Western Region Sustainable Water Strategy (Phase 1 scoping paper)

Subject: Phase 1 scoping paper. Recording avoided water use as a first-class outcome

Dear Western Region Sustainable Water Strategy team,

This is a contribution to Phase 1 of the new Western Region Sustainable Water Strategy (the Strategy), which the Department of Energy, Environment and Climate Action is developing under the Water Act 1989. Consultation on the scoping paper closes at 11:59 pm on 30 August 2026. A draft Strategy is expected in 2027.

The contribution is offered from the Negawatt Economy, an originated body of work on energy and resource conservation that can be verified, measured, and valued. I am an ecological engineer. Ecological engineering here means measuring function in the landscape, including water that was not extracted. I do not live or farm in western Victoria. I do not claim local knowledge of particular properties, stock routes, or catchment practice in the Western Region. The argument is architectural. It is a measurement principle, offered for this scoping stage and for the later draft.

I acknowledge the Traditional Owners of Country across the Western Region. I do not speak for them. Traditional Owner access to water is already identified in the Department's material. That work belongs with Traditional Owners and the State, not with this submission.

The 2011 Strategy followed the Millennium Drought. The new Strategy is being prepared in a drier climate, for a region of about one-third of Victoria, from the southern Mallee to the south-west coast. Government material already lists livestock water in drought, Traditional Owner access, stormwater and recycled wastewater, waterway flows in dry conditions, infrastructure losses (seepage and evaporation), availability and demand trends, and licensing and trade. Those are the right headings. What many water strategies still omit is a rule of accounts: what is avoided must be as visible as what is produced or delivered.

A megalitre not taken from a stressed system, a megalitre not lost to seepage or evaporation, and a megalitre of potable take displaced by fit-for-purpose recycled water are real outcomes. If they are booked only as residual after supply is counted, the Strategy will keep seeing production and miss restraint. Architecture over belief. Restraint, once recorded against an independent method, is an asset of the system, not a story about virtue.

The public record of this work is at https://nigelgrier.com. Related commercial work is at https://negawatts.io.

Recommendations

I recommend that the Department:

1. Record avoided take as a first-class entry. Demand reduction, unused entitlement, and water left in the system should appear in the Strategy's accounts with the same standing as water supplied. Absence of take is not a rounding error.
2. Measure livestock drought water as both delivery and avoided demand. Emergency supply is necessary. So is a verified record of efficiency, substitution, and demand that did not materialise. Otherwise drought response will be told only as a supply story.
3. Verify substitution from stormwater and recycled wastewater against a baseline of take. New sources should be counted as substitution where they displace potable, environmental, or licensed take, not only as additional volume on the supply side.
4. Treat dry-condition waterway flows as a recorded environmental holding. Water that remains in a waterway because it was not extracted is an outcome. It should be measured and reported, not implied by residual flow after extraction.
5. Make infrastructure losses visible, and make avoided loss visible. Seepage and evaporation are already in the Department's list. A reduction in those losses is conserved water. It should be verified, not assumed from works completed.
6. Keep licensing and trade from seeing only extraction. If trade and licensing report only water moved and used, conserved or unused entitlement will remain invisible. The Strategy should require that unused and conserved volumes stay on the ledger.

These recommendations do not require local case studies from me. They require the Strategy to treat measurement as part of its architecture. I would be prepared to comment further on verification design at draft stage in 2027, if that would assist the team.