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Summary of submissions to the discussion paper on trade of Commonwealth environmental water

A discussion paper on trade of Commonwealth environmental water was released for consultation over the period from November 2011 to May 2012. Forty four submissions were received from a range of stakeholders including national and state industry groups, irrigation corporations, state government agencies, water brokers and individuals.

Approximately eighty five percent of the submissions either explicitly supported or were generally in agreement with trading by Commonwealth Environmental Water Office (the Office). Three submissions explicitly indicated that they do not support trade of Commonwealth environmental water and it should not be traded, and a further three submissions were generally not in agreement with trade. Most submissions indicated that the discussion paper was a positive step in developing a trading framework and welcomed the opportunity to participate in the consultation process.

Whilst there was broad general support for trade most stakeholders also addressed issues, some of which had been raised in the discussion paper:

  • Nearly three-quarters of respondents noted the size of the Commonwealth environmental water holdings and potential market impacts of trade;
  • Approximately two-thirds supported the need for transparency to assist water market participants to understand the operations of the Office;
  • More than half were concerned about potential adverse third party impacts as a result of trade and carryover of significant amounts of water by the Office;
  • Just under one-third commented on the need for more information about environmental water plans as well as a portfolio management strategy;
  • Approximately fifteen percent raised:
    • the need to address any conflict of interest issues;
    • the need for controls and monitoring of trading arrangements;
  • Approximately ten percent suggested that:
    • the Water Act should be amended (section 106) to provide for greater flexibility in trading; and
    • socio-economic issues should be considered as well as environmental outcomes when considering trading.

The next step in the process will be the public release of a position paper with our responses to the issues raised in the submissions. This will inform development of operating rules which will establish the general framework within which trade will occur.

Fact sheets on carryover issues will also shortly be released and it is intended that each year information will be provided on carryover of Commonwealth environmental water and comparisons to other carryover.

As the process of developing trading arrangements is ongoing, we welcome feedback, both formal and informal, on trading arrangements at any stage. Feedback can be sent to:, or by mail to the following address:

Commonwealth Environmental Water Office
Department of Sustainability, Environment, Water, Population and Communities
GPO Box 787
Canberra ACT 2601