The Concerned Waterways Alliance has lodged a detailed submission on the Victorian Government’s scoping paper for the new Western Region Sustainable Water Strategy.
The Strategy will guide water management across much of western Victoria for the next 50 years. CWA’s submission argues that this makes it critical to get the foundations right now, particularly what the Strategy means by “sustainable” in a region already experiencing declining river flows, stressed wetlands and fallinn the scoping paper that CWA supports, including its recognition of water as a living entity, its acknowledgement of a drying climate and its commitment to more integrated and collaborative water management.
However, our submission argues that the available evidence points to considerably greater urgency than is currently reflected in the scoping paper.
Sustainability must mean more than sustaining decline
A central theme of the submission is that sustaining an already degraded water system is not sustainability.
Across parts of western Victoria, water availability has declined substantially while consumptive use has remained comparatively stable, leaving rivers, wetlands and other environmental water to absorb much of the loss.
CWA is therefore calling for the Strategy to define sustainability clearly and to make maintaining and restoring ecological condition a fundamental constraint on water allocation decisions — rather than simply one interest to be balanced against others.
Importantly, the submission calls for environmental water deficits to be quantified and published for the region’s major river systems before the draft Strategy is released. Without knowing how much water waterways already need for recovery, it is impossible to make informed decisions about further allocation, trade or new demands.
Groundwater requires urgent attention
Groundwater is one of the strongest areas of concern identified in the submission.
DEECA’s recent Groundwater Sustainable Yield Assessment found that groundwater entitlements exceed assessed sustainable yield in five Western Region management units, while caps exceed sustainable yield in nine units and sub-zones. In another six south-western management units, no sustainable yield has yet been accepted.
CWA argues that groundwater entitlements and caps must be progressively brought back within sustainable limits, with restrictions on further allocation or activation of dormant entitlement where sustainable yield has not been established.
The Strategy must also better recognise the connection between groundwater and rivers, springs, wetlands and other groundwater-dependent ecosystems. If waterways are genuinely to be managed as living entities, that must include their vertical connection to groundwater, not simply the visible river channel.
The hidden impact of farm dams
The submission also highlights the cumulative interception of water by farm dams, plantations and other land-use changes.
As a small case study, CWA examined nine new or enlarged dams in headwater streams draining the Dundas Range near Cavendish. Together they have added an estimated 1,321 ML of storage since 2011 which is water intercepted before it can contribute to downstream river flows.
CWA is calling for cumulative interception studies across Western Region catchments, registration and volumetric accounting of catchment dams in identified hotspots, better controls on dam enlargement, and improved public reporting.
Rethinking the Wimmera–Glenelg system
The submission also calls for a long-overdue review of the Wimmera and Glenelg Rivers Environmental Entitlement.
Current dry-year rules can place the first burden of water shortages on the environment, while passing flows can ultimately be reduced to zero. CWA argues that these arrangements need to be reconsidered against today’s climate and projected future conditions.
Particular attention is also needed for the Wimmera terminal system, including Lake Albacutya and the wetlands extending towards Wyperfeld National Park, as well as the region’s Ramsar-listed wetlands and the Glenelg Estuary and Discovery Bay.
New industries should bring new water
Western Victoria is also facing growing water demand from mineral sands mining, timber processing, food production, renewable industries, carbon sequestration and potentially data centres.
CWA argues that this demand should not simply be added to already stressed rivers and groundwater systems.
Large new or expanding industries should be required to bring their own water, relying wherever practicable on recycled water, treated stormwater or appropriately treated brackish and saline water rather than taking additional freshwater from stressed systems or activating dormant entitlements.
Acting before the next drought
Western Victoria enters the next major drought from a very different starting point to previous generations. Climate change has reduced inflows, many wetlands have already been heavily altered, groundwater systems are under increasing pressure and significant quantities of water remain outside effective accounting.
That is not an argument for pessimism. It is an argument for urgency.
A 50-year Sustainable Water Strategy provides an important opportunity to act before the next crisis rather than after it. But that requires the draft Strategy to begin with an honest assessment of the condition of the region’s rivers, wetlands and aquifers, establish what they need to remain healthy, and then make water allocation decisions within those ecological limits.