Our Review of the ACCC Water Market Inquiry submissions

The Australian Competition and Consumer Commission (ACCC) conducted an inquiry into markets for tradeable water rights in the Murray-Darling Basin, consulting with a wide range of water market participants involved in water markets in the Murray-Darling Basin in October 2019.

The ACCC will release an interim report on the inquiry in May 2020 and the final report in November 2020.

You can read our full submission provided to ACCC Inquiry here.

We conducted our own analysis, reviewing the public submissions, to highlight common themes & key issues raised by stakeholder type, level of support for or against reform & solutions suggested. At the time we conducted our review,  there were 121 submissions in total made to the ACCC Murray-Darling Basin Water Markets Inquiry.

Download our full report.


Submissions were made by the following key stakeholder groups:

  • 50 Private responders
  • 39 Industry Group responses
  • 16 Government and Statutory responses
  • 8 Irrigation provider responses
  • 8 Market intermediary responses

Chart 1: Submission type


Chart 1 shows ‘private individuals and companies’ represented most of all stakeholder groups (43%) who made a submission.

Chart 2: Themes raised


Chart 2 presents the top 10 themes raised, according to the number of submissions that raised them. There was a diversity of issues raised in these submissions.

Chart 3:  Speculators and investors – mentions by industry type


Chart 3 shows a total of 63 (52%) submissions mentioned the involvement of speculators and investors in the water market. Chart 3 presents this by submission type. It shows that the private individuals and companies were those who referenced speculators and investors the most (43%) market intermediaries made reference to this topic the least (5%).

Chart 4:  Responses expressed on carryover arrangements in the water market.


Chart 4 presents how the respondents felt towards the carryover water arrangements in the water market. A total of 60 percent of submissions expressed a critical view of carryover arrangements, either had concerns, want improvements or disagree with the current arrangements. Those in favour of carryover, stated that carryover plays a critical role in increasing the economic use of temporary water and reducing seasonal volatility prices and allows entitlement holders to manage their inter-annual resource risk.

Chart 5:  Carryover mentioned by submission type


Chart 5 presents those who mentioned carryover by submission type.

  • 4 out of 10 submissions provided by industry mentioned the use of carryover.
  • Almost 35% of private submissions raised the topic of carryover, while only 6% of market intermediaries mentioned carryover.
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