The Coastal Waterways and Wetlands Alliance has lodged our submission on the Victorian Government’s scoping paper for the new Western Region Sustainable Water Strategy.
The submission complements and endorses the submission made by the Concerned Waterways Alliance, while concentrating specifically on the coastal end of western Victoria’s water systems — its estuaries, Ramsar wetlands, heritage rivers, coastal groundwater and the interface between freshwater and the sea.
Its central concern is straightforward: the scoping paper does not name a single Ramsar site, estuary or heritage river, despite the Western Region containing three Ramsar-listed wetlands, supplying a fourth across the South Australian border, containing two of Victoria’s eighteen heritage river areas, and supporting a chain of environmentally significant estuaries.
CWWA argues that these places cannot be treated simply as the downstream recipients of decisions made elsewhere. They are integral parts of the water systems the Strategy is being developed to manage.
A river does not end at the last gauging station
A key theme of the submission is the need for the Strategy to adopt a genuinely source-to-sea approach.
The scoping paper recognises waterways as living, integrated natural and cultural entities. CWWA strongly supports that direction, but argues that the concept must have practical meaning.
A living waterway depends on connections along the river from its headwaters to its estuary and sea; laterally to floodplains and wetlands; vertically between surface water and groundwater; and through time, with floods and other hydrological events occurring frequently enough to sustain ecological processes.
As the submission puts it, an estuary is the terminal expression of every upstream decision — allocations, passing flows, pumping rules and interception by farm dams. When those connections break, the consequences can emerge first at the river mouth through closure, increased salinity and nutrients, reduced fish passage and declining ecological condition.
Put internationally significant wetlands on the map
CWWA is particularly concerned by the absence of the region’s Ramsar wetlands from the scoping paper.
These include the Glenelg Estuary and Discovery Bay Ramsar site, the Western District Lakes and Ngalpakatia/Ngelpagutya (Lake Albacutya). Western Victorian waterways also contribute flows to the Ramsar-listed Bool and Hacks Lagoons across the South Australian border.
These are not simply environmental assets among many others. Ramsar sites have defined ecological values and existing Ecological Character Descriptions containing limits of acceptable change.
CWWA therefore argues that the Strategy should name these sites, identify their water requirements and use their existing ecological benchmarks to calculate environmental water deficits.
This is increasingly important as river flows decline. Average annual flows have fallen by around 57 per cent on the Glenelg at Dartmoor, 60 per cent on the Hopkins and 40 per cent on Darlot Creek when comparing 1973–96 with 1997–2019.
Finish the job at Lake Corangamite
The submission highlights Lake Corangamite as a particularly clear example of unfinished business.
The 2011 Western Region Sustainable Water Strategy committed to changes to the Woady Yaloak Diversion Scheme to improve flows to Lake Corangamite. Physical works have largely been completed, but the operating-rule change that would actually deliver more water to the Ramsar lake remains unresolved because of concerns about flood risk to adjoining land.
CWWA is calling for that issue to be resolved, with a clear completion date, responsible agency and funding pathway.
More broadly, the submission argues that the new Strategy should not simply carry unfinished actions forward indefinitely. Where the evidence exists and the necessary work has already been identified, implementation should be the priority.
Estuaries need water too
CWWA describes estuaries as among the region’s most neglected water-dependent assets.
The submission calls for environmental flow studies to be commissioned or updated for the Glenelg, Hopkins, Merri, Moyne, Curdies, Fitzroy and Darlot systems, with results expressed in a form that can actually inform water allocation and entitlement decisions.
It also calls for the State’s estuary entrance management framework to be updated for a future of lower freshwater inflows and rising sea levels, and for decisions to artificially open estuary mouths to be based on documented assessments of risks to environmental values.
Cease-to-pump rules for coastal streams should similarly recognise the needs of downstream estuaries, rather than treating them as incidental beneficiaries of whatever water remains.
Coastal groundwater is part of the same system
Groundwater is another major focus.
Six groundwater management units across the south-west — Nullawarre, Hawkesdale, Yangery, Heywood, Paaratte and Glenormiston — currently have no accepted sustainable yield. Across these areas, approximately 38,500 ML of currently unused groundwater entitlement could potentially be activated.
These aquifers are not isolated underground water supplies. They support karst springs, wetlands, summer baseflows in coastal streams and groundwater-dependent parts of the Glenelg Estuary and Discovery Bay Ramsar site.
CWWA is calling for the sustainable-yield work to be completed before further entitlement is issued or dormant entitlement activated, for groundwater-dependent ecosystem requirements to be assessed using ecological thresholds, and for the risk of seawater intrusion to coastal aquifers to be properly investigated.
Use the evidence we already have
Across its 22 recommendations, the submission repeatedly makes the same point: much of the necessary framework already exists.
Ramsar Ecological Character Descriptions have already established environmental benchmarks. Heritage rivers have already been designated. Groundwater protection guidelines already exist, although they need updating. Victoria already has methods for assessing estuary condition and environmental flows.
CWWA is not asking government to start again. It is asking that these existing tools and obligations be brought together and used to shape the next Western Region Sustainable Water Strategy.
The coast is where the cumulative consequences of decisions made throughout a catchment ultimately arrive. A Strategy intended to manage rivers and water resources for the next 50 years must therefore follow those rivers all the way to their wetlands, estuaries and the sea.