.
Community Participation Must Mean More Than Consultation
The Alliance notes that while the draft strategy frequently acknowledges the value of community involvement, it provides very few mechanisms for communities to participate directly in governance and decision-making. The submission highlights successful examples such as the Moorabool Yarning Circle model and calls for similar community reference forums to be established across Victoria.
Looking Ahead
Overall, the Concerned Waterways Alliance regards the Draft Third Victorian Waterway Management Strategy as a substantial improvement on previous iterations and acknowledges the efforts of the DEECA strategy team and Victoria's Catchment Management Authorities. At the same time, the Alliance believes the final strategy must better align its implementation framework with its vision.
If waterways are to be recognised as living and connected entities, then that recognition must extend beyond philosophy and become a practical decision-making principle that shapes environmental water recovery, groundwater management, planning decisions, water quality protection and community participation. The coming decades will be defined by climate change, declining inflows and increasing competition for water. The final Victorian Waterway Management Strategy must be capable of meeting those challenges.