Federal Register of Legislation - Australian Government

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Other as made
This Protocol sets rules for adjusting valley accounts and State transfer accounts.
Administered by: Agriculture, Water and the Environment
Exempt from sunsetting by the Water Act 2007 s 18C(3)
Registered 14 Sep 2010
Tabling HistoryDate
Tabled HR28-Sep-2010
Tabled Senate28-Sep-2010

MURRAY-DARLING BASIN AGREEMENT (SCHEDULE D – ADJUSTING VALLEY ACCOUNTS AND STATE TRANSFER ACCOUNTS) PROTOCOL 2010

 

EXPLANATORY STATEMENT

 

1.    INTRODUCTION

1.1.   The Murray-Darling Basin Agreement (Schedule D – Adjusting Valley Accounts and State Transfer Accounts) Protocol 2010 (the Protocol) sets out the rules for maintaining accounts to record the volume of water allocations and entitlements transferred / traded between trading zones. Other Protocols made under Schedule D establish the valleys between which transfers may occur, restrictions on such transfers and the exchange rates to be applied (usually 1:1) for transfers between particular zones.

1.2.   As well as setting out accounting rules, the Protocol sets out rules for delivering the water necessary to supply transfers of allocations and entitlements.

1.3.   The Protocol is made under paragraph 6(1)(c) and (f) of Schedule D to the Murray-Darling Basin Agreement (the Agreement).  The Agreement is Schedule 1 to the Water Act 2007 (the Act).  The Protocol is a legislative instrument: see section 18D of the Act.

1.4.   The Protocol commences on the day after it is registered on the Federal Register of Legislative Instruments.

1.5.   The Protocol is not subject to disallowance by Parliament nor the sunsetting rules in Part 6 of the Legislative Instruments Act 2003: see section 18D of the Act.

1.6.   The Protocol revokes the Murray-Darling Basin Agreement (Adjusting Valley Accounts and State Transfer Accounts) Protocol 2010.  This protocol was made and registered on the Federal Register of Legislative Instruments on 25 January 2010.

1.7.   The Contracting Governments to the Agreement have been consulted in the development of this Protocol.

1.8.   The Office of Best Practice Regulation has also been consulted on this Protocol and has determined that regulatory impact statements will not be required for this Protocol.

 

2.    TYPES OF TRADE

2.1.   Trade of allocation

The basic rule is that when allocation is traded, the full nominal volume of the trade must be transferred from the seller’s trading zone to the buyer’s.

2.2.   Trade of entitlement – exchange rate mechanism

This mechanism for trading entitlement ceased on 30 June 2007 barring an exception for back-trade into the Goulburn. However there is a legacy of exchange rate trades. The basic rule is that in each year the allocations that would have been made to the entitlements in the buyer’s trading zone must be passed to the seller’s trading zone. This means that:

·        any under-use benefits the buyer’s trading zone / State;

·        in years when the allocation in the buyer’s trading zone is lower than that in the seller’s, insufficient water will be transferred to meet the buyer’s allocation. The shortfall is met by all holders of entitlement in the buyer’s trading zone;

·        in years when the allocation in the buyer’s trading zone is higher than that in the seller’s, more than enough water will be transferred to meet the buyer’s allocation. The excess benefits all holders of entitlement in the buyer’s trading zone.

2.3.   Trade of entitlement – tagged mechanism

This mechanism has been in place since 1 July 2007. The basic rule is that the seller’s trading zone must transfer to the buyer’s trading zone the allocation actually used by the buyer. Thus any under-use benefits the seller’s trading zone / State.

 

3.    TYPES OF ACCOUNT

3.1.   The Protocol distinguishes between two types of accounts:

·        “valley accounts” which are accounts maintained between valleys/trading zones within a State. Examples are the Goulburn valley account, between the Goulburn and the Victorian Murray, and the Murrumbidgee account, between the Murrumbidgee and the New South Wales Murray;

·        “State transfer accounts” which are between valleys / trading zones in different States. These may be between an upper State and South Australia, between the Victorian Murray and the New South Wales Murray (accomplished by a transfer between Victorian and New South Wales in Hume) or between an upper State and the Snowy Scheme as a result of transfer of Snowy savings. The Snowy accounts are currently needed only for environmental water, as non-environmental entitlement holders do not trade between the Murray and Snowy.

3.2.   Functionally, both types of accounts can be regarded as keeping track of the physical transfers of water between trading zones which are needed to maintain the integrity of water traded between them by holders of entitlements and allocations.

3.3.   Accounts are maintained in each valley. If, for example, an entitlement is transferred from the Goulburn Valley to South Australia, it will be necessary to adjust not only the accounts for the valley of origin (Goulburn) and the State of destination (South Australia) but also the account for the intermediate Victorian Murray, through which any water delivered to meet the transfer must pass.

3.4.   The schematic relationship between accounts is set out below:

 

 

3.5.   Table 1 of the Protocol illustrates the accounts that need to be adjusted for transfers between particular zones, and is reproduced below.

 

Table 1 – Valley Accounts and State Transfer Accounts

To

From

Goulb

Camp-aspe

Loddon

Vic M

NSW M

Bidgee

SA

Snowy

Lwr D

Goulb

 

-

C

L

G

G, H

G, H, B

G, V

G, Sv

G, H, D

Camp-aspe

 

-

C, L

(not G)

C, G

C, G, H

C, G, H, B

C, G, V

C, G, Sv

C, G,  H, D

Loddon

 

 

-

L, G

L, G, H

L, G, H, B

L, G, V

L, G, Sv

L, G,  H, D

Vic M

 

 

 

 

-

H

H, B

V

Sv

H, D

NSW M

 

 

 

 

 

-

B

N

Sn

D

Bidgee

 

 

 

 

mirror

 

-

B, N

B, Sn

B, D

SA

 

 

 

 

image

 

-

V(orN), Sv or Sn

D, N

Snowy

 

 

 

 

 

 

 

 

-

D, Sn

Lwr D

 

 

 

 

 

 

 

 

 

 

 

**

 

Key to accounts

G          Goulburn valley account

C          Campaspe valley account

L          Loddon valley account

B          Murrumbidgee valley account

D          Lower Darling valley account

H          Vic/NSW transfer account in Hume

V          Vic / SA transfer account

N         NSW /SA transfer account

Sn        Snowy environmental transfer account (NSW)

Sv        Snowy environmental transfer account (Vic)

 

4.    GENERAL RULES FOR ADJUSTING ACCOUNTS

These are set out in Part 2 (i.e. sections 6 to 10) of the Protocol, which covers both valley accounts and State transfer accounts. The following sections of this explanatory statement deal with each account in turn, rather than generalising.

 

5.    GOULBURN VALLEY ACCOUNT

Principles

5.1.   In principle, the Goulburn valley account is increased when any of the following events occurs:

·        there is trade of allocation out of the Goulburn system (or the “upstream” tributaries of Campaspe and Loddon) to the Victorian Murray (or another downstream location to which trades are possible);

·        there is allocation to Goulburn irrigators, which means that the same allocation is notionally made to all entitlements that historically traded out of the Goulburn under the “exchange rate” regime that ended on 20th June 2007. No further exchange rate trades “out” are possible, but Victoria may allow trades of entitlement back “in” to be via the exchange rate process;

·        water is “used” by entitlement holders of rights that have traded out of the Goulburn and tributaries under the “tagged trade” arrangements that have been in place since 1 July 2007. This is recorded when the water is ordered and is later adjusted as necessary for actual use.

5.2.   The account is decreased when any of the following events occurs:

·        there is trade of allocation into the Goulburn system (or tributaries) from the Victorian Murray (or another downstream location);

·        water is physically “called out” of the Goulburn system to the Murray by the Authority;

·        the account is reduced because of spills.

Present practice

5.3.   Victoria has a semi-automated arrangement that enables it to keep track of what it believes is in the account by taking information about trades and retail use from its Water Register. It publishes information about the “back-trade” available to any trading zone from any other trading zone on www.waterregister.vic.au The volume quoted as “available for back-trade” from the Victorian Murray to the Goulburn will not necessarily be the full balance in the Goulburn valley account, as it will exclude any volume reserved for such purposes as call-out by the Authority.

5.4.   However, Schedule D and the protocols provide that the Goulburn account is kept by MDBA and require the following:

·        Trade of allocation. At the end of each month, Victoria must inform the Authority of the net volume of trade of allocation out of the Goulburn Valley to each other trading zone. The Goulburn valley account is adjusted, by the full value of the sum of the trades.

·        Trade of entitlement – exchange rate trade. Again, Victoria must inform the Authority monthly. The account is adjusted for progressive allocation to the historical legacy of trade of entitlement out of the Goulburn as at the previous 1 July, plus increases in allocation after the date of permanent trade to any entitlements traded in the current year, in accordance with the Goulburn allocation, and at the time the allocation is made. The account is adjusted for the full net value of the trade.

Note that if “unused” allocation is traded with a permanent trade, this is a separate allocation trade.

·        Trade of entitlement – tagged trade. In theory the Goulburn valley account is adjusted as each retail order is made for delivery of allocations arising from the traded entitlements (estimates may be used if more practical), and a further reconciliation adjustment is made when the actual retail usage is known. Again, Victoria reports monthly to the Authority, so in practice the adjustments can only be made monthly by the Authority.

Note that:

·        Goulburn irrigators will have access only to Goulburn entitlement (or Campaspe or Loddon which are upstream), whether the entitlement is located on the Goulburn or tagged elsewhere.  This is the only entitlement that can be guaranteed to be able to be delivered from Eildon.  Thus there will be no Murray (or any other downstream) entitlement allowed to trade into the Goulburn as back trade other than possibly exchange rate trade as described in the next dot point. This makes the accounting for permanent trade out of tagged entitlement simpler – the whole of the net trade out is relatively simple to identify.

·        An additional complication is the legacy of exchange rated trade out. Victoria may decide to allow both tagged trade out of the Goulburn (and reversal of such trade) and exchange rate trade into the Goulburn simultaneously until all (or some agreed portion) of the legacy exchange rated trade out has been back-traded, and then move to fully tagged trade. Such exchange rate trade will include only high reliability products. 

Other comments

5.5.   The account kept by Victoria and that kept by the Authority should reconcile except for timing differences. A process will need to be set up to ensure that the two versions do reconcile.

5.6.   As per Table 1, other accounts may need to be adjusted by the same volume, depending on the location of purchasers. The accounts for the Goulburn, Campaspe and Loddon may be treated as one by the MDBA under current (as of 2009/10) trading rules.

5.7.   The Authority may call the water out of the Goulburn valley account (effectively from Eildon Reservoir or by reducing diversions to Waranga Basin) based on system demands in the Murray (including allocations to the purchased entitlements). Subject to agreement by the Authority, the water may be delivered from the Broken Creek or from the Campaspe rather than directly down the Goulburn. The volume and timing of call-outs is specified in agreed annual operating plans agreed between Victoria and the Authority as part of the annual operating plan.

5.8.   If releases from the Goulburn valley are restricted by channel capacity in the Goulburn River, the available channel capacity must be apportioned between rights to water remaining in the Goulburn valley and rights to water traded downstream, in proportion to those rights.

5.9.   The volume of water delivered in response to a call-out is verified through discussions between Victoria and the Authority, and the agreed volume is applied to reduce the volume in the account. The principle is that the volume that would have passed in the absence of the call-out is estimated, and the volume called out is recorded as the actual less the estimated with no call-out, less unregulated flows over the period. That process takes care of lags between changes of call-out order (because of rain events for example) and delivery of water.

5.10.                    The portion of the valley account that spills when spill or pre-release occurs from Eildon is determined by Victoria, within limits set by the protocol.  This allows for Victoria to determine how spill is assigned between the valley account and its’ entitlement holders. The limits set by the protocol mean that the volume spilled from the account cannot exceed the unused volume carried over from a previous year and that water added to the account in the current year is not subject to spill.

 

6.    MURRUMBIDGEE VALLEY ACCOUNT

Principles

6.1.   The principles are the same as for the Goulburn valley account. However, although the Protocol (sub clause 11(2)) provides for dealing with exchange rate trade, such trades have not previously been allowed in New South Wales, and are unlikely in the future. There is thus no legacy of exchange rate trade to be accounted for.

6.2.   As with the Goulburn valley, the only back-trade of entitlements into the Murrumbidgee that are allowed are those that are “native” to the Murrumbidgee and have previously been “tagged out”.

Present practice

6.3.   As for the Goulburn, New South Wales keeps its own valley account for the Murrumbidgee.

6.4.   However, again as for the Goulburn, Schedule D and the protocols provide that the Murrumbidgee account is kept by the Authority and require the following:

·        Trade of allocation. At the end of each month, New South Wales must inform the Authority of the net volume of trade of allocation out of the Murrumbidgee Valley to each other trading zone. The Murrumbidgee valley account is adjusted, by the full value of the sum of the trades.

·        Trade of entitlement – exchange rate trade. This does not apply, as there are no legacy exchange rate trades.

·        Trade of entitlement – tagged trade. In theory the Murrumbidgee valley account is adjusted as each retail order is made for delivery of allocations arising from the traded entitlements (estimates may be used if more practical), and a further adjustment is made when the actual retail usage is known. Again, New South Wales reports monthly to the Authority, so in practice the adjustments can only be made monthly by the Authority

6.5.   Note that:

·        In principle, under tagged trade the net trade in or out of each entitlement product and the usage of allocations from each entitlement product must be considered, and the result amalgamated into an aggregate net use. Trade may be of High Security or General Security entitlement.

·        As with the Goulburn, “back trade” of entitlement into the Murrumbidgee can only be of “native” Murrumbidgee entitlement that has previously been “tagged out.” This simplifies accounting for permanent trade out of tagged entitlement.

Other comments

6.6.   The account kept by New South Wales and that kept by the Authority should reconcile except for timing differences. A process will need to be set up to ensure that the two versions do reconcile.

6.7.   As per Table 1, other accounts may need to be adjusted by the same volume, depending on the location of purchasers.

6.8.   The Authority may call the water out of the Murrumbidgee valley account (effectively from Blowering or Burrinjuck) based on system demands in the Murray (including allocations to the purchased entitlements). Subject to agreement by the Authority, the water may be delivered from Billabong Creek, or by transfer of Snowy releases from the upper Murrumbidgee catchment to the upper Murray via the Tumut development of the Snowy Scheme rather than directly down the Murrumbidgee. The volume and timing of call-outs is specified in agreed annual operating plans agreed between New South Wales and the Authority as part of the annual operating plan.  Where Snowy releases are transferred the volume supplied is assumed to be delivered in equal monthly quantities between the month in which the supply is announced and the following 30 April, inclusive.

6.9.   If releases from the Murrumbidgee valley are restricted by channel capacity in the Murrumbidgee River, the available channel capacity must be apportioned between rights to water remaining in the Murrumbidgee valley and rights to water traded downstream, in proportion to those rights.

6.10.                    The volume of water delivered in response to a call-out is verified through discussions between New South Wales and the Authority, and the agreed volume is applied to reduce the volume in the account. The mechanism is the same as for the Goulburn.

6.11.                    The portion of the valley account that spills when spill or pre-release occurs from Burrinjuck or Blowering is determined by NSW, within limits set by the protocol.  This allows for NSW to determine how spill is assigned between the valley account and its entitlement holders. The limits set by the protocol mean that the volume spilled from the account cannot exceed the unused volume carried over from a previous year and that water added to the account in the current year is not subject to spill.

 

 

7.    TRANSFER ACCOUNT IN HUME BETWEEN VIC AND NSW

7.1.   A State Transfer Account is notionally located at Hume Reservoir to track net transfers of allocation and transfers of entitlement between New South Wales Murray and Victorian Murray. The account is kept by the Authority according to the following rules:

·        Trade of allocation. Figures are provided monthly by New South Wales and Victoria. The account is adjusted each month for net transfers of allocation between New South Wales and Victoria by the full value of the net trade in the preceding month.

·        Trade of entitlement – exchange rate trade. There is a small legacy (about 5.075 GL when exchange rate trade ceased on 30 June 2007) of exchange rate trade from Victoria to New South Wales resulting from the Pilot Scheme.

·        The account is adjusted as described in clause 1 of Appendix 2 of Schedule D. This clause states that the adjustment is “by the volume of the allocations that would have been made to the entitlement in the State of Origin in every year if the entitlement had not been transferred” The adjustment is a simple calculation if the legacy volumes and the seasonal allocations are known.

·        Trade of entitlement – tagged trade. Again, figures are provided monthly by New South Wales and Victoria. The account is adjusted by the net use of allocations to all entitlements traded. This means that the use of allocations to all Victorian entitlements traded to New South Wales must be calculated and subtracted from the use of allocations to all New South Wales entitlements traded to Victoria.

·        Delivery of water  The water is delivered not by physical “calling out”, but by adjusting the water allocated to New South Wales and Victoria in Lake Hume as described in clause 9(2)(a) of the Protocol for entitlements and 9(3)(a) of the Protocol for allocations. These clauses state that:

·        adjustments for entitlement trade are to be made between “the later of September and the month in which the alteration is to be made” and the following April, in proportion to SA’s monthly entitlement as set out in paragraph 88(a) of the Agreement. Adjustments for entitlement trade in May and June are made between September and April in the following year;

·        adjustments for allocation trade in July to April are similarly made over the period to the next April unless otherwise agreed by the Authority;

·        adjustments for allocation trade in May and June are made in those months unless otherwise agreed by the Authority.

7.2.   Note that the timing of delivery: i.e. adjusting the New South Wales and Victorian shares in Hume, is important because if all the adjustment for trades of allocation (the vast majority of trade) was made immediately following the trade, the chance of internal spill is increased compared with the chance of internal spill if the State shares are adjusted progressively over the season as some of the water is progressively used. It has been agreed that the most equitable method is to make all adjustments, whether arising from allocation or exchange rate entitlement or tagged entitlement change, progressively over the season on a monthly basis as described above.

7.3.   This gives rise to the concept of a transfer account that holds water for some months during the year but is zeroed by adjusting the New South Wales and Victorian shares of Hume by the end of the year (other than minor overdraws or underdraws associated with estimates of use and trade which are later updated to actual use, and allocations arising from entitlement trades in May and June).

8.    TRANSFER ACCOUNTS BETWEEN SA AND UPPER STATES

8.1.   A State transfer account is kept between each upper State and South Australia at the South Australian border. It acts to pass to South Australia a volume equivalent to any net trade between that State and South Australia.

·        Trade of allocation - As for other accounts, adjustments in the state transfer account are made for trades of allocation between each upper State and South Australia, by the full value of the trade. Adjustments are made to the transfer accounts at the end of each month for trades during the month.

·        Trade of entitlement – exchange rate trade  There is a legacy of exchange rated trade from both Victoria and New South Wales to South Australia resulting from the Pilot Scheme.

Again, the accounts are adjusted as described in clause 1 of Appendix 2 of Schedule D; by the volume of the allocations that would have been made to the entitlement in the State of Origin in every year if the entitlement had not been transferred.

Transfers into the accounts take place as allocations are announced.

·        Trade of entitlement – tagged trade  Again, figures are provided monthly by New South Wales and Victoria. Each account is adjusted by the net use of allocations to all entitlements traded (Schedule D Appendix 2 Part 1 clause 1).

This means that, for the Victoria / SA transfer account the use of allocations to all Victorian entitlements traded to South Australia must be calculated. The use of any allocations to South Australia entitlements traded upstream to Victoria would need to be subtracted.

The NSW / SA transfer account is kept in an identical way.

·        Delivery of water  No “callout” by South Australia is required. In the absence of other agreement transfers out of the accounts take place each year by delivery of the appropriate volumes as for Vic/NSW transfers in Hume (i.e. as described in clauses 9(2)(a) and 9(3)(a) of the Protocol).

The Authority can agree to vary the delivery of water to meet expected environmental and consumptive demands within SA.

The volume to be delivered is rationed if necessary in accordance with any rationing of delivery rates imposed in the source valley.

Any overdraw is carried forward to the following year and offset against allocations in that year.

8.2.   Note that as for the timing of transfers between New South Wales and Victoria in Hume, the timing of physical deliveries to South Australia is important as South Australia has no significant storages to capture deliveries and release them when needed. It has been agreed that the most equitable method is to make all adjustments, whether arising from allocation or exchange rate entitlement or tagged entitlement change, as described above.

 

9.    LOWER DARLING ACCOUNT

9.1.   This clause only applies when the Authority has power to direct that water be released from Menindee Lakes Storage pursuant to sub-clause 99(1) of the Agreement.

9.2.   Trade of allocation-At the end of each month, New South Wales must inform the Authority of the net volume of trade of allocation out of the Lower Darling Valley to each other trading zone. The Lower Darling Valley account is adjusted, by the full value of the sum of the trades.

9.3.   Trade of entitlement – No entitlement transfers are permitted into or out of the Lower Darling.

9.4.   Where the Lower darling Valley Account (LDVA) has a positive balance the next releases from Menindee (under Clause 120 (1) (d) of the Agreement) assigned to NSW under sub-clause 120(3)(c) of the Agreement will be deliveries from the LDVA.

9.5.   Where the Lower darling Valley Account (LDVA) has a negative balance the next transfer that would have been made from the  Lower Darling to the Murray will be delayed so that a volume equal to the negative balance of the account is not released and the LDVA will be credited with that volume.

9.6.   The Lower Darling Account sits in the NSW share of the Menindee Lakes and spills from the account may be deemed to occur as a result of pre-release, physical spill and internal spill.

Note the trading rules for the Lower Darling Valley are outlined under a Protocol made under paragraph 6(1)(e) (Permissible transfers between trading zones) of Schedule D.   

10.           SNOWY ACCOUNTS

10.1.   These two accounts do not strictly meet the protocol’s definition either of a State Transfer Account or an Intervalley Account. The Protocol refers (Table 1) to them as “Environmental transfer accounts.” They deal only with environmental water, because there is no non-environmental trade between the Murray and the Snowy Scheme

10.2.   Functionally the Snowy accounts act as accounts between trading zones. Effectively the States trade / transfer “Snowy recovery” allocations to the Snowy Scheme each year. Approximately a third of the water is eventually traded / transferred back to the (New South Wales or Victoria) Murray as “RMIF water.”

10.3.   This section is not really an explanation of the protocol, but more a note on the present operation of these accounts and the need for integration with other water accounting arrangements in the connected lower Murray-Murrumbidgee-Goulburn basin.

10.4.   The two Snowy transfer accounts deal with transfers to the Snowy pursuant to the Snowy Water Inquiry Outcomes Implementation Deed 2002 (SWIOID) initiative of the Joint government Enterprise. The SWIOID requires both New South Wales and Victoria to undertake water efficiency savings projects and, if needed, acquire water from irrigators, to enable 282 GL/year of water to be dedicated as environmental flow for the Snowy and Murray rivers within 10 years. Of the first 210 GL recovered, one third will go to the Murray (70 GL) and two thirds to the Snowy (140GL). The remaining 72 GL will go to the Snowy.

10.5.   For some projects the volume of water saved varies from year to year and will not be known till the end of the irrigation season. Consequently the total savings are to be identified at the end of the season and will remain in the relevant storages to be “available” for the following season. Any environmental water allocated to the Murray River is to be put aside by Snowy Hydro for release at its discretion into the Murray as above target water.

10.6.   To account for the transfer of water from the Murrumbidgee, Murray and Goulburn storages to the Snowy Scheme in each year, the following transactions are needed:

·    water to be transferred from the Goulburn will be credited to the Goulburn Valley Account and therefore available as a Victorian Murray allocatable resource. The Victorian Bulk Entitlement actually requires this to be done each year, but the Eildon Storage operator cannot be expected to know that.  In the language of the protocol, the Minister responsible for those allocations is choosing not to use any of it, but is temporarily trading it to his own Snowy Environmental Reserve entitlement on the Murray;

·   the volume available to the Victorian Murray from the Snowy Scheme is reduced by the volume transferred from the Goulburn to the Victorian Murray plus the volume transferred from the Victorian Murray to the Snowy. In the language of the protocol, that amounts to a temporary trade from the Victorian Murray to the Snowy;

·    the volume available from the New South Wales Murray to the Snowy Scheme is in effect moved to the Snowy by trade of allocation from the NSW Murray to the Snowy Scheme;

·    the volume available from the Murrumbidgee to the Snowy Scheme is traded / transferred there by a similar process. In principle that trade could be made via the New South Wales Murray, providing back trade opportunities through the Barmah Choke, or direct from the Murrumbidgee to the Tumut development of the Snowy Scheme.

10.7.   When water is released from the Snowy back into the Murray as RMIF water under the provisions of the SWIOID, it is in effect being traded / transferred into the control of the States, which then use it for environmental watering along with TLM water and any other environmental water available to it. The other environmental water will generally be held in the form of water shares, licences etc just like irrigation entitlements, and will be accounted for by normal Water Register processes as it is used.

10.8.   Victoria treats RMIF water as a trade of allocation from somewhere outside the State into an allocation bank account held by the Victorian Environmental Manager. New South Wales monitors RMIF through the accounts kept by the Authority.

10.9.   Environmental water already includes:

·   rights conferred by bulk entitlements, water sharing plans etc;

·   Snowy water;

·   purchases by States;

·   purchases by the Authority;

·   purchases by the Commonwealth.

 

Much of this water is held as ordinary water shares licences etc., probably representing every water product in every trading zone in the Southern Connected Basin. Environmental managers will wish to move it between zones (effectively transfer allocations) much as irrigators do, and may also trade with irrigators to maximise the environmental benefits of the water available to them. This will become unmanageable if environmental rights are not held under the same water accounting / trading arrangements as other rights to water.