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Goulburn-Murray Water logo ABN: 46 761 336 846

Our Ref: A4006710Your Ref:

The Hon Richard Wynne MPActing Minister for Water Level 17, 8 Nicholson StreetEAST MELBOURNE VIC 3002

25 March 2021

Dear Minister

Application to Amend GMW Goulburn and Murray Bulk Entitlements

Goulburn-Murray Water (GMW) applies to you, under section 44 of the Water Act 1989, to amend the Bulk Entitlement (Eildon – Goulburn Weir) Conversion Order 1995 [‘Goulburn BE’] and the Bulk Entitlement (River Murray – Goulburn-Murray Water) Conversion Order 1999 [‘Murray BE’].

This application seeks amendment of clauses and schedules and the reduction of loss allowances for irrigation areas of the Goulburn Murray Irrigation District (GMID). The amendments are the first step in enabling the October 2021 distribution to GMID irrigators of water shares equivalent to recovery of 75 GL long-term average annual yield achieved under Stage 1 of the Connections Project. The GMID irrigators will also receive allocation defined by the applicable Goulburn and Murray systems’ seasonal determination.

The amendments comprise:

Goulburn BE:o Changes to clauses for definitions and loss allowanceso Creation of a new clause ‘Savings of Distribution Losses Associated with NVIRP’o Changes to Schedule 1, Schedule 3 and Schedule 8

Murray BE:o Implementation of the outcomes of the GMW-led review of GMID loss allowanceso Changes to clauses for definitions, bulk entitlement, the resources Victoria could divert in

the current year, making seasonal determinations, allowances for distribution losses and obligations to supply primary entitlements

o Creation of a new clause ‘Savings of Distribution Losses Associated with NVIRP’o Changes to Schedule 1, Schedule 3, Schedule 4, and Schedule 5

The Board of GMW approved the proposed amendments at Meeting 331 on 24 March 2021.

Please find enclosed the draft amendment instruments for the Goulburn BE and the Murray BE. Officers in the Department of Environment, Land, Water and Planning helped GMW prepare the draft instruments.

PO Box 165 Tatura Victoria 3616 [email protected]

1800 013 357www.gmwater.com.au

mailto:[email protected]

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Goulburn-Murray Water logo ABN: 46 761 336 846

If you require any further information about this application, please contact Dr Mark Bailey, Manager Water Resources, on 0428 377 866 or [email protected].

Yours sincerely

Charmaine QuickMANAGING DIRECTOR

cc: Grace Mitchell, Executive Director Water Resource Strategy, DELWP

encl: Draft Bulk Entitlement (Eildon – Goulburn Weir) Amendment Order 2021Draft Bulk Entitlement (River Murray – Goulburn-Murray Water) Amendment Order 2021





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Goulburn-Murray Water Logo ABN: 46 761 336 846

Our Ref: A4012314Your Ref:

The Hon Richard Wynne MPActing Minister for Water Level 17, 8 Nicholson StreetEAST MELBOURNE VIC 3002

7 April 2021

Dear Minister

Further information - Application to Amend GMW Goulburn and Murray Bulk Entitlements

I refer to my letter to you of 25 March 2021 regarding Goulburn-Murray Water’s (GMW) application to amend the Bulk Entitlement (Eildon – Goulburn Weir) Conversion Order 1995 [‘Goulburn BE’] and the Bulk Entitlement (River Murray – Goulburn-Murray Water) Conversion Order 1999 [‘Murray BE’] and note the additional information provided below to support this application.

This application should have included a reference to the further 2 GL long-term average annual yield from the Connections Project to be distributed to eligible delivery share-holders. This additional water was provided for in the draft amendments sent to you previously.

These draft amendments also included the outcomes from the GMW review of the Murray Valley and Torrumbarry losses. Please find attached the detailed submission as per the requirements of the Murray BE.

I am also resubmitting a copy of the draft amendments which have been reviewed and updated to include typographical changes. These do not affect the intent of the original amendments approved by the Board of GMW at Meeting 331 on 24 March 2021.

Please find enclosed the updated draft amendment orders for the Goulburn BE and the Murray BE. Officers in the Department of Environment, Land, Water and Planning helped GMW prepare the draft instruments.

If you require any further information about this application, please contact Dr Mark Bailey, Manager Water Resources, on 0428 377 866 or [email protected].

Yours sincerely

Charmaine Quick





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MANAGING DIRECTOR

cc: Grace Mitchell, Executive Director Water Resource Strategy, DELWP

encl: Draft Bulk Entitlement (Eildon – Goulburn Weir) Amendment Order 2021Draft Bulk Entitlement (River Murray – Goulburn-Murray Water) Amendment Order 2021Technical paper – Torrumbarry and Murray Valley loss allowance review

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WATER ACT 1989

BULK ENTITLEMENT (EILDON-GOULBURN WEIR) FURTHER AMENDMENT ORDER 2021

I, Richard Wynne MP, Acting Minister for Water, and the acting Minister administering the Water Act 1989 make the following Order -

CITATION

1. This Order may cited as the Bulk Entitlement (Eildon-Goulburn Weir) Further Amendment Order 2021.

EMPOWERING PROVISION

2. This Order is made under section 44 of the Water Act 1989.COMMENCEMENT

3. This Order comes into operation on the date it is published in the Victoria Government Gazette.DEFINITIONS

4. In this Order:“Act” means the Water Act 1989;

“Bulk Entitlement Order” means the Bulk Entitlement (Eildon-Goulburn Weir) Conversion Order 1995;

“this Order” means this Bulk Entitlement (Eildon-Goulburn Weir) Further Amendment Order 2021.

AMENDMENTS TO THE BULK ENTITLEMENT ORDER

5. I amend the Bulk Entitlement Order as follows:

Amendments to Definitions in Clause 4

6. In the definitions in clause 4 of the Bulk Entitlement Order:(a) after the definition of “cap model” insert:

“ “Census Date” means the date determined by the Deputy Secretary, Water and Catchments, Department of Environment, Land, Water and Planning in October 2021 for the purpose of determining an Eligible Delivery Share Holder;” and

(b) after the definition of “dead storage” insert:“ “delivery share” means the right to the service of having water delivered under section 222(1)(a) of the Act;” and

(c) after the definition of “distribution loss” insert:“ “Eligible Delivery Share Holder” means the owner or occupier of a serviced property in one of the gravity fed irrigation districts of the GMID who holds a delivery share on the Census Date and who is charged an infrastructure access fee;” and

(d) after the definition of “entitlement holder” insert:“ “GL” means gigalitres. 1 GL equals 1000 megalitres;” and

(e) after the definition of “Goulburn Component of GMID” insert:“ “Goulburn Irrigators’ Share” means the Trading Zone 1A (Greater Goulburn) and Trading Zone 1B (Boort) Goulburn portion of the volume of long-term water recovery

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from NVIRP Stage 1 that is to be converted to water shares for the benefit of Eligible Delivery Share Holders based on the overall distribution of delivery shares in the gravity fed irrigation district of the GMID and those for Trading Zone 1A (Greater Goulburn) and Trading Zone 1B (Boort);

“Goulburn Irrigators’ Share Account” means the account administered by the Authority appointed under section 64GA of the Act in accordance with clause 6 of Schedule 3 that records the volume of water that would have been allocated if the water shares associated with the Goulburn Irrigators’ Share were issued on 1 July 2021;

“Goulburn Lower Broken Creek Irrigators’ Share Account” means the account administered by the Authority appointed under section 64GA of the Act in accordance with clause 7 of Schedule 3 that records the volume of water that would have been allocated if the water shares associated with the Lower Broken Creek Irrigators’ Share were issued on 1 July 2021;” and

(f) after the definition of “Goulburn Offset Account” insert: “ “Goulburn Offset Distribution Account” means the account administered by Goulburn-Murray Water that records the volume of water from the Goulburn Offset Account once Goulburn-Murray Water has determined in accordance with clause 5 of Schedule 3 that the water in the Goulburn Offset Account is surplus to needs” and

(g) after the definition of “high reliability entitlements” insert:“ “infrastructure access fee” means the fee that is based on the amount of ML per day of delivery share held by a person to recover most of the cost for operating, maintaining and renewing the delivery network within each irrigation district;

“irrigators’ share” means the 75 GL of long-term average annual yield water recovery achieved by NVIRP Stage 1, plus any additional water recovery determined by the Minister for Water, to be converted to water shares for the benefit of Eligible Delivery Share Holders;” and

(h) after the definition of “Loddon System” insert:“ “Lower Broken Creek Additional Entitlements” means the water shares issued in Trading Zone 6B (Lower Broken Creek) as a result of the distribution of the irrigators’ share;

“Lower Broken Creek Entitlements” means all water shares and bulk entitlements held in trading Zone 6B (Lower Broken Creek) excluding the Lower Broken Creek Additional Entitlements;

“Lower Broken Creek Irrigators’ Share” means the trading Zone 6B (Lower Broken Creek) portion of the volume of the long-term water recovery from NVIRP Stage 1 that is to be converted to water shares for the benefit of Eligible Delivery Share Holders based on the overall distribution of delivery shares in the gravity fed irrigation districts of the GMID and those for Trading Zone 6B (Lower Broken Creek);” and

(i) after the definition of “Mitigation Water Operating Arrangements” insert:“ “ ML” means megalitre. 1 ML equals a million litres;” and

(j) for the definition of “NVIRP” substitute:“ “NVIRP” means the Northern Victoria Irrigation Renewal Project, also known as the Connections Project, which was a major irrigation modernisation project aiming to generate long-term annual average water savings of 429 GL by upgrading irrigation

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infrastructure in the GMID. NVIRP was divided into two stages referred to as NVIRP Stage 1 and NVIRP Stage 2;” and

(k) after the definition of “useful inflow” insert:“ “Victorian Water Register” has the same meaning as “water register” in the Act;”.

Amendment to Clause 7A

7. Clause 7A.5 of the Bulk Entitlement Order is revoked.Insertion of New Clause 7B

8. After clause 7A.4 of the Bulk Entitlement Order, insert new clause 7B:“7B SAVINGS OF DISRIBUTION LOSSES ASSOCIATED WITH NVIRP

7B.1 Where modernisation savings are achieved as a result of NVIRP, the Authority must follow the procedure detailed in clause 5 of Schedule 3 for estimating, accounting, reserving and allocating these modernisation savings.

7B.2 Until the full volume of the Goulburn Irrigators’ Share Account has been converted to water shares, the Authority appointed under section 64 GA of the Act must follow the procedure detailed in clause 6 of Schedule 3 for estimating, accounting, reserving and deducting water in the Goulburn Irrigators’ Share Account.

7B.3 Until the full volume of the Goulburn Lower Broken Creek Irrigators’ Share Account has been converted to water shares, the Authority appointed under section 64 GA of the Act must follow the procedure detailed in clause 7 of Schedule 3 for estimating, accounting, reserving and deducting water in the Lower Broken Creek Irrigators’ Share Account.”.

Amendments to Schedule 1

9. In Schedule 1 to the Bulk Entitlement Order –

(a) substitute Table 3:“Table 3 Entitlements originally issued in respect of the Goulburn System which have been cancelled and issued in respect of another system Bulk obligation to supply other water systems, arising from legacy exchange rate trade

Bulk obligation to supply other water systems, arising from legacy exchange rate trade

From Zone 1A to Victorian Murray (zone 7)

84,110.0

From Zone 1A to South Australia 11,063.0

From Zone 3 to Victorian Murray (zone 7) 4,212.0

From Zone 3 to South Australia 103.0

These volumes can change as a result of trade. The information in this Table is current as of 1 January 2021 and does not take into account any trade of water shares that may have occurred after this date. Up to date records of the obligation to supply other systems from the Goulburn System are maintained by the Authority and are updated in this Schedule from time to time.”

(b) For Table 5 substitute –

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Table 5: Distribution loss provision compared to delivery volume within the Goulburn Component of GMID

Irrigation Area Type Loss Provision (GL), for allocation in line with maximum deliverable volume during the season

Shepparton (zone 1A)

Delivery: 0.000 17.591 35.182 61.569 87.956 123.138 175.911 211.094 255.072 316.641 351.823

Loss: 19.358 22.112 24.865 28.995 33.124 38.631 46.890 52.397 59.280 68.916 74.422

Central Goulburn

(zone 1A)

Delivery: 0.000 37.300 74.600 130.550 186.500 261.100 373.001 447.601 540.851 671.401 746.001

Loss: 28.992 32.570 36.149 41.516 46.883 54.040 64.775 71.931 80.877 93.401 100.558

Rochester & Loddon Valley (zone 1A & 1B)

Delivery: 0.000 39.717 79.434 139.009 198.584 278.018 397.169 476.603 575.895 714.904 794.338

Loss: 35.121 38.043 40.965 45.348 49.731 55.575 64.341 70.185 77.490 87.717 93.561

Loss Provision (GL) 83.471 92.725 101.978 115.859 129.739 148.246 176.006 194.513 217.647 250.034 268.541

Total Diversion (delivery plus loss in GL)

83.471 187.333 291.195 446.987 602.779 810.502 1,122.087 1,329.810 1,589.464 1,952.980 2,160.703

Note: loss provisions may be allocated at different delivery volumes than shown in Table 5 by linear interpolation or extrapolation.

(c) For Table 6 substitute - Table 6: Annual and Cumulative headroom allowances (GL)

Irrigation Area Fixed Loss Annual HeadroomCumulative Headroom

Shepparton (zone 1A) 19.358 3.872 15.367

Central Goulburn (zone 1A) 28.992 5.798 24.274

Rochester & Loddon Valley (zone 1A & 1B) 35.121 7.024 28.183

Total Goulburn Component of GMID 83.471 16.694 67.823

Amendments to Schedule 3

10. In Schedule 3 to the Bulk Entitlement Order:

(a) for item Number 1 substitute: “

1 Goulburn-Murray Rural Water Corporation

- Lower Broken Creek System – Lower Broken Creek Entitlements

Supplementary supplies from the Goulburn system via the Shepparton Irrigation Area up to 40,000 ML each year (during the irrigation season) to meet the Lower Broken Creek Entitlements.The supplementary supply volume varies with the Goulburn seasonal determination. The Bulk Entitlement (River Murray – Goulburn Murray Water) Conversion Order 1999 must supply up to 40,000 ML to meet any shortfall in supply when the Goulburn seasonal determination is lower than the River Murray seasonal determination.

”; and

(b) after item 1 insert new item 1a:“

1a Goulburn-Murray A supply from the Goulburn System via the Shepparton Irrigation

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Rural Water Corporation

- Lower Broken Creek System – Lower Broken Creek Additional Entitlements

Area of up to 1,021 ML each year, aligned to seasonal determinations in the Goulburn system, to meet the high-reliability water share component of the Lower Broken Creek Additional Entitlement. The Bulk Entitlement (River Murray – Goulburn Murray Water) Conversion Order 1999 must supply up to 1,021 ML to meet any shortfall in supply when the Goulburn seasonal determination is lower than the River Murray seasonal determination.

”; and

(c) for item 5 substitute:“

5 Goulburn-Murray Rural Water Corporation - NVIRP Stage 1 and NVIRP Stage 2 gross modernisation savings

5. Procedure for estimating, accounting, reserving and allocating gross modernisation savings as a result of NVIRP.

Each year until the completion of NVIRP and all resulting gross modernisation savings have been converted to new entitlements, Goulburn-Murray Water must:

5.1 On 30 June, carry over all of the unused volume in the Modernisation Savings Account into the next year.

5.2 Estimate the total volume of gross modernisation savings to be achieved from NVIRP Stage 1 and NVIRP Stage 2 during the year that have not been issued as entitlement to a beneficiary of the project in accordance with the Protocol.

5.3 Adjust the volume in the Modernisation Savings Account during the year as necessary based on revised estimates of gross modernisation savings to be achieved in the current year.

5.4 If mitigation water is available in accordance with the approved Mitigation Water Operating Arrangements, the mitigation water must be allocated from the Modernisation Savings Account to the Environmental Entitlement (Goulburn System – NVIRP Stage 1) 2012.

5.5. Once the Audit is published, make any final adjustment to the volume in the Modernisation Savings Account required and then deduct from the volume in the Modernisation Savings Account the total volume of audited savings from the previous year and allocate it as follows:

i. a one-third share of the total audited phase 3 water savings attributed to NVIRP Stage 1 to the Melbourne Bulk Entitlements collectively; and

ii. a one-third share of the total audited phase 3 water savings attributed to NVIRP Stage 1 to the Goulburn Offset Account until June 2022.

5.6 Deduct from the Goulburn Offset Account, as required during the year whenever a seasonal determination is made, the equivalent volume of water that was allocated in the current year to any water shares issued to the CEWH from

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NVIRP Stage 2 in the Goulburn system.

5.7 Determine when the impacts associated with the issue of water shares in the Goulburn and Murray systems to the CEWH from NVIRP Stage 2 have been fully mitigated, then inform the Executive Director, Water Resource Strategy , Department of Environment , Land, Water and Planning, of the volume of surplus water remaining in the Goulburn Offset Account.

5.8 Allocate the volume determined in sub-clause 5.7 of this Schedule to the Goulburn Offset Distribution Account.

5.9 On 30 June, carry over any unused water in the Goulburn Offset Account, minus 5% for evaporative losses unless, as a result of sub-clause 5.6 of this Schedule, the balance in the account is negative.

5.10 Report to the Executive Director, Water Resource Strategy, Department of Environment, Land, Water and Planning, the accounting method and volumes of water reserved and allocated under clause 5 of this Schedule by 1 April each year, or within 14 days of a request by the Executive Director.

”; and

(d) after item 5 insert new items 6 and 7:“

6 Goulburn-Murray Rural Water Corporation Goulburn Irrigators’ Share Account

6. Procedure for estimating, accounting, reserving and deducting water from the Goulburn Irrigators’ Share Account

6.1. Until the full volume of the Goulburn Irrigators’ Share has been issued as to water share, the Authority appointed under section 64 GA of the Act must:

A. On 1 July and for each subsequent seasonal determination in the year as required, i. determine the total volume of high-reliability and

low-reliability water shares associated with the Goulburn Irrigators’ Share that have not yet been issued; and

ii. reserve in the Goulburn Irrigators’ Share Account water equal to the percentage determined under section 64GB(8) of the Act for the seasonal determination of the volume determined in sub-paragraph A(i) of sub-clause 6.1 of this Schedule for high-reliability and low-reliability water shares at that time.

B. Upon the issue of water shares to Eligible Delivery Share Holders, make an adjustment to the volume in the Goulburn Irrigators’ Share Account by deducting from the account the volume equivalent to the percentage,

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determined under section 64GB(8) of the Act, of the maximum volume of high-reliability and or low-reliability water shares.

C. Upon the issue of a water share associated with the Murray Irrigators’ Share, allocate to that share the corresponding volume of water that was deducted from the Goulburn Irrigators’ Share Account in paragraph B of sub-clause 6.1 of this Schedule in proportion to the volume of the share.

6.2. Any water remaining in the Goulburn Irrigators’ Share Account at the end of the year cannot be carried over.

6.3. At the end of the 2022-23 year if there is water remaining in the Goulburn Irrigators’ Share Account which represents water not issued to an Eligible Delivery Share Holder then Goulburn-Murray Water may apply to the Minister for Water to convert the remaining volume to water shares held by Goulburn-Murray Water.

7 Goulburn-Murray Rural Water Corporation Goulburn Lower Broken Creek Irrigators’ Share Account

7. Procedure for estimating, accounting, reserving and deducting water from the Goulburn Lower Broken Creek Irrigators’ Share Account

7.1 Until the full volume of the Lower Broken Creek Irrigators’ Share has been converted to water shares, the Authority appointed under section 64 GA of the Act must:A. On 1 July and for each subsequent seasonal

determination in the year as required, i. determine the volume of high-reliability water

shares associated with the Lower Broken Creek Irrigators’ Share that that has not yet been issued; and

ii. reserve in the Goulburn Lower Broken Creek Irrigators’ Share Account a volume of water equal to the percentage determined under section 64GB(8) of the Act for the seasonal determinations determined in sub-paragraph A(i) of sub-clause 7.1 of this Schedule for high-reliability water shares at that time.

B. Upon the issue of water shares associated with the Lower Broken Creek Irrigators’ Share make an adjustment to the volume in the Goulburn Lower Broken Creek Irrigators’ Share Account by deducting from the account the volume equivalent to the percentage, determined under section 64GB(8) of the Act, of the maximum volume of high-reliability water shares.

C. Upon the issue of a water share associated with the Lower Broken Creek Irrigators’ Share Account allocate to that share the corresponding volume of water that was deducted from the Goulburn Lower Broken Creek

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Irrigators’ Share Account in paragraph B of sub-clause 7.1 of this Schedule.

7.2 Any water remaining unissued water in the Goulburn Lower Broken Creek Irrigators’ Share Account at the end of the water year cannot be carried over.

7.3 At the end of the 2022-23 year if there is water remaining in the Goulburn Lower Broken Creek Irrigators’ Share Account which represents water not issued to an Eligible Delivery Share Holder then Goulburn-Murray Water may apply to the Minister for Water to convert the remaining volume to water shares held by Goulburn-Murray Water.

”.

Amendment to Schedule 8

11. In Schedule 8 of the Bulk Entitlement Order, in B:

(a) after the words “Lake Eildon and Goulburn Weir for” insert the word “the”; and

(b) after the words “allocation assessment date if” insert the words “seasonal determinations are”.

HON RICHARD WYNNE MPActing Minister for Water

/ / 2021.

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WATER ACT 1989

BULK ENTITLEMENT (RIVER MURRAY - GOULBURN -MURRAY WATER) AMENDMENT ORDER 2021

I, Richard Wynne MP, Acting Minister for Water, and as the acting Minister administering the Water Act 1989 make the following Order –

CITATION

1. This Order may cited as the Bulk Entitlement (River Murray – Goulburn-Murray Water) Amendment Order 2021.

EMPOWERING PROVISION

2. This Order is made under section 44 of the Water Act 1989.

COMMENCEMENT

3. This Order comes into operation on the date it is published in the Victoria Government Gazette.

DEFINITIONS

4. In this Order:

“Act” means the Water Act 1989;

“Bulk Entitlement Order” means the Bulk Entitlement (River Murray – Goulburn-Murray Water) Conversion Order 1999;

“this Order” means this Bulk Entitlement (River Murray – Goulburn-Murray Water) Amendment Order 2021.

AMENDMENTS TO THE BULK ENTITLEMENT ORDER

5. I amend the Bulk Entitlement Order as follows:

Amendments to Definitions in Clause 4

6. In the definitions in clause 4 of the Bulk Entitlement Order:

(l) after the definition of “cap model” insert:“ “Census Date” means the date determined by the Deputy Secretary, Water and Catchments, Department of Environment, Land, Water and Planning in October 2021 for the purpose of determining an Eligible Delivery Share Holder;”

“delivery share” means the right to the service of having water delivered under section 222(1)(a) of the Act, at specified volumes during specified periods as determined under section 223 of the Act;” and

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(m) after the definition of “Doctor’s Point” insert:“ “Eligible Delivery Share Holder” means the owner or occupier of a serviced property in one of the irrigation districts of the GMID who holds a delivery share on the Census Date and who is charged an infrastructure access fee;” and

(n) after the definition of “Goulburn-Murray Water” insert:“GMID” means the Goulburn Murray Irrigation District;” and

(o) after the definition of “high reliability entitlements” insert:“ “infrastructure access fee” means the fee that is based on the amount of ML per day of delivery share held by a person to recover most of the cost for operating, maintaining and renewing the delivery network within each irrigation district;

“irrigators’ share” means the 75 GL of long-term average annual yield water recovery achieved by NVIRP Stage 1, plus any additional water recovery determined by the Minister for Water, to be converted for the benefit of Eligible Delivery Share Holders;” and

(p) after the definition of “licence” insert:“ “Lower Broken Creek Additional Entitlements” means the water shares issued in Trading Zone 6B (Lower Broken Creek) as a result of the distribution of the irrigators’ share;

“Lower Broken Creek Entitlements” means all water shares and bulk entitlements held in Trading Zone 6B (Lower Broken Creek) excluding the Lower Broken Creek Additional Entitlements;

“Lower Broken Creek Irrigators’ Share” means the portion of the irrigators’ share to be determined by the Minister and to be distributed in Trading Zone 6B (Lower Broken Creek;

(q) after the definition of “modernisation works” insert:

“ “Murray Irrigators’ Share” means the portion of the irrigators’ share to be determined by the Minister and to be distributed in Trading Zone 6 (VIC Murray – Dartmouth to Barmah) and Trading Zone 7 (VIC Murray – Barmah to SA);

“Murray Irrigators’ Share Account” means the account administered by the Authority appointed under section 64 GA of the Act in accordance with clause 5 of Schedule 5 that records the volume of water that would have been allocated if the water shares associated with the Murray Irrigators’ Share were issued on 1 July 2021;

“Murray Lower Broken Creek Irrigators’ Share Account” means the account administered by the Authority appointed under section 64 GA of the Act in accordance with clause 6 of Schedule 5 that records the volume of water that would have been allocated if the water shares associated with the Lower Broken Creek Irrigators’ Share were issued on 1 July 2021;” and

(r) after the definition of “Murray Offset Account” insert:“Murray Offset Distribution Account” means the account administered by Goulburn-

Murray Water that records the volume of water from the Murray Offset Account once Goulburn-Murray Water has determined in accordance with clause 4 of Schedule 5 that the water in the account is surplus to needs;” and

(s) for the definition of “NVIRP” substitute:

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“ “NVIRP” means the Northern Victoria Irrigation Renewal Project, also known as the Connections Project, which was a major irrigation modernisation project aiming to generate long-term annual average water savings of 429 GL by upgrading irrigation infrastructure in the GMID. NVIRP was divided into two stages referred to as NVIRP Stage 1 and NVIRP Stage 2;”

(t) after the definition of “Victoria’s River Murray Water Accounts” insert:“ “Victorian Water Register” has the same meaning given to “water register” in section

3(1) of the Act;” and

(u) in the definition of “Water Holder” for “act” substitute “Act”.Amendment to clause 6 of the Bulk Entitlement Order

7. For clause 6.1 (d) of the Bulk Entitlement Order substitute:

“(d) up to 40 GL to cover any shortfall in supply from the Goulburn system to the Lower Broken Creek Entitlements and up to 1,021 ML to cover any shortfall in supply from the Goulburn system to the high-reliability Lower Broken Creek Additional Entitlements when Goulburn seasonal determinations are lower than River Murray seasonal determinations. ”

8. After clause 6.1(d) of the Bulk Entitlement Order insert:

“(e) up to 610 ML to the low-reliability component of the Lower Broken Creek Additional Entitlements.”.

Amendment to clause 8 of the Bulk Entitlement Order

9. For clause 8.1(c)(ii) and clause 8.1(c)(iii) substitute:

“(ii) up to 40 GL to cover the shortfall in supply from the Goulburn system to the Lower Broken Creek Entitlements and up to 1,021 ML to cover any shortfall in supply from the Goulburn system to the high-reliability Lower Broken Creek Additional Entitlements when Goulburn seasonal determinations are lower than River Murray seasonal determinations;

(iii) any water carried over from the previous year by persons holding an entitlement specified in clause 15; and”.

10. After clause 8.1(c)(iii) insert:

“(iv) up to 610 ML for the low-reliability component of the Lower Broken Creek Additional Entitlements;”.

Amendments to clause 12 of the Bulk Entitlement Order

11. (1) For clause 12(d) in the Bulk Entitlement Order substitute;

“(d) must subtract the following not covered in Schedule 1:

(i) any gross modernisation savings reserved in accordance with clause 4 of Schedule 5;

(ii) any water that is reserved in the Murray Irrigators’ Share Account in accordance with clause 5 of Schedule 5; and

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(iii) any water that is reserved in the Murray Lower Broken Creek Irrigators’ Share Account in accordance with clause 6 of Schedule 5;” and

(2) For paragraph (h)(iii) substitute:

“(iii) supply to the Lower Broken Creek Entitlements and the Lower Broken Creek Additional Entitlements;”.

Amendments to clause 13 of the Bulk Entitlement Order

12. (1) Clause 13.1 is revoked.

(2) In clause 13.2(a) for sub-paragraphs (i) and (ii) substitute:

“(i) for Murray Valley, 15% of the allowance in Schedule 1 corresponding to the final seasonal determination for that year;

(ii) for Torrumbarry, 15% of the allowance in Schedule 1 corresponding to the final seasonal determination for that year;”.

(3) In clause 13.2(c) for sub-paragraph (ii) substitute:

“(ii) for Torrumbarry, 100 GL;”.

(4) For clause 13.3 substitute:

“13.3 Goulburn-Murray Water in conjunction with other River Murray entitlement holders must review the provisions of this clause five years after the distribution of all entitlements from NVIRP. This review should include a review of the Victorian Mid-Murray Storage losses.”.

(5) After clause 13.3 insert

13.4 In any year where Goulburn-Murray Water has identified that losses in Schedule 1 and sub-clause 13.2 are insufficient to meet all the loss requirements then Goulburn-Murray Water may request a temporary variation to sub-clause 13.2 from the Minister after informing holders of River Murray bulk entitlement.”.


13. For clause 15.4 substitute:

“15.4 For the purposes of clause 15.1 water taken under this bulk entitlement for the purpose of supplying a primary entitlement includes water made available from water savings and which is supplied or used in accordance with clauses 18 and 18A.”.


14. In clause 18.1(b) for “act” substitute “Act”;

15. For clause 18.1(c) substitute:

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“(c) Goulburn-Murray Water may issue water shares under section 33F of the Act if the Authority has been appointed a delegate of the Minister for that purpose and in each case the transfer or conversion must be in accordance with the provisions of this clause and clause 18A.”.

16. For clause 18.10 substitute:“18.10 Where the savings are achieved as a result of NVIRP the provisions of clause 18A

apply.”.

Insertion of new clause 18A in the Bulk Entitlement Order

17. After clause 18 insert:

“18A. SAVINGS OF DISTRIBUTION LOSSES ASSOCIATED WITH NVIRP

18A.1 Where modernisation savings are achieved as a result of NVIRP, Goulburn-Murray Water must follow the procedure detailed in clause 4 of Schedule 5 for estimating, accounting, reserving and allocating these modernisation savings.

18A.2 Until the full volume of the Murray Irrigators’ Share has been converted to water shares, the Authority appointed under section 64GA of the Act must follow the procedure detailed in clause 5 of Schedule 5 for estimating, accounting, reserving and deducting water in the Murray Irrigators’ Share Account.

18A.3 Until the full volume of the Murray Lower Broken Creek Irrigators’ Share has been converted to water shares, the Authority appointed under section 64GA of the Act must follow the procedure detailed in clause 6 of Schedule 5 for estimating, accounting, reserving and deducting water in the Murray Lower Broken Creek Irrigators’ Share Account.”.

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Amendments to Schedule 1 to the Bulk Entitlement Order

18. For Table 1 in Schedule 1 substitute:

Table 1: High-reliability Entitlements (GL)

User group High Reliability Entitlements (GL)

Off-take commitments for high-reliability seasonal determinations of Historic at farm for

allowed loss10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Goulburn-Murray Water

Murray Valley151.077 At farm 15.108 30.215 45.323 60.431 75.539 90.646 105.754 120.862 135.970 151.077 246.072

Losses 28.184 30.050 31.916 33.781 35.647 37.513 39.379 41.245 43.111 44.977 56.710 43.291 60.265 77.239 94.212 111.186 128.160 145.133 162.107 179.081 196.054 302.782

Torrumbarry229.498 At farm 22.950 45.900 68.849 91.799 114.749 137.699 160.649 183.599 206.548 229.498 357.427

Losses 41.498 43.332 45.167 47.001 48.835 50.670 52.504 54.338 56.172 58.007 68.232 64.448 89.232 114.016 138.800 163.584 188.368 213.153 237.937 262.721 287.505 425.659

Nyah8.247 At farm 0.825 1.649 2.474 3.299 4.124 4.948 5.773 6.598 7.422 8.247

Losses 0.500 0.500 0.500 0.500 0.500 0.500 0.500 0.500 0.500 0.500 1.325 2.149 2.974 3.799 4.624 5.448 6.273 7.098 7.922 8.747

Diverters, Dartmouth-Nyah 54.992 5.499 10.998 16.498 21.997 27.496 32.995 38.494 43.993 49.493 54.992

Not associated with land

452.411 45.241 90.482 135.723 180.964 226.206 271.447 316.688 361.929 407.170 452.411

LMURW - Irrigation

Irrigation districts

125.635 At farm 12.564 25.127 37.691 50.254 62.818 75.381 87.945 100.508 113.072 125.635 Losses 12.234 12.234 12.234 12.234 12.234 12.234 12.234 12.234 12.234 12.234 24.798 37.361 49.925 62.488 75.052 87.615 100.179 112.742 125.306 137.869

Millewa & Yelta0.714 At farm 0.071 0.143 0.214 0.286 0.357 0.428 0.500 0.571 0.643 0.714

Losses 4.800 4.800 4.800 4.800 4.800 4.800 4.800 4.800 4.800 4.800 4.871 4.943 5.014 5.086 5.157 5.228 5.300 5.371 5.443 5.514

Diverters, Nyah-S.A.

202.380 20.238 40.476 60.714 80.952 101.190 121.428 141.666 161.904 182.142 202.380


0.852 0.085 0.170 0.256 0.341 0.426 0.511 0.596 0.682 0.767 0.852

Other 0.535 0.054 0.107 0.161 0.214 0.268 0.321 0.375 0.428 0.482 0.535 Grampians Wimmera Mallee Water 3.492 0.349 0.698 1.048 1.397 1.746 2.095 2.444 2.794 3.143 3.492

LMURW - Urban 30.971 3.097 6.194 9.291 12.388 15.485 18.583 21.680 24.777 27.874 30.971

Coliban Water 5.055 River 0.506 1.011 1.517 2.022 2.528 3.033 3.539 4.044 4.550 5.055 1.230 Channel 0.123 0.246 0.369 0.492 0.615 0.738 0.861 0.984 1.107 1.230

Goulburn Valley Water 3.607 River 0.361 0.721 1.082 1.443 1.804 2.164 2.525 2.886 3.246 3.607

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0.128 Channel 0.013 0.026 0.038 0.051 0.064 0.077 0.090 0.102 0.115 0.128 North East Water 13.236 River 1.324 2.647 3.971 5.294 6.618 7.941 9.265 10.588 11.912 13.236

Water Holder

Flora & Fauna 29.609 River 2.961 5.922 8.883 11.844 14.804 17.765 20.726 23.687 26.648 29.609 Snowy EWR 29.794 River 2.979 5.959 8.938 11.918 14.897 17.876 20.856 23.835 26.815 29.794

Living Murray 9.589 River 0.959 1.918 2.877 3.836 4.795 5.753 6.712 7.671 8.630 9.589 Exchange rate trade

South Australia 17.519 SA border 1.752 3.504 5.256 7.008 8.760 10.511 12.263 14.015 15.767 17.519 NSW 5.075 L Hume 0.508 1.015 1.523 2.030 2.538 3.045 3.553 4.060 4.568 5.075

Total 1,375.646 224.780 366.045 507.310 648.575 789.840 931.104 1,072.369 1,213.634 1,354.899 1,496.164

19. For Table 2 in Schedule 1 substitute:

Table 2: Low-reliability Entitlements (GL)

User group Low Reliability Entitlements (GL)

Off-take commitments for low reliability seasonal determinations of Historic at farm for allowed

loss10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Goulburn-Murray

Water

Murray Valley 91.446 At farm 9.145 18.289 27.434 36.578 45.723 54.867 64.012 73.157 82.301 91.446 111.599

Losses 1.129 2.259 3.388 4.518 5.647 6.777 7.906 9.035 10.165 11.294 13.783

10.274 20.548 30.822 41.096 51.370 61.644 71.918 82.192 92.466 102.740 125.382Torrumbarry 124.091 At farm 12.409 24.818 37.227 49.637 62.046 74.455 86.864 99.273 111.682 124.091 157.206

Losses 0.992 1.984 2.975 3.967 4.959 5.951 6.943 7.935 8.926 9.918 12.565

13.401 26.802 40.203 53.604 67.005 80.406 93.807 107.208 120.609 134.010 169.771Murray

diverters 12.029 1.203 2.406 3.609 4.812 6.014 7.217 8.420 9.623 10.826 12.029

Mitta diverters 4.505 0.451 0.901 1.352 1.802 2.253 2.703 3.154 3.604 4.055 4.505

1.653 3.307 4.960 6.614 8.267 9.920 11.574 13.227 14.881 16.534 Not

associated with land

60.948

6.095 12.190 18.284 24.379 30.474 36.569 42.663 48.758 54.853 60.948

Lower Murray Water

Irrigation districts 0.402 0.040 0.080 0.121 0.161 0.201 0.241 0.281 0.322 0.362 0.402

Diverters, Nyah-S.A. 6.675 0.668 1.335 2.003 2.670 3.338 4.005 4.673 5.340 6.008 6.675


0.000

0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Water Holder

Living Murray 98.835 9.884 19.767 29.651 39.534 49.418 59.301 69.185 79.068 88.952 98.835 Flora & Fauna 3.816 0.382 0.763 1.145 1.527 1.908 2.290 2.671 3.053 3.435 3.816

Total 402.747 42.396 84.792 127.188 169.584 211.980 254.376 296.772 339.168 381.564 423.960

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Off-take commitments for 100% high reliability entitlements

from Table 1 224.780 366.045 507.310 648.575 789.840 931.104 1,072.369 1,213.634 1,354.899 1,496.164

Total off-take commitments 267.176 450.837 634.498 818.159 1,001.819 1,185.480 1,369.141 1,552.802 1,736.462 1,920.123

Notes on Tables 1 and 2:1.2. Seasonal determinations may be made in intervals of 1% by interpolation between the values shown or extrapolation below 10% (or above 100% for the losses), not just in the 10% intervals shown.

3.4. Murray Valley and Torrumbarry have fixed losses of 26.318 GL and 39.664 GL (including 0.352 GL for Tresco) respectively, plus two variable loss components (corresponding to historic at farm volumes from 2007 when unbundling occurred):

(a) for high-reliability rights, variable loss varies from zero at zero allocation, increasing linearly to 30.392 GL for Murray Valley at historic (2007) at farm deliveries of 246.072 GL and to 28.568 GL for Torrumbarry at historic (2007) at farm deliveries of 357.427 GL.

(b) for low-reliability rights, variable loss varies from zero at zero low allocation, increasing linearly to 13.783 GL for Murray Valley at historic (2007) at farm deliveries of 111.599 GL and to 12.565 GL for Torrumbarry at historic (2007) at farm deliveries of 157.206 GL; and these losses may be allocated as required to deliver water carried over in these irrigation areas based on the equivalent maximum allocation in each area (calculated as the seasonal determination + carryover).

5.6. Allocations against the 22.1 GL of high-reliability entitlement added to Table 1 in November 2009 for Snowy EWR commenced when the Lake Boga-Lake Kangaroo-Lake Charm component of the Victorian Mid-Murray Storages was first deemed by the Resource Manager to have been operated in accordance with clause 8A (which occurred on 1 April 2010).

7.8. Lower Broken Creek Entitlements and Lower Broken Creek Additional Entitlements are generally supplied from the Goulburn System, including town supplies for Numurkah and Nathalia and relevant environmental entitlements, hence are not included in Tables 1 and 2, but receive Murray allocation regardless of whether they are supplied from the Murray or Goulburn System.

9. The allocation to the Murray Valley and Torrumbarry losses shown may be increased up to the maximum accumulated unused loss volume available for each in order to allow for delivery of allocation carried over in these districts from the previous year.

10. These tables do not show changes in water share volumes as a result of trade since 6 March 2015, or entitlements to unregulated flows in the River Murray or River Murray Increased Flows.

11. LMWURW Irrigation Districts volume includes high-reliability and supply by agreement entitlements in Table 1. ”

12.

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Amendments to Schedule 3 to the Bulk Entitlement Order

20. In clause 3 of Schedule 3 to the Bulk Entitlement Order in the second line for “paragraph” substitute “clause”; and

21. In the First Year Assessment – from current month to end of May of Schedule 3 to the Bulk Entitlement Order after the second dot point in L insert:

“ supplement to the Lower Broken Creek Entitlements (clause 8.1(c)(ii));

Lower Broken Creek Additional Entitlements (clause 8.1(c)(iii)).”.

Amendment to Schedule 4 to the Bulk Entitlement Order

22. In Schedule 4 to the Bulk Entitlement Order in the table headed “Return Points” in the Comment column for the Torrumbarry returns substitute:

“Calculation of Torrumbarry returns involves complex water accounting rules agreed with the MDBA. These rules are recorded in the Diversions Formula Register for the Murray Darling Basin which is established under paragraph 4(1)(b) to Schedule E of the Agreement.”.

Substitution of Schedule 5 to the Bulk Entitlement Order

23. For Schedule 5 to the Bulk Entitlement Order substitute:

“SCHEDULE 5: Goulburn-Murray Water River Murray Entitlements

1. Goulburn-Murray Water Primary Entitlements

Table 1 - Goulburn-Murray Water Primary Entitlements (except Lower Broken Creek)

DESCRIPTION OF ENTITLEMENT NOMINAL VOLUME (ML)1

MURRAY VALLEY IRRIGATION DISTRICT (excluding Lower Broken Creek)High Reliability Water Shares 151,033.8Low Reliability Water Shares 91,445.7Supply by Agreement 43.6Fixed loss allowance 26,317.8Variable loss allowance - high reliability component 30,391.9

Variable loss allowance - low reliability component 13,783.3

TOTAL 313,016.1TORRUMBARRY IRRIGATION AREA (including Tresco & Woorinen) High Reliability Water Shares 227,563.4Low Reliability Water Shares 124,091.4Supply by Agreement 1,934.8Fixed loss allowance (Tresco) 352.0Fixed loss allowance 39,311.7

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Variable loss allowance - high reliability component 28,568.0Variable loss allowance - low reliability component 12,565.0TOTAL 434,386.3NYAH IRRIGATION DISTRICT High Reliability Water Shares 8,196.6Low Reliability Water Shares 0.0Supply by Agreement 50.5Fixed loss allowance 500.0TOTAL 8,747.1PRIVATE DIVERTERS Mitta Mitta Diverters High Reliability Water Shares 8,291.5Low Reliability Water Shares 4,505.2Murray Diverters High Reliability Water Shares 46,700.3Low Reliability Water Shares 12,028.8TOTAL 71,525.8WATER SHARES NOT ASSOCIATED WITH LAND High Reliability Water Shares 452,411.0Low Reliability Water Shares 60,947.5TOTAL 513,358.5TOTAL G-MW Primary Entitlements (excluding Lower Broken Creek) 1,341,033.8

Table 2 – Lower Broken Creek Primary Entitlement

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Description of Entitlement NOMINAL VOLUME (ML)1

G-MW PRIMARY ENTITLEMENTS

High Reliability Water Shares 23,937.6Low Reliabil ity Water Shares 11,377.9Supply by Agreement 4.3Variable loss allowance - high reliabil ity component 10,033.3Variable loss allowance - low reliabil ity component 4,424.7TOTAL 49,777.8OTHER PRIMARY ENTITLEMENTSGoulburn Valley Water Bulk Entitlement - Numurkah 1,206.0Goulburn Valley Water Bulk Entitlement - Nathalia 652.0Environmental Entitlement - Living Murray 3,014.6Environmental Entitlement - Flora & Fauna High 173.5Environmental Entitlement - Flora & Fauna Low 77.3TOTAL 5,123.4TOTAL Lower Broken Creek Primary Entitlements 54,901.2

Notes to tables 1 and 21. These tables do not show changes in water share volumes as a result of trade since 6 March 20152. These tables do not show water shares that were issued or cancelled since 6 March 2015

2. Supply of water to holders of entitlements for taking from another water system

(a) Entitlements issued in respect of the Murray water system

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Description of Entitlement Nominal Volume (ML) Comment

Arising from tagged trade

from zone 6 (above Barmah)

to NSW zone 10 A 0.0

to NSW zone 10 B 0.0

from zone 7 (below Barmah)

to NSW zone 10A 0.0

to NSW zone 10 B 0.0

to NSW zone 11 0.0

to SA zone 12 0.0

Total 0.0

OFFICIAL-Sensitive

(b) Entitlements issued in respect of the Murray water system, which have been cancelled and issued in respect of another water system


Arising from exchange rate trade

Net trade out from zone 7 (below Barmah) via pilot scheme

to NSW (zone 11) 0.0

to South Australia (zone 12) 2,775.0

Net trade out via 2006/07 scheme with SA

to SA from Goulburn zones 0.0

to SA from zone 7 0.0

Total 2,775.0

3. Supply of water to holders of entitlements issued in respect of another water system for taking from the Murray water system


Water may be taken into the Torrumbarry system to supply:

Goulburn HR (zone 1A shares) 100.0

NSW HR shares 200.0

Water may be taken by direct diversion from the Murray to supply:

Goulburn HR (zone 1A shares) 400.0

Note: Details of primary entitlements is based on data relating to primary entitlements, including water rights, as at 04 June 07.

4. Procedure for estimating, accounting, reserving and allocating gross modernisation savings as a result of NVIRP

Each year until the completion of NVIRP and all resulting gross modernisation savings have been converted to new entitlements, Goulburn-Murray Water must:

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4.1 On 30 June, carryover all of the unused volume in the Modernisation Savings Account into the next year.

4.2 Estimate the total volume of gross modernisation savings to be achieved from NVIRP Stage 1 and NVIRP Stage 2 during the year that have not been issued as entitlement to a beneficiary of the project in accordance with the Protocol.

4.3 On 1 July and every fortnight or month afterwards as required, adjust the procedure specified in clause 12 of this Order so that the estimate from sub-clause 4.2 of this Schedule, as varied under sub-clause 4.4 of this Schedule is reserved in the Modernisation Savings Account before making any seasonal determination.

4.4 Adjust the volume in the Modernisation Savings Account during the year as necessary based on revised estimates of gross modernisation savings to be achieved in the current year.

4.5 If mitigation water is available in accordance with the approved Mitigation Water Operating Arrangements, the mitigation water must be allocated from the Modernisation Savings Account to the Environmental Entitlement (River Murray – NVIRP Stage 1) 2012.

4.6 Once the Audit is published, make any final adjustment to the volume in the Modernisation Savings Account required and then deduct from the volume in the Modernisation Savings Account the total volume of audited savings from the previous year and allocate it as follows:

(a) a one-third share of the total audited phase 3 water savings attributed to NVIRP Stage 1 to the Melbourne bulk entitlements collectively;

(b) a one-third share of the total audited phase 3 water savings attributed to NVIRP Stage 1 to the Murray Offset Account until 30 June 2022.

4.7 Deduct from the Murray Offset Account, as required during the year whenever a seasonal determination is made, the equivalent volume of water that was allocated in the current year to any water shares issued to the CEWH from NVIRP Stage 2 that are supplied from the River Murray.

4.8 Determine when the impacts associated with the issue of water shares in the Goulburn and Murray systems to the CEWH from NVIRP Stage 2 have been fully mitigated then inform the Executive Director of Water Resource Strategy of the Department of Environment, Land, Water and Planning of the volume of surplus water remaining in the Murray Offset Account.

4.9 Allocate the volume determined in sub-clause 4.8 of this Schedule to the Murray Offset Distribution Account.

4.10 On 30 June, carryover any unused water in the Murray Offset Account, minus 5% for evaporative losses unless, as a result of sub-clause 4.7 of this Schedule, the balance in the account is negative.

4.11 Report to the Executive Director, Water Resources of the Department of Sustainability and Environment, the accounting method and volumes of water reserved and allocated under clause 4 of this Schedule by 1 April each year, or within 14 days of a request by the Executive Director.

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5. Procedure for estimating, accounting, reserving and deducting water from the Murray Irrigators’ Share Account

5.1 Until the full volume of the Murray Irrigators’ Share has been issues as water shares, the Authority appointed under section 64 GA of the Act must:

A. On 1 July and for each subsequent seasonal determination as required; i. determine the total volume of high-reliability and low-reliability water shares

associated with the Murray Irrigators’ Share that have not yet been issued; and

ii. reserve in the Murray Irrigators’ Share Account a volume of water equal to the percentage determined under section 64GB(8) of the Act for the seasonal determination of the volume determined in sub-paragraph A(i) of sub-clause 5.1 of this Schedule for high-reliability and low-reliability water shares at that time.

B. Upon the issue of a water share associated with the Murray Irrigators’ Share, make an adjustment to the volume in the Murray Irrigators’ Share Account by deducting from the account the volume equivalent to the percentage, determined under section 64GB(8) of the Act, of the maximum volume of the high-reliability and or low-reliability water shares.

C. Upon the issue of a water share associated with the Murray Irrigators’ Share, allocate to that share the corresponding volume of water that was deducted from the Murray Irrigators’ Share Account in paragraph B of sub-clause 5.1 of this Schedule.

5.2 Any water remaining in the Murray Irrigators’ Share Account at the end of the year cannot be carried over.

5.3 At the end of the 2022-23 year if there is water remaining in the Murray Irrigators’ Share Account which represents water not issued to an Eligible Delivery Share Holder then Goulburn-Murray Water may apply to the Minister for Water to convert the remaining volume to water shares held by Goulburn-Murray Water.

6. Procedure for estimating, accounting, reserving and deducting water from the Murray Lower Broken Creek Irrigators’ Share Account

6.1 Until the full volume of the component of the Lower Broken Creek Irrigators’ Share has been converted to water shares, the Authority appointed under section 64 GA of the Act must:

A. On 1 July 2021 and for each subsequent seasonal determination as required, i. determine the total volume of high-reliability water share associated with the

Lower Broken Creek Irrigators’ Share that has not been issued;ii. determine, if the Murray seasonal determinations are higher than the

Goulburn seasonal determinations, the shortfall to supplying the high-reliability Lower Broken Creek Irrigators’ Share that have not yet been issued at that time; and

iii. reserve in the Murray Lower Broken Creek Irrigators’ Share Account a volume of water equal to the percentage under section 64GB(8) of the Act for the seasonal determination, of the volume determined in sub-paragraph A.(ii)

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of sub-clause 6.1 of this Schedule for high-reliability water shares at that time;

iv. determine the total volume of low-reliability water shares associated with the Lower Broken Creek Irrigators’ Share have not yet been issued

v. reserve in the Murray Lower Broken Creek Irrigators’ Share Account a volume of water equal to the percentage, determined under section 64GB(8) of the Act for the seasonal determination, of the volume determined in sub-paragraph A. (iv) of sub-clause 6.1 of this Schedule for low-reliability water shares at that time.

B. Upon the issue of a water share associated with the Lower Broken Creek Irrigators’ Share, make an adjustment to the volume in the Murray Lower Broken Creek Irrigators’ Share Account by deducting from the account the volume equivalent to the percentage, determined under section 64GB(8) of the Act, of the maximum volume for low-reliability water shares.

C. Upon the issue of water shares associated with the Lower Broken Creek Irrigators’ Share, allocate to that share the corresponding volume of water that was deducted from the Murray Lower Broken Creek Irrigators’ Share Account in paragraph B of sub-clause 6.1 of this Schedule.

6.2 Any water remaining in the Murray Lower Broken Creek Irrigators’ Share Account at the end of the year cannot be carried over.

6.3 At the end of the 2022-23 year if there is water remaining in the Murray Lower Broken Creek Irrigators’ Share Account which represents water not issued to an Eligible Delivery Share Holder then Goulburn-Murray Water may apply to the Minister for Water to convert the remaining volume to water shares to be held by Goulburn-Murray Water.”.

HON RICHARD WYNNE MPActing Minister for Water

/ / 2021.

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16

Review of Torrumbarry and Murray Valley Distribution Loss AllowancesDecember 2020

OFFICIAL-Sensitive

Document History and Distribution Version (s)

Version Date Author(s) Notes

1 23 October 2020 A. Shields Internal draft for comment

2 4 November 2020 A. Shields Draft for DELWP review

3 10 December 2020 A. Shields, G. Ortlipp Update based on comments received

4 20 February 2021 A. Shields, G. Ortlipp Update based on comments received

5 30 March 2021 A. Shields Update based on comments received

6 7 April 2021 A. Shields Final

DistributionVersion Recipient(s) Date Notes

1 M. Bailey, B. Knowles, M. Schulz, A, Murray, C. Wiesenfeld, G. Ortlipp, E, Uhe.

26 October 2020 Draft for initial comment

2 J. Nolan, L. Appleyard, C. Wiesenfeld,

4 November 2020 Draft for DELWP review

3 J. Nolan, L. Appleyard, C. Wiesenfeld,

10 December 2020 Draft for final review

4 J. Nolan, C. Wiesenfeld, C. Pittaway.

20 February 2021 Updated draft

5 C. Wiesenfeld, L. Appleyard, P. Smith, M. Gorsuch.

30 March 2021 Updated draft

6 Minister for Water, DELWP

7 April 2021 Final

Document Number: A3836659Version: 6

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ContentsDocument History and Distribution...........................................................................................................2

Version (s)........................................................................................................................................ 2

Distribution........................................................................................................................................ 2

Executive Summary.................................................................................................................................. 4

Background.............................................................................................................................................. 6

Recommendations and Findings from Previous Reports..........................................................................8

2007 Review......................................................................................................................................... 8

2013 Review....................................................................................................................................... 10

Data Preparation and Methodology........................................................................................................11

Flows through Torrumbarry and Murray Valley...................................................................................11

Torrumbarry diversion formula............................................................................................................12

Data availability................................................................................................................................... 12

Loss calculation equations..................................................................................................................13

Water recovery data adjustments.......................................................................................................14

Scaled Baseline Water Balance..........................................................................................................14

Victorian Mid Murray Storage data preparation..................................................................................15

Results and Data Analysis...................................................................................................................... 16

Murray Valley...................................................................................................................................... 16

Torrumbarry........................................................................................................................................ 19

Victorian Mid-Murray Storages...........................................................................................................21

Discussion.............................................................................................................................................. 23

Fixed and variable loss.......................................................................................................................24

Alternative Murray Valley options.......................................................................................................25

Consideration of the proposed and alternative Murray Valley options................................................25

Torrumbarry dry season loss..............................................................................................................27

Loss allowance allocation and the seasonal determination process...................................................28

The 10 year rolling average and headroom compliance.....................................................................30

Climate change implications...............................................................................................................30

Recommendations.................................................................................................................................. 31

Appendix A............................................................................................................................................. 32

Definitions of fixed and variable losses (DELWP, 2018).....................................................................32

References and Related Documents......................................................................................................33


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Executive SummaryThe loss allowances for the Murray Valley and Torrumbarry irrigation areas in the Murray Bulk Entitlement were intended to be reviewed 5 years after the Bulk Entitlement was gazetted in 1999. Reviews were conducted but the findings from these reviews were not finalised or implemented for unknown reasons. This review is being undertaken to ensure that the review of the original loss provisions is completed as intended when they were developed in the late 1990s. This report documents findings and recommendations from the review. Consistent with previous reviews, this review found that the original loss allowances should be revised and developed the proposed loss allowances below.

Additional data from the years since the introduction of the Bulk Entitlement have been used in this review. Adjustments have been required to calculated losses to account for modernisation works in Murray Valley and Torrumbarry to ensure all data is based on the same calculation methodology and is comparable. These include the treatment of passing water through the irrigation areas to other systems and adjustments for the impact of water recovery on the calculated losses.

Based on the information available, the loss allowances are proposed (Figure 1) to be revised to:

Murray Valley: Loss (GL) = 47.686 + 0.2281 x delivery Torrumbarry: Loss (GL) = 133.464 + 0.1969 x delivery

Figure 1: Proposed loss allowances for Murray Valley (left) and Torrumbarry (right)As the Schedule 1 loss allowances for Torrumbarry are recommended to increase based on the historic loss performance, there is no longer the need for the dry season loss allowance. The dry season loss allowance provided additional loss in dry years. The analysis in this report and previous reviews found some of this allowance was needed in most years.

Torrumbarry’s loss allowance was reduced in 2010 when the Victorian Mid-Murray Storages (VMMS) were created. The reduction was for evaporation losses from the four storages, Kow Swamp, Lake Boga, Lake Charm and Kangaroo Lake, as well as the operation of the watercourses linking the storages to the River Murray. It is possible to estimate the evaporation losses from the storages using pan evaporation, rainfall and surface area data, but not so simple to quantify the watercourse losses. The loss analysis in this report includes the VMMS losses. VMMS losses need to be deducted from the proposed Torrumbarry loss allowance. There are two options to make these deductions:

Deduct the evaporation losses from the loss allowance and retain the watercourse loss within the Torrumbarry loss allowance.

Retain the same deduction that occurred in 2010.


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Watercourse losses were estimated based on an analysis conducted at the time of VMMS creation and are a fixed quantity applied annually. It is proposed that this quantity be retained. In light of current trends of use in the Murray system that could see greater emphasis on use of the VMMS, it is recommended that this quantity be reviewed as part of future loss reviews


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BackgroundThe distribution loss allowances for the Murray Valley and Torrumbarry irrigation areas are outlined in Schedule 1 of Bulk Entitlement (River Murray – Goulburn Murray Water) Conversion Order 1999, referred to as the Murray BE here forth. These allowances specify the amount of loss available to Goulburn-Murray Water (GMW) to operate the irrigation areas for a given seasonal determination, although final compliance is based on the actual volume delivered. Table 1 details the loss-allocation relationship as presented in the original Murray BE.

User group High-security rights

Off-take commitments, for high-security allocation of:

50% 60% 70% 80% 90% 100%

Murray Valley

254.565 At farm 127.3 152.7 178.2 203.7 229.1 254.6

Losses 89.5 91.4 93.3 95.2 97.1 99.0

216.8 244.1 271.5 298.9 326.2 353.6

Torrumbarry

403.052 At farm 201.5 241.8 282.1 322.4 362.7 403.1

Losses 141.3 144.5 147.7 150.9 154.0 157.2

Pental Island 6.377 3.2 3.8 4.5 5.1 5.7 6.4

346.0 390.1 434.3 478.4 522.4 566.7

Table 1: Extract from Schedule 1, table 1 from Murray BE, high-security rights and off-take comments (GL) at 1 July 1998The loss allowances have been reduced since the creation of the Murray BE to reflect the water saved through various modernisation projects. Reductions to the Torrumbarry loss were also made with the introduction of the Victorian Mid-Murray Storages (VMMS) in 2010.

For Torrumbarry, an additional 100 GL loss allowance was incorporated into clause 13.1 of the Murray BE, commonly referred to as the dry season allowance. The allowance was included to recognise that Torrumbarry losses are higher in dry years when the contribution from the local catchment to offset losses is limited. If the flows in Loddon River at Appin South are more than 1,000 ML/month in either August, September, October or November, the loss allowance reduces to 50 GL. If the flow exceeds 1,000 ML/month in two of these months then the allowance reduces to zero. With the introduction of environmental flows in the lower Loddon River in 2006 the flow threshold increased from 1,000 ML/month to 2,100 ML/month, excluding held environmental water passing the monitoring site. The introduction of the VMMS in 2010 reduced the total additional loss to 77 GL and the deduction for each month the flow thresholds were exceeded reduced to 38.5 GL.

Data used for the original Murray BE loss allowances was limited (refer Figure 2 and Figure 3). This was recognised in the Murray BE and a clause (13.3) was included stating “Goulburn-Murray Water in conjunction with other River Murray entitlement holders must review the provisions of this clause five years from the commencement of this Order”. Two reviews of the loss allowances have been conducted; one for Murray Valley and Torrumbarry in 2007 (GMW, 2007) and separate reviews for Murray Valley (GMW, 2013a) and Torrumbarry in 2013 (GMW, 2013b). It is unclear why the findings from these reviews did not result in changes to the loss allowances. Both of these reviews recommended that the original loss allowances required revision and are further detailed below.


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This paper supports task 13 of Irrigators Share Distribution Project to review and update the Torrumbarry distribution loss allowance. This task has been expanded to include a review of the Murray Valley loss allowance as well as Torrumbarry as both loss allowances required reviewing. Reviewing loss allowances for both irrigation areas enables consistent underlying principles to be applied. This revision is based on what the original Murray BE loss allowances for Murray Valley and Torrumbarry should have been, not what they should be now.

Figure 2 and Figure 3 show the original loss allowance for Murray Valley and Torrumbarry respectively including the data points available at the time of their development (1982/83 to 1996/97). The limitations of the original curves have been addressed well by the previous reviews as discussed below.

The purpose of this paper is to review the original distribution loss allowances for Murray Valley and Torrumbarry and identify if any changes are required to the original loss allowance. The review will incorporate additional and updated data and operational experience since the original allowances were developed.

Figure 2: Original Murray Valley loss allowance


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Figure 3: Original Torrumbarry loss allowance


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Recommendations and Findings from Previous ReportsThe previous Murray Valley and Torrumbarry loss allowance reviews included additional available data and assessed the suitability of the original allowances. These reviews also made recommendations to revise the loss allowances. GMW (2007) noted with additional seasons of data available, it was important to review the loss allowances to ensure they were suitable in the long term. It is unclear why the recommendation from these reviews did not occur. Nevertheless, the intention to review the original loss provisions was clear in the Murray BE and the recommendations from these reviews provided a valuable platform for the 2020 review. The recommendations from the previous reviews are summarised below.

2007 Review

For Murray Valley, the review recommended based on a line of best fit to reduce the fixed loss (i.e. at 0% allocation) by 20 GL and increase the total loss allowance by 34.8 GL at 100% allocation, equivalent to a delivery of 254.6 GL (option C2 in Figure 4 below).

Following some changes to operations aimed at reducing losses from 2003/04, losses did reduce in Murray Valley compared to historic operations. Given there were only four years of data where operational data related to these changes at the time of the 2007 review, two options were developed for Murray Valley, depending on whether these loss savings were sustainable or reflective of other variables. Option C1 assumed they were not sustainable while C2 assumed they were. Operational data since this time has shown that the loss savings measures appeared to be sustainable and option C2 would have been an appropriate proposal to pursue.

Murray Valley Proposed Loss Allowance - C

0

50

100

150

200

250

0 50 100 150 200 250 300 350 400 450Delivery (GL)

Loss

(GL)

82/83 to 90/91 91/92 to 96/97 97/98 to 06/07 03/04 to 06/07

BE model Proposed C1 Proposed C2

#2050777

Note: All figures adjusted for IMSVID - 2.2GL savings

2006/0703/04

04/05

05/06

Figure 4: 2007 review recommended loss allowance for Murray Valley


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In Torrumbarry, the 2007 review recommended the Torrumbarry loss allowance increase at the 0% and 100% delivery points and remove the dry season loss allowance. Similarly to Murray Valley, this was based on a line of best fit as is detailed below in Figure 5.

Torrumbarry Proposed Loss Allowance - C

0.0

50.0

100.0

150.0

200.0

250.0

300.0

350.0

400.0

0.0 100.0 200.0 300.0 400.0 500.0 600.0 700.0Delivery (GL)

Loss

(GL)

97/98 to 06/07 83/84 to 96/97 revised BE model Proposed C

#2050777

02/03

00/01

84/85

92/93

99/00

97/98

01/02

98/99

05/0603/04

04/05

94/95

96/9793/94

Note:All allowances adjusted for IMSVID and Woorinen savings

06/07

Figure 5: 2007 review recommended loss allowance for TorrumbarryTable 2 below summarises the differences in loss allowance options for Murray Valley and Torrumbarry. The increase in Torrumbarry was to be more than offset by removing dry season allowance.

Allocation 0% 50% 100% 200%Expected Delivery 0% 50% 100% 168% Murray Valley BE Allowance 80 89.5 99 162.7Option C1 60 101.9 143.8 197.7Difference -20.0 12.4 44.8 35.0Option C2 60.0 96.9 133.8 181.3Difference -20.0 7.4 34.8 18.6 Torrumbarry BE Allowance - Wet 125.3 138.9 152.4 251.3BE Allowance - Dry 225.3 238.9 252.4 351.3Option C 136.0 169.9 203.8 246.5Difference - wet 10.7 31.0 51.4 -4.8Difference - dry -89.3 -69.0 -48.6 -104.8

Table 2: Difference between BE allowance and proposed loss allowance (GL) – Option C Additional losses are permitted according to clause 13.2(a) in the Murray BE, 10% of the allowance in Schedule 1 for Murray Valley and 25% for Torrumbarry. The review also recommended these additional loss allowances be revised to 15% for Murray Valley and remain at 25% for Torrumbarry. The maximum cumulative headroom (i.e. specified in clause 13.2 in the Murray BE and refers to the cumulative additional loss, net of any unused allowance) was recommended to be 30 GL for Murray


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Valley and 225 GL for Torrumbarry. Clause 13.2(c) originally specified 40 GL for Murray Valley and 350 GL for Torrumbarry.

2013 ReviewOne of the aspects the 2013 Murray Valley review investigated was the impact moving the Yarrawonga Main Channel offtake measurement point closer to the actual offtake had on losses. As the measurement point moved closer to the actual offtake point, it was hypothesised that additional losses may have been required. However, the review found that the loss allowance was more than sufficient to satisfy system operating losses. It was recommended that the loss allowance remain in its current form, pending further review when modernisation works were complete.

For Torrumbarry, the 2013 review found the schedule 1 loss allowance may not be sufficient to cover the actual losses incurred and that a portion of the dry season allowance was required to ensure annual compliance. It was recommended that:

1. The Schedule 1 loss allowance for Torrumbarry area be increased by 19.5 GL at 0% HRWS equivalent, 25 GL at 100% HRWS equivalent, and 30.5 GL at 100% LRWS equivalent.

OR

The Schedule 1 loss allowance for Torrumbarry area be increased by 16.6 GL at 0% HRWS equivalent, 22.1 GL at 100% HRWS equivalent, and 27.6 GL at 100% LRWS equivalent. With a 2.9 GL increase to the VMMS component of VMMS watercourse losses.

2. The VMMS loss allowance be incorporated into the Bulk Entitlement via a statement that the Resource Manager may allocate an operating allowance each season inline with VMMS annual operating plan.

3. Continue assessing distribution system loss and VMMS losses based on their individual components for Bulk Entitlement compliance and reporting.

The intent of the modifications to Schedule 1 was to remove the dry season loss allowance.


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Data Preparation and MethodologyWater recovery and system operations mean that if the most recent data is used without adjustment the comparison for each year to the baseline loss allowances would not be meaningful. Adjustments have been made to make the data comparable, including:

1. Consideration of how to account for delivery of environmental water through the irrigation areas

2. Application of the Torrumbarry Irrigation Area diversion formula

3. Data availability

4. Loss calculation equations

5. Adjustments for water recovery

6. Victorian Mid-Murray Storages

This resulted in a consistent dataset of delivery and loss volumes that could be used to develop the recommendations.

Flows through Torrumbarry and Murray ValleyBoth Murray Valley and Torrumbarry pass significant volumes through the distribution network destined for other systems. One key consideration is whether these are classed as a volume passed to another area or a delivery. This choice doesn’t impact on the actual volume lost during operations, however it does change the volume delivered and the overall loss allowed under the Murray BE. In recent years, water delivered from Murray Valley into lower Broken Creek for both environmental flow provision or to provide water to bypass the Barmah Choke has meant that the outfalls have been running close to capacity for the entire irrigation season and to a lesser extent, outside of the irrigation season as well. Previously, environmental water delivery from Murray Valley to lower Broken Creek has been classed as a delivery whilst water delivered to bypass the Barmah Choke has been classed as passed to another area. Whilst this does not change the calculated loss for Murray Valley, it does impact the volume delivered and thus the volume of allowed loss. For this analysis, all ordered outfalls from Murray Valley have been classed as a delivery as there is no difference between delivering environmental water or water to bypass the Barmah Choke.

Similarly for Torrumbarry, environmental flows in Gunbower Creek have regularly been provided since water was recovered for environment. Provision of these environmental flows are provided within the area (Gunbower Creek is a natural carrier and part of the Torrumbarry irrigation area), unlike the Murray Valley case which is a delivery out of the area. Losses are incurred within the irrigation areas from water delivered to receiving systems, for this reason the volume passing to other areas that is a deliberate transfer of water is classed as a delivery in the analysis. In the case of environmental water delivery in Gunbower Creek, for the flow volume that passes down Gunbower Creek in excess of normal operating levels, there is water that leaves the creek via flood runners and other means. GMW debits environmental accounts 20% of the Gunbower Creek flow (in excess of normal operating flows) as use to account for this lost water. For the purposes of loss accounting, this use in Gunbower Creek is counted as a delivery in the same way as other deliveries within the area.

As allowable loss is a function of delivery, counting the volume debited from environmental accounts for the flows through flood runners and other areas as a delivery increases the allowable loss. The logic of this approach is that the loss incurred to pass environmental water through the system and into the


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Gunbower Creek needs to be covered by the loss allowance, in the same way that a delivery to an irrigator on Gunbower Creek is covered.

This concept of delivering environmental water and operational water through Murray Valley and Torrumbarry was not an issue considered in the previous loss reviews.

Torrumbarry diversion formulaThe Murray Darling Basin Authority (MDBA) diversion formula register has been set up to account for water flowing into and out of the irrigation areas. When the return volume is greater than the diverted volume in a month, the formula assumes the extra water comes from ungauged tributaries (into Torrumbarry) and nets the diversion calculation to zero. The formula does not allow for the calculation to be negative, i.e. a net return from the area.

However, after diversions at the National Channel cease, water can still be returned to the Murray or delivered for the environment from stored resource. This is legitimate use of water that has been included as a diversion into the area in a previous month and thus should not be netted to zero in the diversion calculation. This could also occur when water is returned from the VMMS to the River Murray. If these returns are not counted, the net diversion is higher and so is the calculated loss. To correct for these returns in this analysis, only the months where the diversion is negative caused by ‘flood’ conditions have been set to zero. Table 3 outlines the months when the net diversion was set to zero due to flood conditions. A ‘flood’ month has been flagged in the data using gauged tributary flows as an indicator, e.g. when the measured flow on the Loddon River at Appin South is high (greater than about 5,000 ML/month).

Season Flood Months

1983/84 August 1983, September 19831987/88 July 1987, May 1988, June 19881988/89 July 1988, May 1989, June 19891989/90 July 1989, August 1989, September 19891990/91 July 19901991/92 July 19911992/93 October 19921993/94 August 1993, September 1993, October 19931994/95 June 19951995/96 July 19952010/11 September 2010, February 2011, March 20112016/17 October 2016

Table 3: Months where net diversion were set to zero due to flood conditions

Data availabilityAs noted in the original development of the loss allowances and subsequent reviews there are several issues with the data used in the development of the original BE loss relationship for Murray Valley.

Modelling was used to separate the lower Broken Creek customers from the total Murray Valley delivery volume prior to 1990/91 and to estimate the outfall via the Yarrawonga Main Channel escape before 1990.

It is uncertain how the Murray bypass flows were accounted prior to 1991. The accounting method has been inconsistent where data is available and the Murray Darling Basin Authority (MDBA) receives returns based on flows at Rices Weir rather than the individual Murray Valley outfall regulators. Only the years with sufficient data available for the outfalls was included in this analysis (i.e. post and including 1998/99).


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There was a significant shift in area operational behaviour from 2003/04 regarding loss management activities and a significant decrease in outfall volumes. This contributed to lower outfalls to lower Broken Creek.

Where the breakdown of outfall volumes to lower Broken Creek was not available (only prior to 2005/06) (i.e. how much of the outfall volume was to meet an order versus outfall due to excessive channel flows) it was assumed that all water measured as passed to lower Broken Creek was ordered and thus delivered, and none of the volume was system outfall (i.e. loss). In reality this may not have been the case, however no data is available to indicate the purpose of the outfall (ordered or excess system flows). Using this assumption makes these historic delivery/loss data points look better (i.e. more delivery and less loss) than if the outfall was considered as a loss.

If the delivery/loss data points between 1991/92 and 1997/98 been included in the analysis, these points were mostly at the high delivery/high loss end of the curve and would push the trend of the data points higher, i.e. more loss per delivered ML.

In Torrumbarry, losses incurred in 1984/85 were over 50 GL higher than any years with similar delivery volumes. Although rainfall was well below average over the summer months (at Kerang), water savings measures undertaken through the millennium drought and contemporary operation of the system would indicate that such a high loss year would be unlikely to occur again. The data point was therefore considered an outlier and removed from the Torrumbarry analysis. Removing this data point lowered the gradient of the trend line. Other potential outliers were examined for Torrumbarry and these are described on page 20 of this paper.

Loss calculation equationsMurray Valley loss is calculated using the following equation;

Loss = Diversions - Returns - Deliveries - Planned Downstream Deliveries

Where;

Diversions = Yarrawonga Main Channel + Cobram Pumps

Returns = Yarrawonga Main Channel Escape

Deliveries* = Irrigation + domestic and stock + urban + environmental^

Planned downstream deliveries = Broken Creek bypass ordered by MDBA *Broken Creek irrigation deliveries are not included as a Murray Valley delivery

^Environmental deliveries within Murray Valley and to lower Broken Creek

Torrumbarry loss is calculated using the following equations;

Loss = Net diversions - Deliveries

Where;

Net Diversions = Gross Diversions – Net Torrumbarry returns

Gross Torrumbarry Diversions = National Channel + Ashwins pumps + Swan Hill pumps + diversions from the Loddon River downstream of Loddon Weir + Swan Hill Channel 9 + Lake Boga Inflow from Little Murray River

Net Torrumbarry returns = Gross Torrumbarry System Returns – Torrumbarry System Tributary Inflows

Gross Torrumbarry Returns = Koondrook Spillway + Barr Creek downstream of pumps + Loddon River at Kerang Weir + Sheepwash Creek spill + release of declared unregulated flows from Gunbower Creek for environmental watering of riverine wetlands + 6/7 outflow + Lake Boga outflow + Lake Charm outflow + other outflows from Gunbower Forest

Torrumbarry System Tributary Inflows = The maximum of either:


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1. Gross Torrumbarry Returns – Gross Torrumbarry diversions

2. Loddon River at Appin South + Mt Hope Creek at Mitiamo + Avoca to Little Murray + Lake Boga Outflow + Barr Creek downstream of pumps

Deliveries^ = Irrigation + domestic and stock + urban + environmental ^Environmental deliveries within Torrumbarry including estimated losses in Gunbower Creek. Irrigation delivery includes Tresco and Woorinen.

Water recovery data adjustmentsThere have been numerous changes to the distribution loss allowances for water recovery projects and other system configuration changes including:

Snowy water recovery including the Improvement Measurement of Small Volume supplies in Irrigation Districts (IMSVID) project (2005)

The Living Murray Initiative (2009) Victorian Mid Murray Storages creation (2009), and The Connections Project (2013, 2014, 2015 and 2019).

Calculated losses since 2005 need to remove the impacts of these water recovery projects and system configuration changes. To ensure recent loss data can be compared to losses in earlier years, adjustments have been made to the data. These are:

Adding the phase 3 water recovery from Stage 1 and Stage 2 of the Connections Project to the actual loss to reflect what losses would have occurred without the Connections Project. Phase 3 savings are the actual water savings based on deliveries in the year. Table 4 contains the Stage 1 and Stage 2 phase 3 water savings from the annual water recovery audits. The information in this table was sourced from the Independent Audit of Water Savings reports from 2008/09 to 2018/19. A link to these reports in available in the References and Related Documents section of this paper.

Adding an estimate of the savings made from the Snowy and other modernisation works prior to the Connections Project. These volumes have been assumed based on a pro-rata of the percentage of HRWS delivered in the year.

Irrigation area 08/09 09/10 10/11 11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/1919-20 (est)

Murray Valley 120 601 1,385 13,397 20,957 22,236 24,921 25,776 26,134 37,742 34,253 29,974

Torrumbarry 68 570 2,854 13,432 22,166 24,406 29,258 28,758 30,773 56,085 57,679 58,124

Table 4: Stage 1 and Stage 2 phase 3 water savings for Murray Valley and Torrumbarry (ML)

Scaled Baseline Water BalanceThe Water Savings Protocol (DELWP, 2018) was developed to quantify the water savings in irrigation modernisation projects. A great deal of effort went into estimating the different loss components that made up observed losses incurred in the irrigation districts. This breakdown of losses included the fixed and variable loss components for the baseline year, which is the year that all operational changes are compared to estimate water recovery. The baseline year for the Connections Project is 2004/05. Appendix A contains the definition of fixed and variable losses from DELWP (2018) as well as what type of loss (i.e. evaporation, seepage etc.) is considered fixed and variable.

The estimated fixed and variable loss based on the Water Savings Protocol have been included as a comparison line in the results and referred to as the scaled baseline water balance. Table 5 shows the fixed and variable losses based on the baseline water balance losses extrapolated to match the delivery volume in the original loss allowances. Note that the delivery and loss volumes for the 100% low


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variable are the total at 100% high and 100% low. The high and low entitlement volumes are as specified in the original Murray BE.

Murray Valley Torrumbarry

Delivery Loss Delivery LossFixed 0.0 47.7 0.0 133.1*+ 100% high variable 258.3 101.0 401.9 209.1+ 100% low variable 422.2 134.9 656.2 257.1

Table 5: Calculated Murray Valley and Torrumbarry fixed and variable baseline loss components (GL)* Note: This does not include the 0.352 GL for fixed losses in Torrumbarry. This has been added in to the analysis in further sections.

Victorian Mid Murray Storage data preparationThe VMMS comprises Kow Swamp, Kangaroo Lake, Lake Charm and Lake Boga and watercourses that are used to move water between the storages and return water to the River Murray. The VMMS was created in 2010 and amendments to Schedule 1 of the Murray BE occurred to reflect the change in loss allowance provisions. Based on annual averages, 47,371 ML was deducted from the Torrumbarry fixed losses to cover the evaporation from the four storages (35,929 ML) and the watercourse operation (11,442 ML) including seepage, leakage and evaporation from the natural carriers. DSE (2009) estimated the watercourse operation losses to be 22,884 ML which was split between the VMMS and the Torrumbarry loss allowance. The Torrumbarry dry season allowance was reduced from 100,000 ML to 77,000 ML based on a pro-rata change to the fixed losses in Torrumbarry and Murray Valley. The variable losses remained unchanged. While the losses were removed from Schedule 1, the losses incurred in VMMS are covered by an allowance made under clause 8.1(b) of the Murray BE.

Evaporation data used to estimate the evaporation losses from the VMMS is based on evaporation data for Kerang accessed from the SILO website (www.longpaddock.qpd.gov.au/silo, site Kerang Model Farm 80126). A pan factor of 0.8 was used to calculate the evaporation in ML.

The loss data for Torrumbarry includes the loss incurred by the VMMS so no adjustments were made for VMMS operation.


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Results and Data AnalysisThis section presents graphs showing the calculated losses, losses adjusted for water recovery, trend lines and the baseline water balance lines from Table 5. Regression lines provides a good indication of how losses vary with delivery.

Murray Valley

Figure 6: Murray Valley calculated losses compared to losses adjusted for water recoveryFigure 6 shows the calculated losses for Murray Valley based on the equation detailed in the previous section compared to the estimated losses that would have occurred with no water recovery through loss savings works. The original loss allowance and the losses in the baseline water balance are also shown. The delivery/loss data point for 2004/05 should in theory pass through the scaled baseline water balance line. The data presented includes the volume passed to lower Broken Creek as a delivery whereas the baseline water balance only includes irrigation and urban delivery within Murray Valley.


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Figure 7: Murray Valley losses adjusted for water recovery compared to baseline water balance and original loss allowanceThe fixed loss on the original loss allowance curve is much higher than the trend line for the loss adjusted for water recovery (blue dotted line in Figure 7). This line suggests a fixed loss of 6 GL when extrapolated to the zero delivery point (i.e. the y-axis). Figure 7 highlights that the steepness of the trend line slope is influenced by the high delivery and high loss years from 1998/99 to 2003/04. The green dotted trend line in Figure 7 is the line of best fit with the y-intercept set to the fixed loss in the scaled baseline water balance. This lowers the gradient and provides a better estimate of the fixed loss component.

Using the fixed loss provided by the baseline analysis and drawing a trend line through the observed loss points (adjusted for loss savings) produces the blue line in Figure 8.


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Figure 8: Murray Valley proposed loss allowanceFigure 8 shows that the majority of observed delivery/loss points, at the low to medium delivery volumes, are below the loss curve. However, for higher deliveries, the points are mostly above the loss curve. Figure 9 includes a line with an additional 15% of the proposed loss allowance to provide coverage for seasons when losses are higher. It does not capture all the potential outliers but does provide a reasonable threshold for additional losses to ensure that most of the observed losses are covered.

Figure 9: Proposed loss allowance with additional 15% allowance


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Torrumbarry

Figure 10: Torrumbarry calculated losses compared to losses adjusted for water recoveryFigure 10 shows the calculated losses for Torrumbarry based on the equation detailed in the previous section (with only flood months set to zero) compared to the estimated losses that would have occurred with no water recovery through loss savings works. The original loss allowance and the losses in the baseline water balance are also shown. The calculated losses are shown in Figure 10 to illustrate the impact of water recovery on calculated losses.

Figure 11: Torrumbarry losses adjusted for water recovery compared to baseline water balance and original loss allowance


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The recent delivery/loss data points shown in Figure 11 mostly sit above the original Murray BE loss allowance line. To investigate this further, Figure 12 highlights the difference between the allowed losses based on the volume delivered and the losses adjusted for water recovery for Torrumbarry. The negative volumes indicate that losses were higher than the allowed volumes and positive numbers mean losses were lower than allowed. In most years Torrumbarry would have exceeded the loss allowance. Only in the wetter years were losses lower than the allowance. Torrumbarry has access to additional losses (i.e. the dry season losses and the additional 25% of the Schedule 1 allowance) if flow thresholds, excluding delivery of held environmental water, on the Loddon River in August, September or October are not met. This additional loss assisted with compliance in many of these years. However, while the annual loss was within the allowances, the dry season loss allowance and the additional 25% do not contribute to the rolling 10 year average under the rules of the Murray BE (i.e. clause 13.1). This meant Torrumbarry was at risk of not complying with the longer term aspect of the loss allowance, despite the availability of the dry season allowance. Consistently exceeding the original loss provision suggests that the initial loss allowance was insufficient and some of the dry season loss was needed to cover observed losses. The 10 year average is included in Figure 12, highlighting that losses have been consistently higher than the loss allowances. During the 1990s and early 2000s, the 10 year average benefited from the very wet years and low losses in the 1990s.

Figure 12: Annual difference between actual and original Murray BE allowed Torrumbarry losses (negative indicating calculated losses were higher than allowed and positive lower than allowed)Torrumbarry losses are much more variable than Murray Valley, mainly due to the influence of flood years (i.e. 1992/93, 2010/11). Variation is also influenced by the cumulative uncertainty of all the inputs that are used to calculate Torrumbarry losses including rainfall, evaporation, ungauged inflows and outflows. Noting this variation, the trend line using all the calculated losses has a similar gradient (197 ML of loss per 1,000 ML delivered) to the baseline water balance (189 ML of loss per 1,000 ML delivered). The fixed loss of the calculated loss adjusted for water recovery trend line is about 37 GL lower compared to the baseline water balance (Figure 11 contains the equation for the trend line, including the y-intercept). Calculated losses in flood years are much lower than those in years when the tributary flows are negligible, even when the months of negative diversion have been set to zero in the annual calculation. The flood years could be considered as outliers due to their influence on the analysis. If the flood years were removed from the analysis, the gradient of the trend line reduces by 10 ML per 1,000 ML delivered and thus does not make a significant difference.


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An option for the Torrumbarry loss curve is to use the fixed loss from the baseline water balance and the gradient from the observed losses (including the flood years). This method produces the blue line shown in Figure 13. Figure 14 includes a line with an additional 15% loss to cover additional seasons when the losses were above the proposed loss allowance.

Figure 13: Torrumbarry proposed loss allowance

Figure 14: Proposed loss allowance with additional 15% allowance

Victorian Mid-Murray StoragesNet evaporation data since 2007/08 is available for the VMMS (Figure 15). Net evaporation for 2008/09 and 2009/10 is lower than other years as Lake Boga was dry in both years. In 2010/11, net evaporation was very low due to the very wet conditions experienced. The average net evaporation from 2010/11 to 2019/20 was 43,479 ML, about 7,500 ML higher than the average used to amend the Murray BE in


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2010. This variation in observed evaporation seems to be within the expected range over the last 10 years.

The VMMS watercourse losses were estimated based on the surface area and length of the watercourses as well as an adopted seepage and leakage rate and a number of other factors. Determining the actual losses incurred in the watercourses is not possible based on the available data. A comparison between the actual watercourse losses and the volume used to amend the Murray BE is not available. When attributing watercourse losses to Torrumbarry, 11,442 ML (half of the watercourse average losses) is deducted each year from the calculated Torrumbarry losses as this is the volume assigned to the VMMS along with the net evaporation losses.

For the purposes of assessing VMMS losses, making the adjustment to the calculated loss for the watercourse losses does not provide a true reflection of the loss being incurred as it based on a calculation over the long term and not reflective of actual losses.

Figure 15: Actual net VMMS evaporation loss compared to average modelled net evaporation


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DiscussionIt is clear that the original loss allowance for Torrumbarry was too low and the original loss allowance for Murray Valley was too high for low deliveries. This was identified in the 2007 review and subsequent reviews. Figure 16 and Figure 17 show the differences between the finding of this review with the previous reviews for Murray Valley and Torrumbarry. Compared to the 2007 review, this review for the Torrumbarry loss allowance is slightly higher and the Murray Valley loss allowance is lower. Further loss and delivery information and operating experience in the years after 2007, including data from the millennium drought, have further informed the loss allowances. This is particularly the case for Murray Valley where the loss allowance proposed in 2007 didn’t have the information available from these recent years.

Figure 16: Comparison of 2007 Murray Valley loss reviews with the 2020 review


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Figure 17: Comparison of previous Torrumbarry loss reviews with the 2020 review

Fixed and variable lossWhen the original loss allowances were developed, there were very few years with low deliveries. This made estimating the loss required at the low delivery end of the curve difficult. Including delivery and loss data from the millennium drought and subsequent years provides more information to inform the loss relationship for both Murray Valley and Torrumbarry.

One of the challenges in determining loss allowances is working out what the fixed loss component is. The slope or gradient can be based on the trend line of observed losses to give an indication on how the volume of loss increases as delivery volumes increase, but that relationship may not reflect the fixed loss at zero deliveries. The term fixed loss suggests this amount will be lost, regardless of the delivery volume. However, it is plausible that in any season where deliveries were expected to be so low that they approached zero, the network would be operated in such a way as to reduce the volume of loss incurred in the network, for example not filling many of the spur channels. Therefore the volume of loss required to run the network, before any water is delivered to a customer meter, would change depending on the season. This has happened to some extent in low delivery years where not all the system has been filled. Another contributing factor to reducing the fixed loss in recent years has been to only draw down part of the irrigation work at the end of the season where maintenance was required. Channel draw down at the end of the season occurred regularly before this was identified as a way to reduce losses.

Despite this, an estimate of fixed loss is required to recognise that there are volumes of loss required to run the network before any water is delivered that represents an average fixed loss. For both Murray and Torrumbarry the fixed loss from the baseline water balance for the 2004/05 water year has been used to define the curve. This has been used as it has been well studied and quantified based on the Water Savings Protocol, is considered a representative year prior to most modernisation and represents a year that had delivery close to 100% of historical high-reliability water share volume.


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Losses from the baseline water balance are based on the various components of loss as defined in the Water Saving Protocol and provides the best approximation of the fixed loss. This is why it has been used in the analysis and formed the basis for the fixed loss. Using the fixed loss from the baseline water balance and the observed variable loss is consistent with the approach taken to develop the loss allowances in the Goulburn system (DSE, 2010).

The analysis for Murray Valley and Torrumbarry shows a linear relationship would be best suited to describing the loss-delivery pattern. We can see from plotting the baseline water balance loss relationship that there is nothing to suggest that the slope of the loss curve should change once a particular volume of delivery is reached.

The proposed loss allowances are not designed to cover all historic losses. Setting loss allowances for this purpose would result in an overly conservative estimate of required losses. The allowances have been designed with an aim to provide a reasonable estimate of the loss volume required to deliver a certain volume within the irrigation area (i.e. cover the losses in most years). Where the variation is large, the annual additional loss allowances provide the tolerance to ensure loss provisions are available for the season. Over the long term, these seasons are offset by other seasons where actual loss is below the allowed loss. The way the loss allowances have been prepared ensure a balance between this. A 15% tolerance threshold for each of Murray Valley and Torrumbarry should provide this coverage in most years.

The method used to develop the proposed loss allowance gradient for Murray Valley and Torrumbarry differed slightly. Murray Valley’s proposed allowance was based on fixing the y-axis to the scaled baseline water balance fixed loss, with a trend line through the observed delivery/loss points from this fixed point. For Torrumbarry, the scaled baseline water balance fixed loss was used as a starting point with the gradient of the observed data trend line used to construct the variable portion of the allowed loss curve. If the Torrumbarry method was used for Murray Valley, the gradient would have been steeper and overestimated the loss required. Using the Murray Valley method for Torrumbarry would have resulted in a flatter gradient and potentially underestimating the loss required. The variations to the methods provided a better fit of the data to achieve the aim to determine a reasonable loss allowance that covers the required loss in most seasons.

Alternative Murray Valley optionsAn alternative option for the Murray Valley loss allowance to lower the fixed loss and have a steeper gradient was considered. While this would have provided a better fit of the observed data, the calculated fixed loss is an important feature of the loss allowances. As the fixed loss calculation is based on an analysis of the whole irrigation area in a representative year, it provides the best estimate of the fixed loss. Lowering this would mean the best information on fixed losses was not incorporated into the new loss allowance. Another option considered was to have a constant fixed loss for the first 50 GL delivered, then introduce the variable loss. This would have also provided a better fit of the data but introducing a variable loss for different delivery rates was difficult to justify, particularly in defining where the gradient of the curve should change.

Consideration of the proposed and alternative Murray Valley optionsWhen considering the proposed loss curve and the alternative with a potentially better fit of the observed data, the data points below the proposed loss allowance at lower delivery volumes (see the data points in the green circle on Figure 18) were further considered as were the data points above the proposed loss allowance at higher delivery volumes (see the data points in the red circle on Figure 18).

Lower losses at lower delivery volumes (see the data points in the green circle in Figure 18)

There are a variety of reasons why there are five observed low delivery, low loss points that fall below the proposed loss allowance. These include:


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Three of these years were during the millennium drought (2007/08, 2008/09 and 2009/10) and actions were taken to reduce losses by:

Actively reducing outfalls

Increased focus on reporting addressing leaks

Minimising the extent of the network operating at normal levels

Commencement of practice to maintain water in channels over winter to reduce the volume required for system fill. As an example, the system fill loss component reduced from about 8,000 ML in 2006/07 to about 2,000 in 2007/08.

Wet conditions in 2010/11 contributed to lower losses, mainly due to reduced net evaporation. Data issues at the Yarrawonga Main channel offtake in 2019/20 are being investigated. The

current data point was considered the best available for 2019/20 at the time of this analysis.The operational actions taken to reduce losses in 2007/08, 2008/09 and 2009/10 were drought response measures that were possible due to low water availability. These were temporary measures to reduce water use in those years, which is different to water recovery actions which recover water permanently through infrastructure modernisation.

An impact of the actions taken to reduce losses during these drought years is that some fixed losses may not have been incurred in those years where they would have in years when the entire area was fully operational. As additional losses would have occurred without these interventions, and the interventions were temporary in nature, it is appropriate that the loss allowance line is above these data points. The loss allowances need to be allow for a representative year, rather than a year with demand management in place or for a flood year.

Higher losses at higher delivery volumes (see the data points in the red circle on Figure 18)

There are also high loss, high delivery data points above the proposed loss allowance and it is appropriate that these points are above the proposed relationship as there have been sustainable actions taken to reduce losses since. These actions include those implemented from the loss management program such as reducing outfalls, as referred to in GMW (2007). The more recent data points have not been adjusted up to reflect these actions as they are difficult to quantify and considered part of normal system operations, rather than permanent water recovery actions. You would expect that if a high delivery year occurred now, the losses would be lower than experienced in those earlier years. All these data points have been included in the analysis and contribute to the proposed loss allowance that fits in the middle of the data points.

Estimated data for 2020/21

Interim information about Murray Valley delivery and loss in 2020/21 (Figure 18), which has been adjusted for estimated water recovery as per the other points, indicates that the observed point would be very close to the proposed relationship. While not included in the analysis and noting the information is preliminary, it does provide additional confidence that the Murray Valley proposed original loss allowance is appropriate.

Summary of proposed curve and alternative option

While the proposed curve is potentially shallower than an alternative option which could fit the observed data more closely, on balance, the importance of reflecting the fixed losses as accurately as possible for a representative year means that the proposed curve is more appropriate. The data in the green and red circles is real data and was therefore included in the determination of a line of best fit, however they are justifiably above and below the proposed loss allowance. The estimated data for 2020/21 provides additional confidence that the loss curve is a reasonable proposal.


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Figure 18: Interim 2020/21 data point (adjusted for water recovery) in relation to proposed Murray Valley original loss allowance, low loss, low delivery years (in green) and high loss, high delivery years (in red)

Torrumbarry dry season lossIn Torrumbarry, the original Murray BE clauses recognised that there would be years when losses would exceed the allowances due to observed loss variability. To recognise this, additional losses could be provided using the dry season allowance, up to 100 GL. The variation in the annual losses remain, however not to the extent of 100 GL or even 77 GL after the VMMS amendment highlighting that the total dry season loss is not required. The proposed loss allowance for Torrumbarry captures the variation covered by the dry season allowance, rendering this allowance redundant.

Torrumbarry net diversion calculationThe Torrumbarry area is distinct to the other GMID areas in that there are many inflow points and return flow points, with many of these being natural carriers that respond to rainfall and runoff when the catchment conditions are right. Another distinction is the relatively large internal storage capacity of the area with the VMMS and the role these storages play in both helping to meet internal demand and supplement River Murray operations.

When calculating the net diversions for Torrumbarry, where the return flows are higher than the volume diverted in a month, the current calculation assumes, rightly or wrongly, that the extra water comes from flows from the ungauged tributaries. Rather than allowing the calculated diversion to be negative, these assumed extra ungauged tributaries mean the net diversion is instead calculated be to zero.


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However, this is not always a fair reflection of operations. For example, at the end of the irrigation season when diversions via the National Channel have ceased, if water that was diverted at an earlier stage of the season and held in storage is returned to the River Murray the additional water would be assumed to come from the tributaries. Another example is where water is delivered for the environmental water holders outside of the irrigation season with this water coming from in-system and stored resource in Torrumbarry rather than diversion from the River Murray.

There may be times when ungauged tributaries do contribute large inflows and it is appropriate to reduce the net diversion to zero for these months. However, the calculation formula needs revising to allow for negative diversions in those months where the negative isn’t caused by ungauged inflows.

Loss allowance allocation and the seasonal determination processThe proposed loss allowances are based on delivery rather than the water allocated in the season. This allows for sufficient volumes to be allocated to the loss allowance given carryover from the previous season plus the new allocation in the current season, which combined is higher than just the current season allocation.

Changing the distribution loss allowances has implications for the way Murray system seasonal determinations are calculated as the proposed allowances are higher than the original Schedule 1 allowances. The original loss allowances and associated clauses mean water is allocated to the full dry season loss allowance (currently 77 GL) unless the flow on the Loddon River at Appin South exceeds a certain volume in August, September or October. In dry years the full dry season allowance is allocated. Historic loss performance indicates the full dry season loss may not be required meaning water is allocated to these losses when it is not needed, limiting the amount allocated to entitlement holders if seasonal determinations are lower than 100% HRWS. In wetter years the dry season loss has not been allocated and this has made more water available for allocation. To identify the possible impact on seasonal determinations, Table 6 shows the estimated seasonal determinations on 1 July in the last 10 years and Table 7 shows the estimate for 15 October if the loss allowances were modified. Table 8 shows the estimated final Murray seasonal determinations.

On 1 July, seasonal determinations could have been the same or higher. In the 11/12 and 12/13 seasons, the dry season allowance was not allocated as the Appin South flow trigger had been met so removing this allowance and increasing the loss allowance meant less water was available for allocation. These were both wetter years and seasonal determinations increased to 100% of high-reliability water shares. However, this may delay the full repayment of the water borrowed from the Barmah Millewa Environmental Water allocation. Importantly, in drier years (i.e. 15/16 and 18/19) when the dry season loss was allocated, implementing the revised loss allowance increases the volume available to allocate. It is important to highlight, there would have been no change to the final announced seasonal determinations.

Scenario 11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Actual seasonal determination

21% 26% 42% 57% 35% 1% 66% 41% 2% 8%

Estimate with revised loss allowance

22% 26% 43% 58% 37% 7% 69% 44% 8% 11%

Table 6: 1 July Murray high-reliability water share seasonal determination difference with proposed loss allowance


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Scenario 11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21


86% 95% 100% 100% 82% 100% 100% 84% 40% 55%


81% 90% 100% 100% 85% 100% 100% 88% 40% 57%

Table 7: 15 October Murray high-reliability water share seasonal determination difference with proposed loss allowance

Scenario 11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21


100% 100% 100% 100% 100% 105% 100% 100% 66% 100%


100% 100% 100% 100% 100% 105% 100% 100% 66% 100%

Table 8: Final Murray high-reliability water share seasonal determination difference with proposed loss allowanceNote: impacts are not cumulative and may not flow through from year to year and are indicative only.

Revising the Schedule 1 loss allowance and removing the dry season allowance should provide more certainty on the volume required for distribution losses. It also allows the schedule 1 allowance to deal with more variability in loss behaviour. The nature of the trigger for the dry season loss allowance means that it is not always available in the years when it is needed. Higher flows in the Loddon River over winter and spring does not always mean that losses in Torrumbarry will be lower, particularly if these flows reduce to low rates by the end of spring.

When actual distribution losses have been higher than the volume allowed, more water needs to be allocated to losses in the seasonal determination calculations. This may be permitted with the additional losses allowed in clause 13.2(a), however, there may be occasions when this is insufficient. A provision in the Murray BE is needed to clarify how the Resource Manager can allocate more to Murray Valley and Torrumbarry losses if actual losses in a given year exceed the specified loss provisions. This would not be to ensure compliance with the loss provisions, but would be there to reduce the risk of actual losses being higher than the volume allocated in the seasonal determination calculations. If actual losses were higher than the volume allocated to loss, the process for allocating water to entitlement holders is underwritten.


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An observation on both the proposed Murray Valley and Torrumbarry curves is that the majority of data points, particularly at the lower to medium delivery volumes, sit below the loss curve. This means that if similar seasons to these were experienced again, there would be more loss available than required. Any loss allocated in a season for expected deliveries, but then not required to cover the loss actually experienced in the season, is returned to the general allocation pool in the following season. This actual mechanism used is in contrast to a hypothetical alternative where any loss allocated but not utilised by the end of the season would be carried over to use in subsequent seasons. Given that unused loss is not carried over but returned to the general pool, the risk of allocating too much loss in a season is low and thus it is preferable to have a loss allowance that is adequate for the majority of seasons rather than one that is not.

Victorian Mid-Murray StoragesWhile there was an estimate of operating losses and evaporation losses taken out of the Torrumbarry loss allowance to account for VMMS losses and manage them separately, it is hard to accurately determine the operating loss from year to year.

While difficult to estimate, the modelled fixed watercourse loss remains the best estimate of this volume. Current trends of use in the Torrumbarry area versus the greater Murray system is seeing both a reduction in Torrumbarry irrigation deliveries and the potential for greater emphasis on use of the VMMS for meeting wider Murray system demands. Accordingly, it is proposed that this quantity be reviewed as part of future loss reviews, particularly the assumed 50/50 split of the volume between Torrumbarry and the Murray system.

The loss allowances contained in the Murray BE are used by GMW for pricing purposes. Changes due to revising the original curves as well as adjustments for the VMMS alter the price recovery. GMW would need to further investigate and determine what cost implications these changes may have for GMID customers and all Murray entitlement holders in the future if a change was to be made

The 10 year rolling average and headroom complianceThe Murray BE indicates the volume of loss allowed in a year for the given volume of delivery, taking into account additional losses provided under clause 13.2. Clause 13.2 also specifies requirements based on the loss calculated as an average over a rolling 10 year period (minus any additional loss or, in the case of Torrumbarry, dry season loss) and a rolling headroom balance which is debited or credited, as the case may be. This analysis suggests that current the available headroom for Torrumbarry, 350 GL, is too high as the difference between the actual and available losses will reduce the with revised loss allowance. A lower volume of 100 GL is proposed for Torrumbarry and the 40 GL for Murray Valley to remain. Both of these are to be reviewed five years after the loss allowance amendments for water recovery.

Climate change implicationsThe loss allowances for Murray Valley and Torrumbarry are based on observed historic loss and delivery information. Most climate change scenarios indicate warmer temperatures and lower rainfall is expected across Australia in the decades to come. If this trend continues then the evaporation component of losses in the irrigation areas is expected to increase. This additional evaporation has not been incorporated into the analysis. Future loss allowance reviews will be informed by observed loss and deliveries that are available. This information will include the observed impacts of climate change on loss behaviour.

Pre-empting the additional evaporation losses needed based on climate change scenarios could result in loss provisions being too large for what is required now due to the uncertain impact of climate change.


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The provision for VMMS losses can be modified based on estimated losses and can be increased in observed losses are higher than forecast.


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RecommendationsThe findings suggest a distribution between delivery and loss is appropriate for Torrumbarry and Murray Valley. The recommended loss equations are:

Murray Valley: Loss (GL) = 47.686 + 0.2281 x delivery Torrumbarry: Loss (GL)^ = 133.464 + 0.1969 x delivery

^ Prior to VMMS adjustments and including Tresco

These relationships will allow the Resource Manager to allocate the appropriate loss volume based on the volume available to deliver in each irrigation district rather than based on the seasonal determination.

It is recommended to remove clause 13.1, the reference to dry season losses as this component of the additional allowances is no longer required.

The provision in clause 13.2(a) to allocate water in the seasonal determination process to additional losses up to 10% in Murray Valley and 25% in Torrumbarry of the Schedule 1 loss allowance to cover any years when losses are expected to exceed what has been allocated should be revised to 15% of Murray Valley and 15% for Torrumbarry. To expand this, in circumstances when observed losses exceed the additional allowances a clause could be added to allow the Resource Manager to allocate more to losses. This would ensure actual losses do not exceed the volume allocated and compliance would still be based on the allowed loss.

For the VMMS deductions, it is recommended volumes used in 2010 are retained and these provisions are reviewed in the future. Other clauses that may need to be revised:

13.2(a)(ii) remove reference to clause 13.1 13.2(c)(ii) reduce the headroom for Torrumbarry to 100 GL 13.3 to revise the review clause period noting that the five year review is no longer relevant, but

another clause should be added to allow a review 5 years after the completion of the Connections Project and further observed data.

Changes to Schedule 4: Off-take point and return points may be required to align with the Diversion formula register. Particularly the section on Torrumbarry returns and the reference to net returns in a month. A clause should be added to reflect that returns may be higher than the diversion. This clause should also reference returns should be set to zero for the month during floods to avoid a large reduction in the net diversion.

To ensure the loss allowances and associated Murray BE clauses remain contemporary, a review should be scheduled in 2027 following completion of the major water recovery projects in the Goulburn Murray Irrigation District.


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Appendix ADefinitions of fixed and variable losses (DELWP, 2018)Fixed losses - Distribution losses not dependent on the volume of water delivered through the irrigation distribution system.

Variable - Distribution losses that vary with the volume of water delivered through the irrigation distribution system.

System Loss Nature of Loss

Variable (i.e. delivery-dependent) outfall losses - The volume of water passed through an outfall structure.

100% variable

Fixed (i.e. delivery-independent) outfall losses - The volume of water passed through an outfall structure.

100% fixed

Unauthorised use - Water taken from any part of the system without the authorisation to do so.

100% variable

Seepage - Water lost through micro pores in channel beds and banks in earthen channel systems.

100% fixed

Bank leakage - The water lost through holes and cracks in channel banks. Bank leakage is often the balancing component in water balances for irrigation distribution systems.

65% Variable, 35% Fixed

Evaporation - The water lost from the surface of irrigation distribution systems.

100% Fixed

Meter error - The volume of water that passes through a meter that is not accounted for due to the inaccuracy of the meter itself (usually expressed as a percentage of deliveries).

100% Variable

Leakage through and around service points - Water that is lost due to inadequate design of concrete cut-off walls, poor bank compaction around the service point and/or eroded banks at the service point.

100% Fixed

Unmetered use - Water received through an unmetered water supply point. The billing volumes are usually quantified by deeming or rule of thumb calculations. These are mainly irrigated properties which have traditionally held both Water Right for the farm and a parallel D&S right for the homestead. This second supply, usually about 2 ML/year, is commonly provided through a small poly-pipe, and is generally not metered.

There are also a large number of un-metered small-scale D&S only services that have traditionally been provided with water from irrigation distribution system supply channels.

100% Variable


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References and Related Documents GMW, 2007. Review of Murray Irrigation Areas Bulk Entitlement Loss Allowance. Document number A2424708.

GMW, 2013a. Review of Murray Valley Area Distribution Loss Allowance. Document number A2311939.

GMW, 2013a. Review of Torrumbarry Area Distribution Loss Allowance. Document number A1842679.

DSE, 2009. Identification of system operating water requirements in Kow Swamp and the Mid-Murray Storage system.

DSE, 2010. Goulburn Irrigation Areas Loss Relationships.

Independent Audit of Water Savings from 2008/09 to 2018/19. Accessed via https://www.water.vic.gov.au/water-for-agriculture/investment-in-irrigation-efficiency/historic-water-recovery-audit-reports.

DELWP, 2018. Water Saving Protocol – A protocol for the quantification of water savings from modernising irrigation distribution systems.


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