10/11/2025
Hello everyone,
The information below has just now been sent to rural print media in the area covered by GMW. Our date in the tribunal is looming. Please make contact if you would like some more information.
Rod, Ian, Nick, Heather and Cameron
Our story.
Small Rural Water Customers to Fight GMW and ESC in VCAT Over Unfair Fees
Country Victoria, Goulburn-Murray Water Catchments – A group of small rural water users is appearing before the Victorian Civil and Administrative Tribunal (VCAT) on 27 November 2025 to challenge unfair and unjustified fees charged by Goulburn-Murray Water (GMW) and approved by the Essential Services Commission (ESC).
This will be only the second time the ESC has faced a legal challenge from consumers to its pricing decisions and the first time a challenge will have proceeded to a full VCAT hearing.
The applicants, representing many of the over 2,000 small domestic and stock customers across the region, argue that they have been charged for services that do not exist. They rely on unregulated waterways—creeks and springs with no GMW-operated dams or infrastructure—and yet saw their annual water fees almost double between 2015 and 2020. This has since been compounded by massive rises in licence renewal fees which are to rise from $700 in 2023-24 to around $1,100 in 2027-28.
“Year after year, our fees have increased far beyond inflation—for no service, no infrastructure, and no benefit,” said Cameron Reid, spokesperson for the group. “For most of us, water comes from small local creeks. We maintain our own pumps, pipes, and filtration. GMW provides no service beyond enforcing compliance fees, yet continues to charge as if it does.”
The group has been advocating for fair treatment since 2018, forming a collective known as GMW Concerns after previous attempts by an earlier group, Justice for Domestic Users, to hold the regulator accountable failed.
The hearing will focus on three specific errors of fact the applicants argue were relied upon in setting charges. Beyond the numbers, the group emphasises the broader issue: recognition and fairness for small rural customers often overlooked because of their relatively low revenue contribution and dispersed existence.
“We are not asking for special treatment,” Mr Reid said. “We are simply asking that the fees applied to us relate to services we actually receive. This is about fairness, trust, and respect for small rural Victorians who have been left out of the system.”
The applicants acknowledge the important work GMW does for large irrigation customers but stress that the business model does not extend to small unregulated water users. They are calling for clearer accountability, independent regulation, and a fee structure that reflects reality.
Background: Summary of Alleged Errors in ESC’s Approval of GMW Fees
Error One – False Assumption of Annual Site Inspections
The Essential Services Commission (ESC) based its latest pricing decision on the idea that unmetered domestic and stock water users have their service points inspected roughly every year.
That assumption is wrong.
Evidence shows that Goulburn-Murray Water (GMW) does not carry out annual inspections for these small rural customers.
A key Excel file provided by GMW to the ESC’s consultants — but only disclosed to applicants at the last minute — confirms that such inspections do not occur.
In reality:
· Numerous customer submissions report that inspections are extremely rare.
· GMW’s own consultants (Aither/DGC) describe them as “incidental or opportunistic”, not scheduled.
· GMW’s compliance policy prioritises high-risk irrigators, not small domestic users.
· With only 13 diversion inspectors across the region, annual checks on thousands of service points are physically impossible.
Despite this, the ESC kept the same Service Point Fee structure, effectively charging customers for inspection work that doesn’t happen.
Error Two – Wrongly Averaging “Deeming” Costs Across All Users
The ESC also approved GMW’s method of spreading “deeming” costs evenly across all unmetered users.
Deeming — now called “use estimation” — is a process for estimating water use where meters are not installed.
However, it simply doesn’t apply to unmetered domestic and stock users, who neither need nor benefit from it.
Internal GMW data shows deeming costs are almost entirely linked to irrigators, not households:
· Irrigators incur about $68.52 per licence for deeming activities.
· Domestic and stock users are allocated about $4.01, but even that amount relates to a metering method GMW itself has said it doesn’t use.
This cost-sharing method has no factual or procedural basis.
If the ESC’s consultants had correctly recognised that deeming doesn’t apply to small unmetered customers, the Commission could not have lawfully approved the same Service Point Fee for both groups.
Error Three – Misrepresentation of Access Fee Cost Drivers
Finally, the Access Fee charged to all unregulated diverters is also based on false assumptions.
Consultants claimed GMW had shown that Access Fee costs are “driven by the number of service points rather than water volume.”
No data was ever produced to prove that.
In fact:
· GMW admitted as far back as 2016 that it had no cost data to support this claim.
· The ESC itself required GMW to “improve its cost data” — effectively confirming that such evidence still doesn’t exist.
· Most activities said to justify the Access Fee (like water ordering and streamflow management) don’t apply to small domestic diverters at all.
Data from the Victorian Water Register shows irrigators account for about 95% of all licensed water on unregulated streams, while domestic and stock users hold barely 5%.
Yet both groups are charged as if they create the same costs.
If the Access Fee were fairly based on water volume rather than service count, small domestic users would pay only a fraction of what they are charged today.
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