Landholders upstream of Tharwa could have been illegally pumping river water and reducing the already poor flow to the village, evidence shows.
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Before recent rainfall, the flow of water in the Murrumbidgee River near the village was so light it stopped, with stagnant pools forming by the Tharwa Bridge.
In December 2019, conditions were so dire the ACT government trucked non-potable water into Tharwa for the first time to top up supply.
A spokeswoman for NSW's water regulator confirmed it issued two stop work orders because of illegal pumping in the same month.
"The Natural Resources Access Regulator is investigating reports of alleged unlawful water take from the Murrumbidgee River, in the Numeralla area [near Cooma]," the spokeswoman said.
"Cease-to-pump rules, triggered by low flows, [were] in place for holders of water access licences for irrigation purposes.
"Where any unlawful water take is occurring there may be impacts downstream, to both water users and the environment".
Local community association president Kevin Jeffery said the river reached its driest point in 20 years in December 2019. He, like the water regulator, believed the suspected illegal pumping could have made an already bad situation worse.
Water supply issues have plagued Tharwa since the 1980s.
"Once [the Murrumbidgee River is] so dry that the water's not flowing, it takes a lot of water to get it back flowing again," Mr Jeffery said.
"If you just look after it and keep it flowing a little bit, it keeps everyone happy."
The NSW water regulator's findings are backed up by University of Canberra associate professor in water science Dr Fiona Dyer.
Her analysis suggests when the Murrumbidgee River stopped flowing upstream of Tharwa in late 2019 - between Mittagang Crossing and Billilingra - "there looked to be pumping involved".
During periods in November and December, when cease-to-pump restrictions applied, river water levels downstream at Billilingra were lower than upstream at Mittagang Crossing.
Numeralla is between Mittagang Crossing and Billilingra.
River flow is meant to increase, not decrease, as it travels further downstream.
"You would expect the flow at Billilingra to be higher than at Mittagang Crossing, unless water is being taken out of the river," Dr Dyer said.
"There are rules in place to protect the environment and downstream communities and I find it hard that people would not abide by those rules under really serious drought conditions.
"[When they don't] both the environment and downstream communities suffer."
A Snowy Monaro Regional Council spokesman said it was confident the regulator would "assess the severity of any proven breach and take action as appropriate".
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Despite knowing the stop work orders had been issued, an ACT government spokesman said it was not aware of any illegal water pumping at Numeralla.
"In late 2019, flows in the Murrumbidgee River at Tharwa ceased due to extended dry conditions in the region," the spokesman said.
"This had direct impacts on the people of Tharwa and required alternate water supply be provided by the ACT Parks and Conservation service."
Mr Jeffery said the Tharwa community wanted the ACT government to care more about illegal pumping upstream.
"Essentially everything that's [outside] of the Cotter [catchment] supply for Canberra appears to be disregarded," he said.
Although some water was taken out of the Murrumbidgee River for firefighting late last year, it would not have been enough to impact water levels, Mr Jeffery said.
"The amount that goes on irrigation for one farm is massively more than you could possibly extract with helicopters," he said.
"It seems like a lot when a helicopter will suck a town swimming pool dry, but when you actually compare that with how much water is [used] in irrigation, it's tiny."
Tharwa residents rely on Murrumbidgee River water for non-potable uses, like garden maintenance. A community run system pumps it into a tank behind the village store and gravity feeds it through a network of pipes.
Village households access drinking water through private rain-fed tanks.
NSW-issued licenses, which allow landholders to pump water out of the Murrumbidgee River, include conditions that they must not pump when the river is at "very low flow".