In 1886, a regulatory framework was introduced by Alfred Deakin, then Victoria's Minister for Water Supply to promote orderly development of water resources for irrigation. Cracks in that framework became evident nearly a 100 years later and forced a reconsideration of the regime. In 1989 a new Water Act unveiled a form of property rights in water resources. Northern Victoria, the cradle of large irrigation schemes in Australia, was the focus of change when new rights for the Goulburn and Murray catchments in Northern Victoria were issued in 1995 and 1999 respectively. By doing so, the State separated water title from land and formally provided water for flora and fauna use. This article describes the main features of the new 1989 legal regime, and assesses key issues involved in converting poorly specified existing uses of water under the regulatory regime to firm, semi-exclusive, tradeable property rights called "Bulk Entitlements". After probing the tensions between private consumptive use and environmental allocations, I suggest a number of reasons why Victoria's conversion process falls short of expectations.