Submission to the 2026 Basin Plan Review

The review is a timely and important opportunity to integrate more than a decade of lived experience, knowledge and innovation to deliver a plan that is genuinely aligned with the objectives of the Water Act and the purpose of the Basin Plan.

ABOUT GREATER SHEPPARTON

C4GS writes from the perspective of a regional development organisation representing the broader economy, communities and environmental stakeholders of Greater Shepparton and the local government areas of Greater Shepparton, Moira and Campaspe.

For the purposes of this submission, we highlight the region’s significant manufacturing and value adding sector that exists because of the region’s reliable primary production that is in turn made possible by Australia’s largest man-made irrigation network.

Manufacturing in the local government areas of Greate Shepparton, Campaspe and Moira:

·         contributes more than $5.5 billion to the Australian economy,

·         provides employment for more than 6,200 local staff and

·         injects more than $500 million in wages and salaries into the local economy.

Food and grocery manufacturing makes up almost 60%, with the balance comprising a mix of allied manufacturing including metal fabrication, personal products, and packaging.

The region

·         Is home to Australia’s largest oilseed crushing facility, UHT milk processor and cut flower producer, and Australia’s only tinned tomato processors,

·         Processes approximately 30% of Australia’s milk pool and delivers 11-15% of milk into NSW and Queensland consumer markets.  

·         Is one of the largest sources of product through Australia’s busiest container port – Port of Melbourne

·         Local produced products are in the shopping trolleys of at least 70% of Australian households.

PURPOSE

C4GS recommends a stronger principles-based approach in the next Basin Plan that is genuinely aligned with the purpose of the Water Act and the Basin Plan’s vision for a healthy working Murray–Darling Basin with productive water-dependent industries and communities with confidence in their long-term future.

A purpose driven approach will -

·         Restore the status of productive industries and resilient communities as equal and core Basin outcomes, alongside and equal to the environment, and in doing so establish stronger foundations for the transparent measurement, accountability and continuous improvement in the use of water resources by all stakeholders.

·         Avoid the experience of the past decade where overly prescriptive settings locked governments and communities into outdated solutions, even when technology improved, local knowledge deepened and better alternatives became available. The MDBA’s own evaluation findings, as referenced in the Discussion Paper, state that flexible, principles-driven programs have performed better than prescriptive and complex elements of the Plan.

·         Ensure the plan has equal regard for all areas of the Basin from the Culgoa to the Coorong. C4GS supports the need to protect nationally significant downstream sites but rejects any policy framing that implicitly treats upstream ecosystems and production landscapes as sacrifice zones for downstream objectives.

·         Remove the implied equivalence between simple water volume targets and the multiple environmental, operational and community benefits delivered by SDLAM works and measures, so that well‑designed projects are properly recognised and prioritised.

PLACE

The next Basin Plan should explicitly embed place-based and community-led approaches in implementation – such as those outlined the Victorian Government’s Planning our Basin Future Together Prospectus.

The current Plan has demonstrated that many of its objectives depend on the support of landholders, communities and local institutions.

Environmental outcomes that require changed watering regimes, relaxed constraints, altered land management or access across private land will not be durable without local legitimacy and participation.

C4GS also urges the MDBA and governments to better recognise the economic contribution of irrigated agriculture pre and post the farmgate.

The MDBA Discussion Paper acknowledges that the 2025 Basin Plan Evaluation found water recovery had a relatively minor effect on the Basin-wide regional economy, while also recognising that some smaller irrigation communities have experienced real harm, including business closures, lower school enrolments and pressure on community wellbeing.

C4GS submits that Basin-wide averages are too blunt to assess impacts in highly specialised irrigation economies such as Greater Shepparton, where manufacturing, processing and export performance are closely tied to irrigation reliability and throughput.

PACE

The pace of the next Basin Plan must be balanced with the speed with which impacted regions, industries and shared networks can physically and reasonably adjust.

This is especially important for the Goulburn Murray Irrigation District channel network where modelling demonstrates that further non-strategic water buybacks could increase of fixed network costs by 10-15% for remaining water users. 

Unlike water users who pump water directly from a river, the reduction of users of a shared network means the costs are borne by a smaller number of users – and cost reductions determined by the network operator’s ability to resize the network to match the location and entitlements of remaining users.

The Commonwealth has already invested heavily in irrigation modernisation and network efficiency in northern Victoria and achieved the single largest contribution to current environmental water entitlements.

That makes it economically irrational to ignore the risk of stranded value in the very systems public policy has spent decades upgrading.

In addition to increased fixed charges, remaining water users will be competing for a smaller consumptive pool. ABARE’s analysis confirms material increases for allocation (temporary) water prices and especially in drier seasons and future drier scenarios.

Dairy Australia estimates that further water buybacks could reduce the southern Basin consumptive water pool by around 7 to 16 percent, with allocation price increases of around 17.5 to 40 percent depending on the scenario. 

Most irrigators do not own their full annual water needs and instead rely on a mix of entitlements and allocation purchases.

It is a reasonable assumption that water users will seek to limit their exposure to more volatile seasonal prices and instead purchase a greater proportion of entitlements thereby undermining the valuable contribution of water trading to water sharing within the basin.   

PERFORMANCE

The MDBA’s own initial SDL assessment states that more environmental water on its own cannot deliver all Basin Plan environmental outcomes, and identifies additional drivers of poor outcomes including floodplain disconnection, poor river connectivity, habitat condition, invasive species and water quality.

That finding should reshape the next decade of Basin policy.

Priority should be given to getting more value from the existing environmental water portfolio through better planning, clearer priorities, improved transparency, better coordination of delivery, modern infrastructure, habitat restoration, water quality interventions and practical constraints management.

This is especially important in a drying climate.

Future resilience will depend not only on entitlement volumes but on how intelligently available water is deployed across a more contested system.

C4GS recommends

·         the Sustainable Diversion Limit Adjustment Mechanism (SDLAM) offset projects that can deliver the remaining 605 GL should be ‘lifted and dropped’ into the next Basin Plan – thereby removing the need for further water buybacks, and importantly, demonstrating the supremacy of the Plan’s purpose. 

·         Perfecting the efficient and effective use of environmental water – including performance measures across a wider suite of agreed environmental health measures such as water quality, native fish outcomes and river system resilience.

PREDICTABILITY

Structural change is real, but it is not an excuse.

In barely four decades Australian agricultural industries have responded to deregulation, floating dollar, deregulation of water, energy, fertilisers and other critical inputs, technological change that has paved the way for economies of scale, farm aggregation and consolidation.

But this history should not be used to diminish the distinct effect of water policy on irrigation-dependent regions.

Regional industries have repeatedly shown they can adapt when policy provides a clear direction, a credible transition path and confidence to invest.

The transformation of modern dairy, horticulture and food manufacturing in northern Victoria shows that productivity gains, innovation, automation and product diversification are possible when settings are stable and future oriented.

What undermines adaptation is not change itself but uncertainty, policy volatility and a persistent threat of further non-strategic measures such as water buybacks.

Evidence from both irrigation and dairy stakeholders repeatedly stresses that certainty and stability are essential to long-term planning and confidence, especially given much of the readily achievable efficiency and adaptation has already been realised.

POLICY ALIGNMENT

The Australian Government has committed $3.5 million to develop Feeding Australia: A National Food Security Strategy, which is intended to set a vision for a sustainable, resilient and secure food system that serves all Australians from producers to consumers.

The National Food Council is tasked with finalizing the strategy by late 2026 – very similar timing to the MDBP review.

The Commonwealth is reviewing the Basin Plan at the same time it is developing a national food security strategy, yet the connection between the two processes remains weak – especially with the acknowledged absence of agriculture and food production in the Basin Plan discussion paper.

C4GS submits that the next Basin Plan should seek to align with the National Food Council and the National Food Security Strategy.

It is difficult to justify running one major national process focused on future availability of a critical input to food production and another focused on food system resilience without a clear bridge between them.

A stronger connection between the two would improve policy logic and give practical effect to the idea of a healthy working Basin. It would ensure water policy better reflects the role of irrigated regions in food production, processing, exports, supply chain resilience and national security.

CONCLUSION

Greater Shepparton and northern Victoria have shown they can adapt, invest and innovate.

What the region needs from the next Basin Plan is not another decade of uncertainty and non-strategic recovery, but a practical framework that respects the distinct structure of the southern irrigation system, values the full regional economy pre and post the farmgate, and works with communities to achieve durable environmental outcomes.

From the Culgoa to the Coorong, the review is an opportunity to correct a long-standing weakness in Basin policy: the failure to fully account for the industries, supply chains and communities made possible by irrigated agriculture.

A Basin Plan that genuinely embraces the idea of a healthy working Basin will be more credible, more balanced and more capable of delivering outcomes that endure.

We look forward to continuing to work with the Murray-Darling Basin Authority and Government Departments to progress this review and the future for all communities, industry and stakeholders across the Basin.